ICLE Issue Brief

Paying to Stand Still: Legacy Copper Mandates in a Fiber World

Executive Summary

America’s telephone network was built on copper wire. For much of the 20th century, that infrastructure carried nearly every call. Today, consumers rely on mobile service, Voice over Internet Protocol (VoIP), and fiber broadband. Yet federal and state rules still require carriers to maintain aging copper networks—even where few customers remain. The evidence shows these requirements impose large and growing costs with shrinking benefits, and reform is economically justified.

The consumer shift is clear. From 2014 to 2024, subscribers using copper last-mile connections fell 81%, from nearly 66 million to about 12.5 million. Over the same period, mobile subscriptions rose from 322 million to 391 million. By 2024, 79% of U.S. adults lived in wireless-only households, while fewer than 1% relied exclusively on landlines. Consumer behavior has already determined the outcome; regulation has not caught up.

Maintaining copper networks for this shrinking user base is increasingly expensive. In 2024, AT&T reported spending roughly $6 billion annually—about 5% of total revenue—to keep its copper network operating. These costs include maintenance, energy use, cooling, and real estate for oversized wire centers. In California alone, AT&T spent more than $1 billion in 2023 maintaining copper infrastructure serving fewer than 5% of households, now closer to 3%. By contrast, Verizon’s migration of 4.5 million circuits to fiber produced about $180 million in annual operating savings and a 60% reduction in maintenance dispatches. Similar trends appear across mid-sized and regional carriers.

The disparity reflects copper’s physical limitations. Copper corrodes, absorbs moisture, and degrades under environmental stress. Failures require costly maintenance dispatches—“truck rolls”—that often cost hundreds of dollars per visit. Fiber transmits light rather than electricity, making it more reliable and cheaper to operate. Industry analysis estimates that all-fiber networks cost about $91 less per home annually than copper-based DSL networks, and AT&T reports fiber costs roughly 35% less per subscriber to maintain.

Energy consumption widens the gap. Copper systems require continuous power and cooling for central-office equipment. AT&T estimates its copper-to-fiber transition saved about 340,000 megawatt-hours of electricity in 2024 alone. Altafiber reports copper service consumes 172 kWh annually per subscriber compared with just 6 kWh for fiber—a 97% reduction. Transitioning the remaining copper subscribers would save an estimated $398 million to $830 million in energy costs alone, while also reducing emissions.

Copper’s commodity value now creates public-safety risks. Prices rose from $2.29 per pound in 2020 to nearly $6 by early 2026. In 2025, AT&T reported nearly 8,700 theft incidents, costing about $76 million in repairs. Industrywide, more than 15,500 theft and sabotage incidents between mid-2024 and mid-2025 disrupted service to over 9.5 million customers, at times affecting 911 systems, hospitals, and military facilities. Estimated repair costs approach $136 million annually, and the social costs are higher.

The infrastructure itself is aging out. Core switching systems were last manufactured decades ago, and replacement parts now come largely from secondary markets. Each year, maintenance becomes harder, more expensive, and less reliable.

The policy question is not whether transition entails costs—it does. The question is whether those costs justify spending billions each year to preserve infrastructure serving a shrinking and voluntarily departing customer base. Removing regulatory barriers to copper retirement would reduce deadweight loss, reallocate capital and labor to next-generation networks, improve resilience and energy efficiency, and align telecommunications policy with today’s competitive marketplace.

I. Introduction and Overview

In 2025, the International Center for Law & Economics (ICLE) filed comments with the Federal Communications Commission (FCC) on copper retirement.[1] Those comments argued that existing FCC rules make it unnecessarily costly to migrate from aging copper networks to next-generation IP-based infrastructure. Current network-change and service-discontinuance regulations impose substantial transaction costs and create deadweight loss by inflating the price of retiring inefficient copper facilities. Removing those impediments would improve consumer welfare and speed infrastructure upgrades.

ICLE therefore urged the FCC to use its Section 10 forbearance authority to waive the network-change notice requirements of Section 251(c)(5) and the service-discontinuance requirements of Section 214 where competitive alternatives exist. Doing so would better reflect modern competition, reduce unnecessary compliance costs, and free private capital for faster deployment of advanced networks.

The ICLE comments explained:

As markets have moved toward mobile and VoIP, maintaining legacy copper lines has become increasingly expensive. With fewer subscribers, the per-subscriber cost for copper lines has increased. Prices have also gone up for standalone voice service over copper lines, leading to even more switching by consumers. This negative feedback loop is unsustainable over the long term, which is why many providers are looking to retire their copper networks.[2]

The filing identified several drivers of rising maintenance costs:

• Operating wire centers to serve a shrinking customer base;
• Growing copper theft, partly driven by higher commodity prices; and
• The declining availability of hardware and cables no longer manufactured or supported.

