We Are Calling for a Complete Halt to the Entire FCC Brendan Carr Proceedings. And We Challenge — Prove Us Wrong.

Carr’s Hidden Agenda Plans is to Dismantle Customer-funded State Infrastructure Utilities and Give the Telcos Hundreds of Billions of Dollars in a Wireless Bait and Switch

The IRREGULATORS have filed on these issues for decades — with no changes made. We call on Congress to investigate. We have also filed an Application for Full Review, detailing how our rights and America’s due process were harmed.

> IRREGULATORS Request Full Review of the FCC Deregulation Order.

Below, we will list the reasons for Congress to investigate, and the public will realize the massive manipulation of the story you have been told:

Some of these items include:

Misrepresentation and deceptive presentation of essential facts.

Exclusion of key facts that make Carr’s orders invalid

> The use of industry biased data without any examination

Removal of Due Process, Discrimination and Censorship

Manipulation of the Number of Lines: Intent to deceive; creating corrupt FCC orders, regulations, and public policies.

Structural flaws that are in every proceeding — the same violations appearr in every potential and recently passed order.

We will list specific issues and violations in a moment.

**23+ FCC Proceedings to Streamline, Abolish, Eliminate, Remove… with a Hidden Agenda.**

**IRREGULATORS: 8 YEARS AGO THE FCC TRASHED OUR ADVERSE COMMENTS IN IDENTICAL PROCEEDINGS.**

> Refreshing the Record: 27 Years of FCC Filings and Complaints in the Section 706 Advanced Network and Related Proceedings by New Networks Institute, Teletruth and the IRREGULATORS.

Let us add some details:

The bending of multiple proceedings through the use of distortions and manipulations of the data to force invalid Carr-O-Centric public policies.

Chairman Carr has put forward a barrage of over 25+ separate and still continuing but inter-locking proceedings to dismantle every state’s critical telco infrastructure. It is a plot that has been hidden via the following shell game.

But at the core is Delete, Delete, Delete — an all out erasure of laws, rules and regulations, including states and cities rights over telecom, or removal of customer rights and protections, or slowing the speed of America’s broadband to make sure wireless and satellite can get government subsidies. Moreover, this is an attempt to erase all audit trails of the financials to hide hundreds of billions of dollars in rate-payer- funded state critical infrastructure being handed over to the wireless subsidiaries.

At the Core: The Hidden Infrastructure, State Telecom Utility?

If your answer is, What utility? Isn’t the utility just old copper wires, quickly disappearing? Isn’t the FCC’s plan to bring fiber to the home replacing these old copper wires?

All of these assertions are wrong.

The utilities still exist and their customer-funded assets include the fiber optic wires used for Verizon’s FiOS and wireless services. But the construction budgets are coming out of the ratepayers being charged extra. And those copper lines? — The numbers have been manipulated to hide 70–90% of all networks.

Moreover, the entire USOA, Uniform System of Accounting, used by the industry has been manipulated to charge the utility — the regulated entities that are subject to consumer protection — for all of the other lines of business using these same networks.

And we did supply extensive documentation and analyis from experts auditors and lawyers with a long list of credentials..

When we supplied the data and analysis to substantiate these claims — over the last 28 years, the FCC has repeatedly refused to deal with our adverse comments in the public interest.

Rural areas should have been upgraded to fiber over the last 3 decades as customers paid thousands of dollars per line extra to fund buildouts that never happened.

America’s prices would not be out of control had the FCC got rid of made-up junk fees or cleaned up the ramming and cramming on bills.

Prices would have been lower had the networks been open to competition instead of a slight of hand used to ‘reclassify’ networks as IP and closed.

Had the FCC examined the record we presented, they would have noticed that over the last 3 decades, state laws were changed to replace the fully depreciated copper wires — as they got paid to do so numerous times.

Prices should have been in steep decline. The budgets for the copper maintenance were slashed, staff, especially union workers, were dramatically cut, and the expenses that are being assigned to make the basic wired services artificially inflated as the other lines of business have been getting a free ride. Moreover, when the subsidiaries are not paying market prices, the states could have fixed these manipulated accounting for the last 2 decades, but didn’t.

