Mar 21 Oppose Letter for AB 470, Telephone corporations: carriers of last resort

March 17, 2025

The Honorable Assemblymember Tina McKinnor
California State Assembly District 61  
1021 O Street, Suite 5520  
Sacramento, CA 95814

Re: AB 470 (McKinnor), Telephone corporations: carriers of last resort – Oppose

Dear Assemblymember McKinnor,

On behalf of the Marin County Board of Supervisors, I write in respectful opposition to AB 470, which would allow any Carrier of Last Resort (COLR), in specified areas, to no longer provide service in those locations if the provider submits a notice to the California Public Utilities Commission (CPUC) that it meets certain requirements.  

This legislation would accomplish the same aims as AT&T’s application to the CPUC for relief of its COLR obligations, which was dismissed last year by Administrative Law Judge Glegola and faced substantial public opposition, with over 5,000 people publicly commenting against the application last year. AB 470 would provide a legislative path forward for AT&T to get out of its COLR obligations with minimal oversight, threatening potentially significant negative effects to the more than 580,000 customers in California that rely on Plain Old Telephone Services (POTS) under AT&T’s current COLR obligations. 

For some of our County’s most vulnerable residents, especially those in more geographically remote and rural areas without cell phone reception, AT&T’s withdrawal from COLR obligations would result in them paying more for telephone service, receiving lower quality service, being required to purchase phone service as part of an expensive “bundle,” or receiving no phone service at all. AT&T's application requests COLR relief in providing landline service for over 99% of its service territory where it determines an alternative voice provider exists (VoIP, wireless, etc.) and does not request a replacement COLR. Since the definition of “alternative voice provider exists” is based on demonstration that a carrier’s footprint covers only 50% of the census block, residents in the remaining 50% are in danger of having no phone service.  

Additionally, AT&T’s application describes the COLR requirement as an “underutilized landline telephone network,” however, in households with limited cell phone coverage, landlines are far from underutilized. Landlines provide essential communications, especially in emergencies, to households without cell coverage and/or other connectivity options. Over 580,000 AT&T customers would be affected – including 28,800 households in Marin County – many of whom are senior citizens, live in low-income households, or reside in rural areas where other connectivity is not available to them, placing their lives in jeopardy in the event of an emergency. This includes:  

• Approximately 630 households in west Marin who have no other option if the AT&T application is approved, and  
• Approximately 23,000 residents in suburban and urban areas that currently subscribe to AT&T’s plain landline service and may have to select a different carrier and/or pay more if the application is approved.  

Over time, telecommunications firms (like AT&T) charged with providing this service and maintaining the state’s copper landline network have not taken necessary actions to maintain their networks, despite recording record profits from their consumer businesses. This deferred maintenance has created a growing logistical challenge, and the CPUC should not reward firms responsible for unmaintained networks with relaxed regulations that leave underserved populations vulnerable to disaster and loss of communication.  

Last year, Marin County opposed both AT&T’s application to withdraw from its COLR obligations, as well as nearly identical legislation in AB 2797 (McKinnor), which sought to give AT&T and other COLR providers the ability to withdraw from their COLR obligations if the provider submits a notice to the CPUC. AB 470 would again allow providers to more easily renege on their COLR obligations, leaving hundreds of Marin County residents, and thousands of other California residents in rural areas without the POTS services they require to remain on the cell network.  

The CPUC’s core function is to balance procedures and safeguards to protect consumers as well as ensure the provision of safe, reliable utilities and infrastructure at reasonable rates. AB 470 puts the industry’s interests ahead of the needs of a diverse state. Much of rural Marin County is already under- or un-served, lacking universal access to reliable, secure, and open networks. COLR rules remain essential and must continue to prioritize consumer protections and universal access while facilitating the transition to modern networks.  

For these reasons, Marin County opposes AB 470, as this legislation does not address these inequities, but rather increases them.  

Sincerely,  

Mary Sackett, President
Marin County Board of Supervisors

CC:    Marin County Board of Supervisors
Assemblymember Damon Connolly
Senator Mike McGuire