At the end of August, the FCC issued a new Notice of Proposed Rulemaking (NPRM) that would make it even easier for telephone companies to tear down copper networks. The Rulemaking proposes to change the disclosure laws, meaning that there won’t be a lot of required notice to the public or other carriers when copper will be retired. This Docket would formalize the temporary process instituted in July where the FCC exempted telcos from many of the notice procedures for two years.

It turns out that the current FCC regulations include dozens of different kinds of notices must be given when a telco wants to tear down copper. The NPRM goes through many pages and specific language changes that are needed to eliminate the many rules associated with decommissioning copper. I have to admit that I didn’t realize how complex it is to decommission copper until I read this document.

While this is titled as an NPRM, where the FCC asks for public feedback on various proposed changes to FCC regulations, this doesn’t feel like an NPRM where the FCC is really seeking feedback. Instead, this feels like a document where the FCC has already decided what it is going to do, and this process is a formality, since not going through an NPRM and getting public feedback can lead to legal challenges. This is not that unusual, and all prior FCCs have issued some NPRMs where the results were a foregone conclusion.

This is the first FCC document in many years that hints at dismantling the vestiges of the Public Switched Telephone Network (PSTN) that is in place to interconnect telephone companies. As hard as it is to believe in 2025, a lot of that network still includes connections between telcos, called trunks, that still use the TDM technology that drove copper networks. Small telcos, CLECs, cellular carriers, and others that directly interconnect with the big telcos should be on the lookout for the disconnection of TDM trunks that carry traffic between local companies.

That will make for an interesting change in the telephone network. One of the things that protected the PSTN from the big nationwide or regional outages was that the network was arranged into regional networks that surrounded large tandem switches, most often, but not always, owned by the biggest telcos. Since 70% or more of telephone calls are somewhat local and don’t leave a region, the local PSTN trunk network allows calls to travel for free between telcos and others in a region. I would expect that, as the PSNT is dismantled, small telcos and CLECs will have to pay to carry calls to and from the replacement network.

I find it likely that as copper is retired, the tandem switching network will go with it, and the big telcos will likely establish a handful of national tandem hubs where everybody else will have to bring traffic. This has been on the wish list for the big telcos for several decades, and if they are allowed to finally dismantle the PSTN, then regional tandem switches will not be far behind.

I wrote about a similar issue in a blog last year when I warned about the dangers of 911 consolidation, which is creating large 911 hubs, meaning that a 911 call can be carried far out of state before it’s answered. That greatly increases the chance of 911 calls not working because of network issues that happen in another state. I’ve been recommending that States should consider not allowing 911 calls to be routed outside of their State.