This issue brief builds on those observations. Evidence from carrier financial disclosures, FCC reports, industry studies, and peer-reviewed research shows three consistent trends: maintenance costs are large and rising, consumers have shifted decisively to alternative technologies, and regulatory delay magnifies costs as the subscriber base shrinks and infrastructure deteriorates. The data point to a straightforward conclusion—the commission’s proposed reforms are economically justified.

II. Copper Is No Longer the Consumer Default

The Federal Communications Commission’s most recent “Voice Telephone Services” report captures the scale of the market shift. From 2014 to 2024, subscribers using switched access lines fell 77%, from nearly 73 million to just over 16 million.[3] Subscribers served by copper local-loop—or “last-mile”—connections dropped even faster, declining 81%, from almost 66 million to about 12.5 million.

Figure 1: Number of Subscribers to Voice Telephone Services by Type (000s)

SOURCE: Federal Communications Commission

Copper’s share of the remaining wireline market also collapsed. In 2014, 60% of wireline subscribers relied on copper last-mile connections. By 2024, that figure had fallen to 28%. Over the same period, mobile subscriptions rose from 322 million to 391 million, a 21% increase (see Figure 1).

The Centers for Disease Control and Prevention’s National Health Interview Survey confirms the consumer response. In 2024, roughly 79% of adults lived in wireless-only households, while only 0.9% lived in landline-only households.[4]

III. Maintaining Copper Networks Is Economically Unsustainable

For U.S. telecommunications carriers, maintaining legacy copper networks has shifted from routine upkeep to a major operational burden. Copper once formed the backbone of the nation’s communications system. The rapid spread of fiber and other modern technologies now exposes how costly and inefficient those legacy facilities have become.

Across the industry—large incumbents and regional providers alike—the pattern is consistent. Carriers spend billions each year to operate infrastructure serving a rapidly shrinking customer base. Much of the expense does not vary with usage: utilities must still power equipment, maintain wire centers, dispatch technicians, and hold real estate, even as subscribers leave. As lines disappear, the per-customer cost rises.

The transition to fiber reverses those economics. Companies that migrate customers off copper report fewer repair dispatches, reduced building footprints, and lower operating costs. They also report substantial reductions in electricity use and emissions. Together, the operational, financial, and energy data point in the same direction: copper networks impose escalating costs, while modern networks generate measurable savings and reliability gains.

A. AT&T Spends Billions to Maintain a Shrinking Copper Network

At its 2024 Analyst & Investor Day, AT&T reported spending roughly $6 billion each year in direct operating costs to keep its copper network running—about 5% of the company’s $122 billion in annual revenue.[5] The figure excludes capital expenditures and legacy IT-system costs. About 40% reflects customer-facing expenses, such as installation and service calls, while the remaining 60% consists of fixed geographic costs, including power, maintenance, and real estate.

The same pattern appears at the state level. In California, AT&T spent more than $1 billion in 2023 maintaining its legacy copper network even though fewer than 5% of households in its service territory still relied on traditional copper voice service.[6] Today, that infrastructure serves only about 3% of households.[7]

Subscriber counts continue to fall rapidly. As of year-end 2024, AT&T had 3.3 million network-access lines and 127,000 DSL subscribers remaining, down from 4.2 million lines and 210,000 DSL subscribers the year before—a decline of 983,000 lines in a single year.[8]

In January 2025, CEO John Stankey announced the company would seek FCC approval to stop selling legacy products at roughly 1,300 of its approximately 4,600 wire centers.[9] The FCC has since approved retirement of copper facilities across more than 30% of AT&T’s footprint (excluding California), with discontinuations targeted to begin in late 2026 and full retirement planned by the end of 2029.[10]

B. Verizon’s Fiber Shift Slashes Operating and Real-Estate Costs

Verizon has migrated 4.5 million circuits from copper to fiber and fully retired 36 central offices. The company reports roughly $180 million in annual operating savings, driven by fewer maintenance dispatches and lower energy use.[11] Fiber conversion alone reduced maintenance dispatches by about 60%.[12]

Regulatory filings show the same effect. In a 2017 FCC filing seeking approval to retire copper in eight Northeast markets, Verizon documented 3.4 million fewer repair and troubleshooting dispatches between 2012 and 2016 than would have occurred had those customers remained on copper.[13]

The savings extend beyond field operations. Verizon maintains about 50 million square feet of central-office real estate but estimates that 60% to 80% becomes unnecessary in an all-fiber network. Decommissioning legacy Class 5 switches and associated copper infrastructure allows the company to shrink facilities dramatically—reducing buildings that once required up to 13 floors of equipment to just one or two.[14]

C. Mid-Sized and Regional Carriers Are Also Moving from Copper to Fiber

The shift away from copper extends well beyond the largest carriers.

