# POTS line replacement and copper retirement Canonical: https://warmtransfer.net/knowledge/pots-line-replacement Last verified: 2026-10-02 The FCC adopted its Network and Services Modernization Report and Order (FCC 26-19, WC Docket Nos. 25-208 and 25-209) on March 26, 2026, and the order grants carriers blanket section 214(a) authority to grandfather legacy voice service, lower-speed data telecommunications service, and interconnected VoIP provisioned over copper wire[^25][^21]. FCC 26-19 also eliminates all Commission filing requirements in the network change disclosure rules for copper retirements and short-term network changes, while incumbent LECs must still give direct notice to directly interconnected telephone exchange service providers and 911 service providers[^32][^31]. ## Regulatory timeline - The FCC adopted its Technology Transitions order (FCC 16-90) on July 14, 2016 and released it on July 15, 2016[^3]. - On March 20, 2025, the FCC Wireline Competition Bureau waived the Commission filing requirements of the network change disclosure rules, and the associated public notice and objection processes, for 2 years (DA 25-252)[^34]. - The FCC adopted FCC 26-19 on March 26, 2026 and released it on March 27, 2026[^25]. - The Federal Register published FCC 26-19 as FR Doc. 2026-07622 on April 20, 2026, and that publication made the rules effective May 20, 2026[^28]. - The amendments to sections 51.329, 51.333, 63.60, 63.62, 63.63, 63.71 and 63.602 were delayed indefinitely[^28]. ## Network change notice for copper retirement Under the network change rules before the 2025 waiver, copper retirements could not be implemented until at least 90 days after the Bureau's public notice[^37]. Short-term network changes could not be implemented until at least 10 business days after that notice[^37]. Under the 2025 waiver, incumbent LECs still had to give public notice as soon as practicable for network changes caused by force majeure or other events outside their control[^27]. They also had to communicate directly with interconnected providers about those changes[^27]. FCC 26-19 eliminates the Commission filing requirements in the network change disclosure rules[^32]. It also eliminates the Bureau public notice process and the interconnected-provider objection process for copper retirements and short-term network changes[^32]. The amendments to sections 51.329 and 51.333 are among those whose effective date was delayed indefinitely[^28], and whether these network change eliminations depend on those sections is not covered by the sources below. The following obligations remain after FCC 26-19: - Incumbent LECs must give direct notice of copper retirements and short-term network changes to directly interconnected telephone exchange service providers, 911 service providers, and directly interconnecting LECs that support essential 911 network functions[^31]. - Incumbent LECs must post public notice of planned network changes through industry fora, industry publications, or the carrier's publicly accessible internet site[^33]. The FCC states that neither section 251(c)(5) nor its implementing network change rules impose notice obligations toward end users[^35]. Under those rules, retail customers learn of copper retirements only as a matter of carrier practice[^35]. ## Grandfathering and discontinuance Before a carrier grandfathers service under the blanket authority, it must notify affected customers[^29]. That notice must include a "no earlier than" date by which the carrier intends to seek permanent discontinuance[^29]. FCC 26-19 revises section 63.71 so that a 31-day automatic grant period applies to all discontinuance applications, whether the applicant is dominant or non-dominant[^5]. The FCC lists section 63.71 among the amendments whose effective date was delayed indefinitely[^28]. FCC 26-19 finds that federal law preempts state and local requirements to the extent they impede providers from discontinuing interstate and jurisdictionally mixed legacy services the FCC has authorized them to discontinue[^49]. ## Qualifying replacement services Under the consolidated technology transition discontinuance rule, a carrier qualifies for streamlined treatment by certifying that at least 1 qualifying replacement service is available at every location throughout the affected service area[^38]. FCC 26-19 recognizes these replacement categories: - Facilities-based interconnected VoIP service[^39]. - Facilities-based mobile wireless service, where it offers at least 5/1 Mbps as reflected on the National Broadband Map[^41]. - Voice service supported through the Commission's modernized high-cost support programs[^40]. - The carrier's own alternative voice service, if it has been