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Telecom Alert: AT&T California COLR Obligation; AI Technology Subject to TCPA; Pole Attachment Petition Pleading Cycle; Reminder of FCC Discontinuance Rules [Vol. XXI, Issue 7]

AT&T California Requests Relief from COLR Obligation

AT&T California is seeking relief from its Carrier of Last Resort (“COLR”) obligation, which requires AT&T to provide basic landline telephone service to any customer requesting such service in a specified area.   AT&T argues that its COLR obligation is outdated and effectively mandates AT&T to continue building out a copper-based network that is becoming obsolete.  The company has asked the Public Utilities Commission of California to relieve AT&T of its COLR obligation in areas where consumers have access to alternative basic telephone service options.  For more information, please contact Greg Kunkle (; 202.434.4178). 

Declaratory Ruling on AI Technology Under the TCPA

The FCC released a Declaratory Ruling last week confirming that the Telephone Consumer Protection Act’s (“TCPA”) restrictions on the use of artificial or prerecorded voice includes AI technologies that generate human voices.  The TCPA is designed to protect consumers from unwanted calls by requiring consumer consent before using such artificial or prerecorded voice to make a call.  The Commission has now clarified that calls made using AI technology to generate human voices require the prior express consent of the called party before initiation, absent an emergency purpose or exemption.  For more information, please contact Wes Wright (; 202.434.4239).

Pole Attachment Petition for Reconsideration Pleading Cycle

The pleading cycle has been set in response to the Edison Electric Institute’s (“EEI”) petition asking the FCC to reconsider the declaratory ruling it made in December 2023, which established a process for review of pole attachment disputes and outlined pole owners’ responsibility to share easement information.  Oppositions are due by February 13 and replies to oppositions are due by February 23.  For more information, please contact Tom Magee (; 202.434.4128) or Tim Doughty (; 202.434.4271).

Reminder of FCC Discontinuance Rules

A 200-foot radio tower and other equipment was stolen from a radio station in Alabama, forcing the station to go silent.  The station proceeded to notify the FCC that its AM station was down and was required to turn off its FM translator pursuant to the FCC’s AM and FM radio broadcast rules.  FCC licensees are reminded that interruptions to their operations, whether voluntary or involuntary, must be reported to the Commission under various circumstances.  For more information, please contact Greg Kunkle (; 202.434.4178) or Wes Wright (; 202.434.4239).

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