Lumen Technologies lost 310,000 legacy (“other”) broadband subscribers between Q4 2024 and Q4 2025—a 21% decline—leaving 1.16 million total broadband subscribers.[15] Lumen sold its consumer fiber business to AT&T for $5.75 billion, while retaining its copper broadband and voice operations.[16]

Frontier Communications reported a 234,000 drop in copper subscribers during 2024, leaving just 702,000 at year-end.[17] At the same time, fiber broadband revenue rose 25% year over year, including a record 133,000 fiber net additions in Q3 2025.[18] Verizon completed its $20 billion acquisition of Frontier in January 2026, further consolidating the industry’s fiber-first trajectory.[19]

Altafiber experienced similar trends. Its legacy subscriber base fell from 227,000 in 2024 to 187,000 in 2025, a 17% decline.[20]

Newer market entrants show the same direction of change. Brightspeed—formed after acquiring Lumen’s incumbent local-exchange carrier (ILEC) assets across 20 states for $7.5 billion—serves more than 7.3 million homes and businesses and had passed more than 2 million locations with fiber as of April 2025.[21] The company uses what it calls a “reactive” retirement approach: customers experiencing repeated copper failures are migrated to fiber or wireless service.[22]

Consolidated Communications (Fidium) has likewise sought to discontinue legacy voice service. It petitioned the FCC to retire copper voice service at more than 45,000 locations across Maine, New Hampshire, and Vermont, followed by a second petition covering another 61,000 locations in August 2025.[23] Searchlight Capital Partners acquired the company for $3.1 billion in December 2024, and nearly 60% of its footprint has now been upgraded to fiber.[24]

D. Fiber Networks Dramatically Reduce Energy Use and Emissions

Fiber-optic networks deliver large gains in energy efficiency and environmental performance relative to legacy copper and coaxial systems. Copper-based POTS (“plain old telephone service”) networks require substantial electricity to maintain electrical signals over long distances and to cool heat-intensive equipment—even when traffic volumes are low. Fiber, by contrast, transmits information using light pulses that experience minimal signal loss and generate far less heat, making networks cheaper to operate.

Multiple studies estimate that replacing copper or cable with fiber and wireless can cut carbon emissions by as much as 90% or more. Transitioning the remaining 12.5 million copper subscribers to modern alternatives would produce estimated energy-cost savings of $398 million to $830 million.[25] As data demand continues to rise, retiring these energy-intensive legacy systems offers both economic and environmental benefits, alongside a technological upgrade.

The energy burden of copper networks is substantial. AT&T’s copper-to-fiber transition saved about 340,000 MWh in 2024—roughly 346 kWh per switched subscriber, or about $66 in energy savings per subscriber.[26] The company projects cumulative savings of 1.06 million MWh from 2024 through 2028, reducing emissions by roughly 740,000 metric tons of CO2 equivalent.[27] AT&T also reports a 70% reduction in energy consumption when neighborhoods move from copper DSL to 1 Gbps fiber service, reflecting both lower power requirements and reduced maintenance needs.[28]

Altafiber reports similar results. Its legacy copper network consumes about 172 kWh annually per subscriber, compared with just 6 kWh for a fiber connection—a 97% reduction.[29] At current electricity prices, that equals roughly $32 in annual energy savings per subscriber.[30] Operating the copper network accounts for 65% of Altafiber’s total carbon emissions: 48% from powering equipment and 17% from cooling.[31]

Industrywide evidence points in the same direction. Verizon’s 2023 ESG report states that fiber-delivered broadband is at least 100 times more energy-efficient on a kWh-per-gigabyte basis than copper-delivered service.[32] A 2023 lifecycle assessment by Corning found optical fiber’s embodied carbon up to five times lower than a copper wire pair.[33] A 2022 Telefónica lifecycle assessment likewise found the environmental impact per petabyte of fiber traffic 18 times lower than copper—a 94% reduction.[34]

IV. Copper Networks Are Less Reliable and More Expensive to Maintain

Copper networks are inherently more expensive to maintain than fiber because of the medium’s physical limitations. Much of the copper plant installed between the late 19th and mid-20th centuries is vulnerable to moisture, corrosion, and electromagnetic interference.[35] Water intrusion can disable a line for days or weeks, leaving remaining subscribers without service.[36] Fiber transmits light rather than electricity, making it immune to electromagnetic interference and far less susceptible to lightning, power surges, and environmental degradation.[37] As a result, fiber-based—including wireless—networks are more resilient and faster to repair.

Carriers’ own data reflect these differences. AT&T reported at its December 2024 Analyst Day that fiber costs about 35% less per subscriber to maintain than copper because failures occur less often.[38] A 2020 Fiber Broadband Association analysis similarly found annual operating costs of $53 per home passed for all-fiber networks, compared with $144 for DSL—a $91 yearly savings, or roughly $910 over a decade.[39] DSL operators also face churn-related costs about 2.5 times higher than fiber providers.[40]

Copper’s higher failure rate drives a large number of maintenance dispatches, commonly called “truck rolls.”[41] Industry estimates place the cost of a single dispatch at $150 to $500, including fuel, labor, and vehicle depreciation.[42] Reducing these visits frees capital for revenue-producing investment, such as new fiber deployment, rather than ongoing repair work associated with legacy facilities.