available for at least the immediately preceding 60 days with substantially similar network performance[^43]. - A widely available third-party voice service that is available at all locations in the affected area and provides access to 911[^44]. For discontinuance purposes, the FCC does not require replacement VoIP to be offered on a stand-alone basis[^55]. Under that rule, a bundled offering can count as an adequate replacement[^55]. ## Backup power and 911 on replacement service FCC 15-98 required providers of facilities-based fixed residential voice service that is not line-powered to offer subscribers an option for 8 hours of standby backup power at the point of sale[^17]. FCC 15-98 required covered providers to also offer a 24-hour standby backup power option within 3 years[^16]. Under FCC 15-98, no provider must install backup power unless the subscriber requests it and pays for it[^19]. FCC 15-98 also imposes no retrofit obligation for existing installations[^19]. AT&T states that AT&T Phone - Advanced includes a built-in 24-hour battery backup intended to keep service working during an electrical outage[^12]. AT&T discloses that without backup battery power, AT&T Phone service, including 911 dialing, will not work during a power outage[^14]. ## Alarm, medical, fire, and elevator lines The 2016 technology transitions rules required replacement services to be compatible with legacy devices such as alarms and medical monitors[^2]. According to the FCC's account in FCC 26-19, that requirement sunset in 2025[^2]. The FCC declined to condition technology transition discontinuances on the replacement supporting a G.711 codec handshake with RFC 2833 disabled on calls to life safety alarm monitoring receivers[^9]. The FCC gave 2 answers to concerns about home security alarms and medical monitoring devices[^10]: - The streamlined rules still require customer notice and give consumers an opportunity to comment or object[^10]. - IP-based and wireless device options exist[^10]. AT&T describes AT&T Phone - Advanced as compatible with most alarm, medical monitoring and teletypewriter devices[^13]. AT&T does not claim universal compatibility[^13]. WarmTransfer's reading of the sources is that an FCC discontinuance grant does not by itself establish that a replacement is acceptable for a fire alarm or elevator line[^26]. We infer that acceptance of those communication paths remains with the local authority having jurisdiction, which applies its adopted NFPA 72 or ASME A17.1 edition[^26]. ### Fire alarm signaling: San Diego example San Diego's fire alarm bulletin allows a DACT to use only 1 telephone line, paired with another NFPA 72 Chapter 26 method[^46]. The bulletin says NFPA 72 no longer allows 2 telephone lines[^46]. San Diego accepts DACTs, cellular communicators and IP transmitters for fire alarm signaling when they comply with NFPA 72 Chapter 26 and are listed by the California State Fire Marshal[^45]. San Diego requires IP fire alarm communicators to be installed so that server maintenance does not cause loss of communication with the supervising station[^47]. ### Elevator emergency communication According to NEII, ASME A17.1-2019 requirement 2.27.1 adds the ability for authorized personnel to assess an entrapment by viewing the elevator cab[^7]. According to NEII, the same requirement adds the ability for authorized personnel to query passengers by visual messages and receive non-verbal responses[^8]. NEII also says the requirement adds the ability for authorized personnel to initiate in-car notifications[^8]. We infer that elevators subject to the 2019 A17.1 video and visual-message features need a communication path that carries data as well as voice[^6]. This is inferred to mean that a like-for-like analog voice replacement alone may be insufficient for those installations[^6]. ## Carrier and state activity ### AT&T AT&T said in August 2025 that the FCC had approved its application to discontinue copper-based services in about 10% of its wire centers[^11]. In the same statement, AT&T committed that no customer would be left without voice or 911 service as copper services are discontinued[^15]. AT&T named AT&T Phone - Advanced, fiber and wireless as the paths for that commitment[^15]. ### Verizon On August 10, 2026, Verizon ILEC affiliates, together with Frontier entities, applied to discontinue residential and business legacy TDM-based voice service[^51]. The application covers portions of Arizona, Delaware, New Jersey, New Mexico, Ohio, Rhode Island, South Carolina, Utah and Virginia[^51]. The application had been scheduled for automatic grant on September 26, 2026[^52]. On September 25, 2026, the Wireline Competition Bureau removed it from automatic grant[^52]. The