Environmental performance follows the same pattern. A January 2025 Ramboll report found that installing fiber infrastructure produces “clear environmental benefits in the long term” relative to maintaining copper and that fiber broadband is at least 100 times more energy-efficient than copper-based service during operation.[43]

V. Copper Theft Imposes Growing Economic and Public-Safety Costs

The copper facilities carriers struggle to maintain have also become valuable targets for theft, especially as commodity prices rise. What once counted as a maintenance problem now creates a security problem.

The consequences extend well beyond carrier balance sheets. Theft has disrupted 911 systems, hospitals, military installations, and local government communications, leaving millions of customers without service and imposing broader social costs.

Regulatory delay compounds the risk. By slowing retirement of legacy copper networks, existing rules leave vulnerable infrastructure in place longer, increasing both economic losses and public-safety exposure.

A. The Scale of Copper Theft Is Driving Costs and Outages

Rising copper prices have made telecommunications infrastructure an increasingly attractive theft target. After the pandemic-era recession in 2020, copper prices climbed from $2.29 per pound to $5.89 per pound by January 2026—an annualized growth rate of roughly 18%.[44]

The operational impact is substantial. AT&T reported nearly 8,700 copper-theft incidents nationwide in 2025, causing about $76 million in repair costs—roughly $8,735 per incident.[45] In California alone, AT&T recorded 2,200 thefts in 2024, up from just 71 in 2021, a thirtyfold increase.[46]

Industrywide data show the same trend. Providers documented 15,540 theft and sabotage incidents between June 2024 and June 2025, disrupting service for more than 9.5 million customers.[47] Using AT&T’s average repair cost, that equals approximately $136 million in annual repair expenses. The pace also accelerated: 9,770 incidents occurred in the first half of 2025, nearly double the 5,770 reported in the second half of 2024.[48] California and Texas accounted for roughly half of all incidents.[49]

The effects extend beyond telecommunications networks. In Los Angeles, the Bureau of Street Lighting reported a tenfold increase in theft-related outages—from 607 incidents in fiscal year 2017–2018 to 6,344 in fiscal year 2021–2022.[50]

B. Copper Theft Now Threatens Critical Infrastructure

Federal authorities have long treated copper theft as more than a property crime. The Federal Bureau of Investigation identified it as a threat to critical infrastructure as early as 2008.[51] Documented incidents have disrupted 911 dispatch systems, law enforcement communications, hospitals, military installations, and schools.[52]

Recent examples underscore the risk. In Contra Costa County, California, copper theft disrupted 911 service for about a week in June 2024.[53] In June 2025, thieves searching for copper damaged Charter’s fiber network in Los Angeles, causing an outage affecting a U.S. military base, emergency dispatch services, police and fire departments, and more than 50,000 people.[54]

States have begun responding. In 2025, 23 states considered infrastructure-protection legislation, and 13 enacted laws increasing penalties for theft and vandalism targeting communications networks.[55]

Economist Edward J. Lopez estimates the broader social harm using a willingness-to-pay framework. Incorporating loss aversion—the higher cost people place on losing service than on gaining it—and network effects affecting those who cannot reach disconnected users, he finds the 5,770 incidents reported in the second half of 2024 alone imposed societal costs between $38 million and $188 million.[56]

VI. Copper Networks Depend on Obsolete Equipment

The copper public-switched telephone network relies on central-office switches that manufacturers no longer produce. The Lucent 5ESS—once one of the most widely deployed Class 5 switches in the United States—entered service in 1982 and was last manufactured in 2003.[57] Nortel, maker of the DMS-100 digital switch introduced in 1979,[58] filed for Chapter 11 bankruptcy in the U.S. Bankruptcy Court for the District of Delaware in 2009.[59] Siemens’ EWSD switching system, first released in 1975, reached end-of-manufacture when Siemens set a final order date of July 15, 2007, for the EWSD core.[60] Support later transferred to Nokia Siemens Networks (now Nokia), but the system is now fully discontinued.[61]

With original manufacturers gone, operators must keep copper networks running using secondary-market vendors and refurbished parts.[62] In one representative case, Tinker Air Force Base maintained a 5ESS switch for years by purchasing replacement components on eBay, because commercial parts had been unavailable for nearly a decade before the system was finally decommissioned in October 2024.[63]

The obsolescence problem extends beyond switching equipment. The SONET/SDH transport systems that carry traffic across copper networks are also disappearing. Major vendors—including Cisco, Ciena, Nokia, and Ericsson—have ended or are phasing out support for legacy SONET/SDH time-division multiplexing transport products, effectively forcing upgrades.[64] Cisco, for example, announced end-of-sale dates for components of its ONS 15454 platform with last support ending in 2019.[65] Analysts likewise reported a 30% drop in carrier spending on SONET/SDH equipment, concluding the technology had been effectively displaced.[66]

Each year, the practical consequences intensify: replacement components grow scarcer, maintenance becomes more expensive, and no new production exists to replenish the supply.

VII. The Policy Case for Allowing Copper Retirement

The evidence presented in this brief points in one direction: requiring continued maintenance of legacy copper networks imposes large costs while delivering shrinking benefits. AT&T alone spends about $6 billion each year—roughly 5% of its revenue—to operate a network serving a steadily declining share of customers.[67] Across the industry, carriers incur additional billions in maintenance expenses, energy consumption, theft losses, and delayed investment in modern infrastructure.

The potential gains from transition are substantial. The Brattle Group estimated in 2024 that completing nationwide fiber deployment would generate $3.24 trillion in net present value and support roughly 380,000 jobs.[68] This brief does not attribute that full amount to the FCC’s proposed reforms. The estimate reflects the value of a complete national fiber buildout. The reforms would instead remove procedural barriers that delay retirement of copper facilities where alternatives exist, redirect billions in annual maintenance spending toward fiber and other modern technologies, and reduce regulatory drag that discourages deployment by incumbent providers. The Fiber Broadband Association similarly estimates all-fiber networks save $91 per home passed each year relative to DSL—across tens of millions of homes, a significant resource misallocation.[69]

International experience reinforces the point. A 2020 WIK-Consult study for the FTTH Council Europe found that lengthy regulatory notice periods—up to five years in some countries—significantly delayed copper switch-off even where fiber was available, recommending shorter timelines once alternatives exist.[70] An Accenture analysis commissioned by Australia’s government-owned broadband operator projected AU$10.4 billion in cumulative GDP growth from 2026 to 2034 from upgrading remaining fiber-to-the-node networks to full fiber.[71] Different institutional structures notwithstanding, the common lesson holds: regulatory certainty accelerates investment.

Transition policy must also account for remaining copper subscribers, who skew older and more rural than the general population.[72] The FCC’s proposed framework addresses this concern through notice requirements and the availability of alternative voice services, including wireless and VoIP. The policy question is not whether transition costs exist—they do—but whether those costs justify continued spending of billions annually to maintain infrastructure serving a shrinking and voluntarily departing customer base.

Resources dedicated to copper maintenance—skilled labor, contractor capacity, and capital—directly compete with fiber deployment and broadband expansion. The proposed reforms would free substantial funding and workforce capacity for investment in next-generation networks with useful lives measured in decades.

VIII. Conclusion

The record shows a widening mismatch between regulation and reality. Consumers have moved to mobile, VoIP, and fiber-based services, yet federal and state rules still require carriers to devote billions each year to infrastructure serving a shrinking and voluntarily departing customer base. Those expenditures divert capital and skilled labor away from fiber and fixed-wireless deployment, reduce network resilience, and prolong exposure to outages, theft, and equipment failure. Each year of delay compounds the problem, as copper facilities deteriorate, parts grow scarce, and maintenance costs rise.

The FCC’s proposed reforms recognize that telecommunications policy must track current technology and competition. Where adequate alternatives exist, preserving legacy barriers to copper retirement neither protects consumers nor promotes efficient investment. Modernizing network-change and service-discontinuance rules would reduce deadweight loss, redirect resources toward durable infrastructure, and speed the transition to more reliable and energy-efficient networks.

The question is no longer whether the transition will occur. It is whether regulation will permit it to proceed in an orderly and economically rational way. The evidence supports reform.

[1] Kristian Stout, Ben Sperry & Eric Fruits, Comments of the International Center for Law & Economics, Reducing Barriers to Network Improvements and Service Changes, Docket No. 25-209; Accelerating Network Modernization, Docket No. 25-208 (Aug. 22, 2025), https://www.fcc.gov/ecfs/document/10822002748400/1.

[2] Id. at 5.

[3] FCC, Voice Telephone Services: Status as of December 31, 2024 (Feb. 2026), https://docs.fcc.gov/public/attachments/DOC-418460A1.pdf (data available at https://www.fcc.gov/sites/default/files/VTS_Historical_Data_Thru_D24.zip).

[4] Stephen J. Blumberg & Julian v. Luke, Nat’l Ctr. for Health Stats., Wireless Substitution: Early Release of Estimates from the National Health Interview Survey, July–December 2024 tbl. 1 (2025), https://www.cdc.gov/nchs/data/nhis/earlyrelease/wireless202506.pdf.

[5] AT&T Inc., Edited Transcript: 2024 Analyst & Investor Day (comments of Susan Johnson, EVP & GM, Wireline Transformation & Global Supply Chain, Dec. 3, 2024), https://investors.att.com/~/media/Files/A/ATT-IR-V2/reports-and-presentations/transcript-2024-12-03.pdf (hereinafter Johnson).