FCC stated that pulling the application from automatic grant is not a final determination on the merits of the discontinuance request[^53]. ### California On June 28, 2024, the California Public Utilities Commission rejected AT&T California's request to withdraw as carrier of last resort in parts of its service territory[^24]. The CPUC's stated reason was that AT&T failed to demonstrate replacement providers willing and able to serve as carrier of last resort[^22]. Alongside the rejection, the CPUC opened a new rulemaking to update its carrier of last resort rules for changed market and technology conditions[^23]. ## See also - [Analog gateways ATA and paging devices](https://warmtransfer.net/knowledge/analog-gateways-ata) - [Troubleshooting analog phones and FXS ports with no dial tone or failed calls](https://warmtransfer.net/knowledge/analog-fxs-troubleshooting) - [PRI and TDM gateway interworking](https://warmtransfer.net/knowledge/legacy-pri-tdm) - [Troubleshooting 911 calls that route with the wrong location](https://warmtransfer.net/knowledge/e911-routing-failures) - [Fax and T.38 in cloud calling](https://warmtransfer.net/knowledge/fax-t38) ## Applicability Applies to: AT&T Phone - Advanced, AT&T, and Verizon. Deployments: carrier-network, elevator, premises-fire-alarm, residential, and residential-fixed-voice. Sources checked 2026-10-02. The FCC 26-19 rules took effect May 20, 2026, except for amendments to sections 51.329, 51.333, 63.60, 63.62, 63.63, 63.71 and 63.602, which were delayed indefinitely[^28]. The fire alarm communication rules described here come from San Diego's bulletin[^45]. The elevator features described here are those NEII attributes to ASME A17.1-2019 requirement 2.27.1[^7]. The carrier of last resort decision described here applies to AT&T California[^24]. ## What remains uncertain - The current text of 47 CFR 51.332 and the copper retirement notice day count after FCC 26-19 are not covered by the sources below. - The 90-day figure applies only to the rules as they stood before the 2025 waiver[^37]. - The amendments to sections 51.329, 51.333, 63.60, 63.62, 63.63, 63.71 and 63.602 were delayed indefinitely[^28]. The OMB approval notice that would set their effective date is not covered by the sources below. - The NFPA 72 2022 and 2025 Chapter 26 text on DACT, cellular, and IP paths is not covered by the sources below. - The primary text of ASME A17.1 requirement 2.27.1 is not covered by the sources below, including any backup power or daily line verification provisions. - San Diego requires California State Fire Marshal listing for fire alarm communicators[^45]. Which POTS replacement devices hold UL 864, UL 1610, or California State Fire Marshal listings is not covered by the sources below. - Carrier price increases on analog business and residential lines are not covered by the sources below. - The FCC stated that removing Verizon's application from automatic grant is not a final determination on the merits[^53]. The final outcome of WC Docket 26-227 is not covered by the sources below. - The USTelecom forbearance orders on legacy voice and copper, including the 2019 order FCC 19-72 and later orders, are not covered by the sources below. - WarmTransfer's reading of the sources is that local authorities having jurisdiction, not FCC grants, decide whether replacements are acceptable for fire alarm and elevator lines[^26]. Readers should verify that reading with their local authority[^26]. ## Sources [^1]: FCC 16-90 created an adequate replacement test for technology transition discontinuances with three elements: substantially similar network performance and service quality; 911, cybersecurity and disability access; and interoperability with an enumerated list of key applications and functionalities. Source: [Declaratory Ruling, Second Report and Order, and Order on Reconsideration, Technology Transitions (FCC 16-90)](https://docs.fcc.gov/public/attachments/FCC-16-90A1.txt), paras. 65, 89, 127, 159 (as reported by extraction). Checked 2026-10-02. [^2]: The 2016 technology transitions rules' requirement that replacement services be compatible with legacy devices such as alarms and medical monitors sunset in 2025, per the FCC's own account in FCC 26-19. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 30. Checked 2026-10-02. [^3]: The FCC's Technology Transitions order (FCC 16-90) was adopted July 14, 2016 and released July 15, 2016. Source: [Declaratory Ruling, Second Report and Order, and Order on Reconsideration, Technology Transitions (FCC 16-90)](https://docs.fcc.gov/public/attachments/FCC-16-90A1.txt), Caption block. Checked 2026-10-02. [^4]: For streamlined technology transition discontinuances, the 2026 consolidated rule's replacement-service categories take the place of the 2016 adequate replacement test as the operative standard (inferred). Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), paras. 6 and 23 read with FCC 16-90 para. 65. Checked 2026-10-02. [^5]: FCC 26-19 revises section 63.71 so that a 31-day automatic grant period applies to all discontinuance applications, whether the applicant is dominant or non-dominant. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 6. Checked 2026-10-02. [^6]: Elevators subject to the 2019 A17.1 video and visual-message features need a communication path that carries data as well as voice, so a like-for-like analog voice replacement alone may be insufficient for those installations (inferred). Source: [Elevator Emergency Communications](https://nationalelevatorindustry.org/elevator-emergency-communications/), 2019 edition enhancements list. Checked 2026-10-02. [^7]: According to NEII, ASME A17.1-2019 requirement 2.27.1 adds the ability for authorized personnel to assess an entrapment by viewing the elevator cab. Source: [Elevator Emergency Communications](https://nationalelevatorindustry.org/elevator-emergency-communications/), 2019 edition enhancements list, item 1. Checked 2026-10-02. [^8]: According to NEII, ASME A17.1-2019 requirement 2.27.1 adds the ability for authorized personnel to query passengers by visual messages and receive non-verbal responses, and to initiate in-car notifications. Source: [Elevator Emergency Communications](https://nationalelevatorindustry.org/elevator-emergency-communications/), 2019 edition enhancements list, items 2-3. Checked 2026-10-02. [^9]: The FCC declined to condition technology transition discontinuances on the replacement supporting a G.711 codec handshake with RFC 2833 disabled on calls to life safety alarm monitoring receivers. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 31. Checked 2026-10-02. [^10]: The FCC's answer to concerns about home security alarms and medical monitoring devices is that streamlined rules still require customer notice and give consumers an opportunity to comment or object, and that IP-based and wireless device options exist. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 30. Checked 2026-10-02. [^11]: AT&T said in August 2025 that the FCC had approved its application to discontinue copper-based services in about 10% of its wire centers. Source: [AT&T Statement on FCC 214 Discontinuance Approval](https://www.attconnects.com/stories/att-statement-on-fcc-214-discontinuance-approval/), Statement body. Checked 2026-10-02. [^12]: AT&T states that AT&T Phone - Advanced includes a built-in 24-hour battery backup intended to keep service working during an electrical outage. Source: [AT&T Home Phone](https://www.att.com/home-phone/), AT&T Phone - Advanced section. Checked 2026-10-02. [^13]: AT&T describes AT&T Phone - Advanced as compatible with most alarm, medical monitoring and teletypewriter devices; it does not claim universal compatibility. Source: [AT&T Home Phone](https://www.att.com/home-phone/), AT&T Phone - Advanced feature list. Checked 2026-10-02. [^14]: AT&T discloses that without backup battery power, AT&T Phone service including 911 dialing will not work during a power outage. Source: [AT&T Home Phone](https://www.att.com/home-phone/), Disclaimer / legal text. Checked 2026-10-02. [^15]: In its August 2025 statement AT&T committed that no customer would be left without voice or 911 service as copper services are discontinued, naming AT&T Phone - Advanced, fiber and wireless as the paths. Source: [AT&T Statement on FCC 214 Discontinuance Approval](https://www.attconnects.com/stories/att-statement-on-fcc-214-discontinuance-approval/), Statement body. Checked 2026-10-02. [^16]: FCC 15-98 required covered providers, within three years, to also offer a 24-hour standby backup power option. Source: [Report and Order, Ensuring Continuity of 911 Communications (FCC 15-98)](https://docs.fcc.gov/public/attachments/FCC-15-98A1.txt), para. 34. Checked 2026-10-02. [^17]: FCC 15-98 required providers of facilities-based fixed residential voice service that is not line-powered to offer subscribers at the point of sale an option for 8 hours of standby backup power. Source: [Report and Order, Ensuring Continuity of 911 Communications (FCC 15-98)](https://docs.fcc.gov/public/attachments/FCC-15-98A1.txt), paras. 