[6] See Opening Testimony of Dr. Mark Israel ¶¶ 19–33, A.23-03-003 (Cal. Pub. Utils. Comm’n Dec. 19, 2023).

[7] Pacific Bell Tel. Co. d/b/a AT&T Cal. (U 1001 C), Opening Comments on Administrative Law Judge’s Ruling Issuing Staff Proposal for Comment at 10, R.24-06-012 (Cal. Pub. Utils. Comm’n Jan. 30, 2026).

[8] AT&T Inc., Annual Report (Form 10-K) for the Fiscal Year Ended December 31, 2024 (Feb. 2025), https://investors.att.com/~/media/Files/A/ATT-IR-V2/financial-reports/t-2024-12-31-10k-final.pdf.

[9] AT&T Inc., Edited Transcript of Q4 2024 AT&T Inc. Earnings Call (Jan. 27, 2025), https://investors.att.com/~/media/Files/A/ATT-IR-V2/financial-reports/quarterly-earnings/2024/4Q24/t-usq-transcript-2025-01-27.pdf.

[10] See Jake Neenan, AT&T Approved to Discontinue Service at More Than 30% of Copper Footprint This Year, Broadband Breakfast (Jan. 13, 2026), https://broadbandbreakfast.com/at-t-approved-to-discontinue-service-at-more-than-30-of-copper-footprint-this-year.

[11] Verizon Commc’ns Inc., Edited Transcript: Investor Day 2022 (Mar. 3, 2022), https://www.verizon.com/about/sites/default/files/2022-03/Investor-Day-2022-Transcript.pdf.

[12] Sarah Thomas, Verizon Saves 60% Swapping Copper for Fiber, Light Reading (May 19, 2015), https://www.lightreading.com/cable-technology/verizon-saves-60-swapping-copper-for-fiber.

[13] Sean Buckley, Verizon Seeks FCC Permission to Retire Copper in 8 Markets, Emphasizes Call to Revise Processes, Fierce Network (Sept. 20, 2017), https://www.fierce-network.com/telecom/verizon-seeks-fcc-permission-to-retire-copper-8-markets-emphasizes-call-to-revise-processes.

[14] Id. See also Melissa Anders, John Vazquez Finds New Life in Old Buildings for Verizon, Am. Builders Q. (2015), https://americanbuildersquarterly.com/2015/verizon (“As modern telecommunications infrastructure migrates to fiber optics, away from copper wire, and from mechanical switches to digital ones, Verizon expects to reduce its technical footprint by as much as 80% where it makes these conversions, according to Vazquez.”).

[15] Lumen Techs., Inc., Financial Trending Schedule: 4th Quarter 2025 (2026), https://s21.q4cdn.com/756714007/files/doc_earnings/2025/q4/supplemental-info/Final-LUMN-Q4-2025-FTS.pdf.

[16] Press Release, AT&T, AT&T to Acquire Lumen’s Consumer Fiber-to-the-Home Business (May 21, 2025), https://about.att.com/story/2025/lumen-mass-markets-fiber-business.html.

[17] Press Release, Frontier Commc’ns, Fourth Quarter and Full Year 2024 Results (Feb. 20, 2025), https://investor.frontier.com/news/news-details/2025/Frontier-Reports-Fourth-Quarter-and-Full-Year-2024-Results/default.aspx.

[18] Press Release, Frontier Commc’ns, Third Quarter 2025 Results (Oct. 28, 2025), https://investor.frontier.com/news/news-details/2025/Frontier-Reports-Third-Quarter-2025-Results/default.aspx.

[19] See Press Release, Verizon, Verizon and Frontier: Regulatory Approval (Jan. 15, 2026), https://www.verizon.com/about/news/verizon-and-frontier-regulatory-approval.

[20] Cincinnati Bell Inc., Quarterly Report (Form 10-Q) (Nov. 12, 2025).

[21] Press Release, Brightspeed, Brightspeed Reaches More than 2M Fiber-Enabled Locations Across 20-State Footprint Ahead of Plan, Upsizes Build Goal to 5M+ (Apr. 2, 2025), https://www.brightspeed.com/brightspeed-news/Brightspeed_Reaches_More_than_2M_Fiber-Enabled_Locations.

[22] Linda Hardesty, Brightspeed Can Replace Copper with Unique Wireless Technology, Fierce Network (Sept. 9, 2024), https://www.fierce-network.com/broadband/brightspeed-can-replace-copper-unique-wireless-technology.

[23] See Jake Neenan, Consolidated Looking to Discontinue Copper at 45,000 New England Locations, Broadband Breakfast (July 10, 2025), https://broadbandbreakfast.com/consolidated-looking-to-discontinue-copper-at-45-000-new-england-locations; Jake Neenan, Consolidated Looking to Retire More Copper Phone Lines in New England, Broadband Breakfast (Aug. 19, 2025), https://broadbandbreakfast.com/consolidated-looking-to-retire-more-copper-phone-lines-in-new-england.