25, 29, 31. Checked 2026-10-02. [^18]: Given the ten-year limit, the federal backup power offering and disclosure duties for non-line-powered residential voice have probably lapsed as of October 2026 unless extended, so battery backup on a POTS replacement is now a matter of carrier offer, contract or local code (inferred). Source: [Report and Order, Ensuring Continuity of 911 Communications (FCC 15-98)](https://docs.fcc.gov/public/attachments/FCC-15-98A1.txt), para. 4. Checked 2026-10-02. [^19]: Under FCC 15-98 no provider must install backup power unless the subscriber requests it and pays for it, and there is no retrofit obligation for existing installations. Source: [Report and Order, Ensuring Continuity of 911 Communications (FCC 15-98)](https://docs.fcc.gov/public/attachments/FCC-15-98A1.txt), paras. 30 and 43. Checked 2026-10-02. [^20]: FCC 15-98 limited the backup power obligations to ten years, with point-of-sale and annual subscriber disclosures running through September 1, 2025. Source: [Report and Order, Ensuring Continuity of 911 Communications (FCC 15-98)](https://docs.fcc.gov/public/attachments/FCC-15-98A1.txt), paras. 4 and 48. Checked 2026-10-02. [^21]: FCC 26-19 grants carriers blanket section 214(a) authority to grandfather legacy voice service, lower-speed data telecommunications service, and interconnected VoIP provisioned over copper wire. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 6. Checked 2026-10-02. [^22]: The CPUC's stated reason was that AT&T failed to demonstrate replacement providers willing and able to serve as carrier of last resort. Source: [CPUC Rejects AT&T Request to Withdraw as Carrier](https://www.cpuc.ca.gov/news-and-updates/all-news/cpuc-rejects-att-request-to-withdraw-as-carrier), Press release, reasons paragraph. Checked 2026-10-02. [^23]: Alongside the 2024 rejection, the CPUC opened a new rulemaking to update its carrier of last resort rules for changed market and technology conditions. Source: [CPUC Rejects AT&T Request to Withdraw as Carrier](https://www.cpuc.ca.gov/news-and-updates/all-news/cpuc-rejects-att-request-to-withdraw-as-carrier), Press release, closing paragraphs. Checked 2026-10-02. [^24]: On June 28, 2024 the California Public Utilities Commission rejected AT&T California's request to withdraw as carrier of last resort in parts of its service territory. Source: [CPUC Rejects AT&T Request to Withdraw as Carrier](https://www.cpuc.ca.gov/news-and-updates/all-news/cpuc-rejects-att-request-to-withdraw-as-carrier), Press release, opening paragraph. Checked 2026-10-02. [^25]: The FCC adopted its Network and Services Modernization Report and Order (FCC 26-19, WC Docket Nos. 25-208 and 25-209) on March 26, 2026 and released it on March 27, 2026. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), Caption block (Adopted/Released dates; docket numbers). Checked 2026-10-02. [^26]: An FCC discontinuance grant does not by itself establish that a replacement is acceptable for a fire alarm or elevator line; acceptance of those communication paths remains with the local authority having jurisdiction applying its adopted NFPA 72 or ASME A17.1 edition (inferred). Source: [Technical Bulletin FIRE-9-2: Requirements for Fire Alarm Control Panels](https://www.sandiego.gov/development-services/forms-publications/technical-bulletins/FIRE9-2), Communication methods section; read together with FCC 26-19 paras. 30-31. Checked 2026-10-02. [^27]: Under the 2025 waiver, incumbent LECs still had to give public notice as soon as practicable, and communicate directly with interconnected providers, for network changes caused by force majeure or other events outside their control. Source: [Order, Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment (DA 25-252)](https://docs.fcc.gov/public/attachments/DA-25-252A1.txt), para. 7. Checked 2026-10-02. [^28]: The Federal Register publication of FCC 26-19 (FR Doc. 2026-07622, April 20, 2026) made the rules effective May 20, 2026, except for amendments to sections 51.329, 51.333, 63.60, 63.62, 63.63, 63.71 and 63.602, which were delayed indefinitely. Source: [Reducing Barriers to Network Improvements and Service Changes (Final rule, FCC 26-19)](https://www.govinfo.gov/content/pkg/FR-2026-04-20/html/2026-07622.htm), DATES section. Checked 2026-10-02. [^29]: Before grandfathering under the blanket authority, a carrier must notify affected customers, and the notice must include a 'no earlier than' date by which the carrier intends to seek permanent discontinuance. Source: [Reducing Barriers to Network Improvements and Service Changes (Final rule, FCC 26-19)](https://www.govinfo.gov/content/pkg/FR-2026-04-20/html/2026-07622.htm), SUPPLEMENTARY INFORMATION, FR summary para. 52. Checked 2026-10-02. [^30]: For the blanket grandfathering authority, lower-speed data telecommunications service means service below 25/3 Mbps. Source: [Reducing Barriers to Network Improvements and Service Changes (Final rule, FCC 26-19)](https://www.govinfo.gov/content/pkg/FR-2026-04-20/html/2026-07622.htm), SUPPLEMENTARY INFORMATION, FR summary para. 50. Checked 2026-10-02. [^31]: After FCC 26-19, incumbent LECs must still give direct notice of copper retirements and short-term network changes to directly interconnected telephone exchange service providers, 911 service providers, and directly interconnecting LECs that support essential 911 network functions. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 12. Checked 2026-10-02. [^32]: FCC 26-19 eliminates all Commission filing requirements in the network change disclosure rules, together with the Bureau public notice process and the interconnected-provider objection process for copper retirements and short-term network changes. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 12. Checked 2026-10-02. [^33]: Incumbent LECs remain required to post public notice of planned network changes through industry fora, industry publications, or on the carrier's publicly accessible internet site. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 12. Checked 2026-10-02. [^34]: On March 20, 2025 the FCC Wireline Competition Bureau waived the Commission filing requirements of the network change disclosure rules, and the associated public notice and objection processes, for two years (DA 25-252). Source: [Order, Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment (DA 25-252)](https://docs.fcc.gov/public/attachments/DA-25-252A1.txt), paras. 1 and 6. Checked 2026-10-02. [^35]: The FCC states that neither section 251(c)(5) nor its implementing network change rules impose notice obligations toward end users; retail customers learn of copper retirements only as a matter of carrier practice under those rules. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 14. Checked 2026-10-02. [^36]: The fetched text of FCC 26-19 does not appear to address fire alarm control panels, elevator emergency phones, fax machines, modems or NFPA codes by name; its device discussion is framed around home security alarms and medical monitoring (inferred). Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), whole document (negative search via extraction model); device discussion at paras. 30-31. Checked 2026-10-02. [^37]: Under the network change rules as they stood before the 2025 waiver, copper retirements could not be implemented until at least 90 days after the Bureau's public notice, and short-term network changes at least 10 business days after it. Source: [Order, Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment (DA 25-252)](https://docs.fcc.gov/public/attachments/DA-25-252A1.txt), para. 5. Checked 2026-10-02. [^38]: Under the consolidated technology transition discontinuance rule, a carrier qualifies for streamlined treatment by certifying that at least one qualifying replacement service is available at every location throughout the affected service area. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 23. Checked 2026-10-02. [^39]: Facilities-based interconnected VoIP service is one of the replacement service categories that supports a technology transition discontinuance under FCC 26-19. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 32. Checked 2026-10-02. [^40]: Voice service supported through the Commission's modernized high-cost support programs is a qualifying replacement category under FCC 26-19. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 36. Checked 2026-10-02. [^41]: Facilities-based mobile wireless service qualifies as a replacement under FCC 26-19 where it offers at least 5/1 Mbps as reflected on the National Broadband Map. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 34. Checked 2026-10-02. [^42]: The carrier's-own-service replacement category is described as requiring speeds of at least 25/3 Mbps and mouth-to-ear latency of no more than 200 ms. Source: [Reducing Barriers to Network Improvements and Service Changes (Final rule, FCC 26-19)](https://www.govinfo.gov/content/pkg/FR-2026-04-20/html/2026-07622.htm), SUPPLEMENTARY INFORMATION, FR summary para. 27. Checked 2026-10-02. [^43]: A carrier's own alternative voice service qualifies as a replacement under FCC 26-19 if it has been available for at least the immediately preceding 60 days with substantially similar network performance. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 37. Checked 2026-10-02. [^44]: A widely available third-party voice service that is available at all locations in the affected area and provides access to 911 is a qualifying replacement category under FCC 26-19. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 23. Checked 2026-10-02. [^45]: San Diego accepts DACTs, cellular communicators and IP transmitters for fire alarm signaling when they comply with NFPA 72 Chapter 26 and are listed by the California State Fire Marshal. Source: [Technical Bulletin FIRE-9-2: Requirements for Fire Alarm Control Panels](https://www.sandiego.gov/development-services/forms-publications/technical-bulletins/FIRE9-2), Communication methods section. Checked 2026-10-02. [^46]: San Diego's fire alarm bulletin allows a DACT to use only one telephone line, paired with another NFPA 72 Chapter 26 method, and says NFPA 72 no longer allows two telephone lines. Source: [Technical Bulletin FIRE-9-2: Requirements for Fire Alarm Control Panels](https://www.sandiego.gov/development-services/forms-publications/technical-bulletins/FIRE9-2), Communication methods section. Checked 2026-10-02. [^47]: San Diego requires IP fire alarm communicators to be installed so that server maintenance does not cause loss of communication with the supervising station. Source: [Technical Bulletin FIRE-9-2: Requirements for Fire Alarm Control Panels](https://www.sandiego.gov/development-services/forms-publications/technical-bulletins/FIRE9-2), Supervising station / IP communicator paragraph. Checked 2026-10-02. [^48]: How far FCC 26-19's preemption finding overrides state carrier-of-last-resort rules such as California's is unresolved in the evidence gathered; state COLR duties may continue to shape timing even where the FCC has authorized discontinuance (inferred). Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 7 read with CPUC press release of 2024-06-28. Checked 2026-10-02. [^49]: FCC 26-19 finds that federal law preempts state and local requirements to the extent they impede providers from discontinuing interstate and jurisdictionally mixed legacy services the FCC has authorized them to discontinue. Source: [Accelerating Network Modernization; Reducing Barriers to Network Improvements and Service Changes, Report and Order (FCC 26-19)](https://docs.fcc.gov/public/attachments/FCC-26-19A1.txt), para. 7. Checked 2026-10-02. [^50]: FCC 26-19 does not set TTY-specific replacement conditions; accessibility questions are referred to the Commission's separate TRS modernization proceeding. Source: [Reducing Barriers to Network Improvements and Service Changes (Final rule, FCC 26-19)](https://www.govinfo.gov/content/pkg/FR-2026-04-20/html/2026-07622.htm), SUPPLEMENTARY INFORMATION, FR summary paras. 40-42. Checked 2026-10-02. [^51]: On August 10, 2026, Verizon ILEC affiliates (with Frontier entities) applied to discontinue residential and business legacy TDM-based voice service in portions of Arizona, Delaware, New Jersey, New Mexico, Ohio, Rhode Island, South Carolina, Utah and Virginia. Source: [Application of Verizon to Discontinue Domestic Legacy Voice Service as Part of a Technology Transition Is Not Automatically Granted (DA 26-1038)](https://docs.fcc.gov/public/attachments/DA-26-1038A1.txt), Opening paragraph (WC Docket No. 26-227). Checked 2026-10-02. [^52]: On September 25, 2026 the Wireline Competition Bureau removed Verizon's legacy voice discontinuance application from automatic grant, which had been scheduled for September 26, 2026. Source: [Application of Verizon to Discontinue Domestic Legacy Voice Service as Part of a Technology Transition Is Not Automatically Granted (DA 26-1038)](https://docs.fcc.gov/public/attachments/DA-26-1038A1.txt), Public notice body, first and second paragraphs. Checked 2026-10-02. [^53]: The FCC stated that pulling Verizon's application from automatic grant is not a final determination on the merits of the discontinuance request. Source: [Application of Verizon to Discontinue Domestic Legacy Voice Service as Part of a Technology Transition Is Not Automatically Granted (DA 26-1038)](https://docs.fcc.gov/public/attachments/DA-26-1038A1.txt), Public notice body, closing paragraph. Checked 2026-10-02. [^54]: The Verizon schedule (application filed August 10, 2026; auto-grant date September 26, 2026, set by an August 26, 2026 public notice) is consistent with the uniform 31-day automatic grant period being applied to a dominant carrier by August 2026, despite the FR listing the 63.71 amendment as delayed (inferred). Source: [Application of Verizon to Discontinue Domestic Legacy Voice Service as Part of a Technology Transition Is Not Automatically Granted (DA 26-1038)](https://docs.fcc.gov/public/attachments/DA-26-1038A1.txt), Public notice body, procedural history; compare FR Doc. 2026-07622 DATES. Checked 2026-10-02. [^55]: For discontinuance purposes the FCC does not require replacement VoIP to be offered on a stand-alone basis; a bundled offering can count as an adequate replacement. Source: [Reducing Barriers to Network Improvements and Service Changes (Final rule, FCC 26-19)](https://www.govinfo.gov/content/pkg/FR-2026-04-20/html/2026-07622.htm), SUPPLEMENTARY INFORMATION, FR summary para. 31. Checked 2026-10-02.