[24] Jake Neenan, FCC Approves Sale of Consolidated Communications to PE Firms, Broadband Breakfast (Dec. 9, 2024), https://broadbandbreakfast.com/fcc-approves-sale-of-consolidated-communications-to-pe-firms.

[25] Range reflects estimated energy savings of 166 kWh per subscriber (Altafiber) to 346 kWh per subscriber (AT&T).

[26] 340,000 MWh ÷ 983,000 decline in network access lines and DSL subscribers. See AT&T 10-K, supra note 8.

[27] AT&T, Energy Management (July 3, 2025), https://sustainability.att.com/priority-topics/energy-management.

[28] Rhonda Johnson, Building Networks for the Next Century, Not the Last One, AT&T Connects (May 15, 2024), https://www.attconnects.com/stories/building-networks-for-the-next-century-not-the-last-one.

[29] Nadja T., Are You Considering the Carbon Footprint of Your Internet Service?, Altafiber Blog (Oct. 14, 2024)., https://blog.altafiber.com/are-you-considering-the-carbon-footprint-of-your-internet-service.

[30] U.S. Bureau of Labor Statistics, Average Price: Electricity per Kilowatt-Hour in U.S. City Average (APU000072610), FRED, Fed. Rsrv. Bank of St. Louis, https://fred.stlouisfed.org/series/APU000072610 (last visited Feb. 24, 2026).

[31] Nadja T., Leaving a Greener Legacy, Altafiber Blog (Oct. 27, 2022), https://blog.altafiber.com/greener-legacy.

[32] Verizon, Verizon ESG Report 2023 (2024), https://www.verizon.com/about/sites/default/files/Verizon-2023-ESG-Report.pdf.

[33] Aislin Sullivan, Pushkar Tandon, Roshene McCool, Amalia Diaz & Constantin Herrmann, A Sustainable Future with Optical Fiber, Corning White Paper (Mar. 2023), https://www.corning.com/catalog/coc/documents/white-papers/WP1000.pdf.

[34] Telefónica, Connectivity Solutions’ Life Cycle Assessment: Executive Report (2022), https://www.telefonica.com/en/wp-content/uploads/sites/5/2022/03/connectivity-solutions-life-cycle-assessment.pdf.

[35] See Ramboll, Greener Connections: Understanding the Environmental Impacts of Fiber and Copper Communications Networks 3 (2025), https://ustelecom.org/wp-content/uploads/2025/01/Greener-Connections_Final.pdf (noting copper lines “are more susceptible to water damage than fiber optic lines” and fiber optic lines are “less susceptible to weather/climate-related events, such as flooding”).

[36] See Mike Robuck, AT&T Makes Case Against Keeping Copper, Mobile World Live (May 22, 2024). https://www.mobileworldlive.com/att/att-makes-case-against-keeping-copper.

[37] See Sullivan et al., supra note 33; Ramboll, supra note 35 (documenting fiber’s greater resilience and durability compared to copper).

[38] Johnson, supra note 5.

[39] Fiber Broadband Ass’n, Operational Expenses for All-Fiber Networks Are Far Lower Than for Other Access Networks (June 2020), https://fiberbroadband.org/wp-content/uploads/2023/03/Access-Network-OpEx-Analysis-White-Paper.pdf.

[40] Id.

[41] Ramboll, supra note 35.

[42] Pete Humes, How to Reduce Truck Rolls with Remote Visual Support, SightCall (Feb. 15, 2023), https://sightcall.com/blog/how-to-reduce-truck-rolls.

[43] Ramboll, supra note 35.

[44] Int’l Monetary Fund, Global Price of Copper [PCOPPUSDM], FRED, Fed. Rsrv. Bank of St. Louis, https://fred.stlouisfed.org/series/PCOPPUSDM (last visited Feb. 17, 2026).

[45] See Nicole Cobler, Copper Thefts in Dallas-Fort Worth Disrupt Utility and Emergency Services, Axios Dallas (Dec. 15, 2025), https://www.axios.com/local/dallas/2025/12/15/copper-thefts-dallas-fort-worth-att; see also Matt Egan, Copper Prices Are Rising. Thieves Are Taking Notice, CNN Business (Dec. 22, 2025), https://www.cnn.com/2025/12/22/economy/copper-wire-theft-att-outages.

[46] Susan Santana, Teaming Up to Tackle Copper Theft, AT&T Connects (July 16, 2025), https://www.attconnects.com/stories/teaming-up-to-tackle-copper-theft.

[47] USTelecom, Protecting the Nation’s Critical Communications Infrastructure from Theft & Vandalism (Oct. 2025), https://ustelecom.org/wp-content/uploads/2025/10/Protecting-Critical-Communications-Infrastructure-Report-Fall-2025.pdf.

[48] Id. The April 2025 edition of the report documented 5,770 incidents during the June–December 2024 period.

[49] Id.

[50] Egan, supra note 45; see also L.A. Bureau of Street Lighting, Outages and Issues, https://lalights.lacity.org/residents/outages_and_issues.html (last visited Feb. 18, 2026).

[51] FBI, Copper Thefts Threaten U.S. Critical Infrastructure (Dec. 3, 2008), https://archives.fbi.gov/archives/news/stories/2008/december/copper_120308.

[52] USTelecom, supra note 47.

[53] Egan, supra note 45.

[54] USTelecom, supra note 47.

[55] Id.

[56] Edward J. Lopez, The Real Costs of Communications Outages Due to Infrastructure Theft or Vandalism (Oct. 2025), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5526102 (also available at https://protectcci.org/wp-content/uploads/2025/10/Economic-Impact-Study_1001_2025.pdf).

[57] Western Electric/Lucent Modern Telephone Switching Systems, Telephone World (June 19, 2023), https://telephoneworld.org/telephone-switching-systems/western-electric-lucent-modern-telephone-switching-systems.

[58] Northern Telecom/Nortel Digital Central Office Switches, Telephone World (May 31, 2021), https://telephoneworld.org/telephone-switching-systems/northern-telecom-nortel-digital-central-office-switches.

[59] In re Nortel Networks Inc., 469 B.R. 478 (Bankr. D. Del. 2012); Long-Struggling Nortel Claims Bankruptcy, CBS News (Jan. 13, 2009), https://www.cbsnews.com/news/long-struggling-nortel-claims-bankruptcy.

[60] Application of Foothills Rural Tel. Coop. Corp. for Certificate of Convenience & Necessity, No. 2008-00163, Ex. B (Ky. Pub. Serv. Comm’n May 2, 2008), https://psc.ky.gov/PSCSCF/2008%20cases/2008-00163/Foothills_Application_050208.pdf (Siemens “Product Phase Out” notice listing the last possible order date and end-of-manufacturing date of July 15, 2007, for the EWSD core).

[61] Siemens EWSD Digital Electronic Switching System, Nokia Support Portal, https://customer.nokia.com/support/s/product2/siemens-ewsd-digital-electronic-switching-system/01t41000004gEmyAAE (last visited Feb. 17, 2026).

[62] See, e.g., Carritech, Lucent 5ESS, https://carritech.com/products/alcatel-lucent/lucent-5ess (last visited Feb. 17, 2026); Worldwide Supply, Nortel, https://worldwidesupply.net/brand/nortel (last visited Feb. 17, 2026); Carritech, Siemens EWSD, https://carritech.com/products/siemens-2/siemens-ewsd (last visited Feb. 17, 2026).

[63] Clayton Cummins, Tinker Retires Phone System Dating Back Over 40 Years, Tinker Air Force Base News (Oct. 24, 2024), https://www.tinker.af.mil/News/Article-Display/Article/3945606/tinker-retires-phone-system-dating-back-over-40-years.

[64] Robert Schult, Why Legacy Telecom Networks Are Giving Way to the Future, TeleGeography (Oct. 10, 2024), https://resources.telegeography.com/why-legacy-telecom-networks-are-giving-way-to-the-future.

[65] See, e.g., Cisco, End-of-Sale and End-of-Life Announcement for the Cisco ONS 15454 SONET/SDH SFP Short Haul Transceiver Module (Jan. 11, 2019), https://www.cisco.com/c/en/us/products/collateral/optical-networking/ons-15454-series-multiservice-provisioning-platforms/eos-eol-notice-c51-730654.html.

[66] Bo Gowan, SONET/SDH Is Dead–Really This Time, Ciena (June 19, 2013), https://www.ciena.com/insights/articles/SONETSDH-is-dead-really-this-time-prx.html.

[67] Johnson, supra note 5.

[68] Brattle Group, Fiber Deployment Has Significant Incremental Economic Benefits (2024), https://www.brattle.com/insights-events/publications/fiber-deployment-has-significant-incremental-economic-benefits-according-to-a-recent-brattle-report.

[69] Fiber Broadband Ass’n, supra note 39.

[70] WIK-Consult, Copper Switch-Off: European Experience and Practical Considerations (White Paper, Q3 2020), https://www.wik.org/fileadmin/Studien/2020/Copper_switch-off_whitepaper.pdf.

[71] Accenture, Economic Impact of Completing the Upgrade of nbn’s FTTN Network (2024), https://www.nbnco.com.au/content/dam/nbn/documents/about-nbn/reports/reports-and-publications/accenture-economic-impact-of-completing-fttn-upgrade.pdf.coredownload.pdf.

[72] See Blumberg & Luke, supra note 4 (reporting lower wireless-only adoption among adults 65 and older and rural-urban disparities in wireline deployment).