Connecting the dots, each of these issues helped to create an artificial Digital Divide, something we predicted would happen in our research in 1998.

Removal of Due Process: Chairman Carr pushed through multiple orders to ‘shut down the copper’, by himself, without a comment period or even a vote of the other Commissioners. He used this collection of manipulated and corrupt data to push through his consumer unfriendly, flawed vision for America.

The Violations and Data Distortions of Chairman Carr

Chairman Carr failed to present basic material facts when he began in March 2025 to ‘shut off the copper’ claiming only 5% of one provider were still using the legacy copper wire. The previous links supply the details:

1. FACT: There is no mention that there are still existing telecommunications public utilities, such as Verizon NY or AT&T -Illinois Bell. or AT&T California — Pac Bell.

2. FACT: AT&T claimed that the FCC gave permission to shut off the copper in 18 states.

3. FACT: AT&T controls 21 state telecommunications public utilities — a fact the FCC never mentioned or acknowledged.

4. FACT: All of these copper wires are part of these state telecommunications public utilities today — a fact the FCC never mentioned nor did AT&T.

Leaving out just these primary facts should be enough to halt all of the proceedings.

Manipulation of the Number of Lines: Intent to deceive; creating corrupted orders, regulations, and public policies

FCC Chairman Carr’s 2025 accounting of the access lines was a pure misrepresentation designed to push forward a very flawed bait and switch plan. By manipulating the accounting of lines, the companies can claim that the utility is just the legacy copper wires and doesn’t matter.

**50 Million Copper Access Lines Appear to be Missing from the FCC’s Analysis. Who Does It Benefit? Why It Matters? Where’s the Audits?**

5. FACT: Brendan Carr’s statements in the July FCC 2025 meeting fail to mention that these copper wires are not 5% of all provider access lines, nor supplies the total number of all copper-based lines.

6. FACT: Brendan Carr used the term “one provider”, even though anyone following the telecom industry heard AT&T’s press announcements on this topic.

7. FACT: Exclusion of Primary Facts: Designed to Deceive: AT&T’s counted only cooper lines that are residential’ and only voice, and only the TDM — not IP Lines.

8. FACT: USTelecom, the wireline association, FCC filings also have an identical deceptive accounting and only count residential lines.

Basic Math:

9. FACT: Out of 80 million locations, AT&T only has 10. million fiber lines to the home and office; the rest of the lines likely are the copper wires that are NOT being counted.

10. FACT: AT&T’s U-verse used the existing copper wires and because it was using “IP” — also called VOIP — it was NOT COUNTED AS A LINE

11. FACT: The copper business lines were not counted.

12. POINT OF FACT: Chairman Carr’s number of 5% is wrong. There are no caveats to the statement and thus would include all copper wires including business lines, or IP-VOIP copper lines or any other copper wire based line.

STATE: IMPORTANT FACTS

13. FACT: State Carrier of Last Resort Removal Passed with Manipulated Accounting> Verizon NY Annual Reports and Illinois Bell Reports appear to show that multiple state laws were changed, like Illinois and other AT&T states with a deceptive accounting of total lines — leaving out all copper wires vs only supplying residential and some business lines.

Consequence: Manipulated Data are the foundation of FCC Orders that should be annulled

14. FACT: Misrepresentation for the removal of Carrier of Last Resort by the FCC Industry and the state actions. The FCC did not count the copper lines that could be shut off.

15. FACT: However, this fictional accounting has provided billions of dollars of rate increases, helping corporations, harming consumers.

16. FACT: State COLR removal was based on manipulated accounting of lines. The Verizon NY annual reports only counts the basic voice residential and some business lines — almost $2 billion dollars but had not access lines given.

17. FACT: All Sorts of Bad Things have happened due to this failure to provide all copper lines. In every state, laws were passed to upgrade the utilities with fiber, replacing the copper wires. All of the copper wires that are left show the failure to properly do the upgrades, so exposing the total number of copper wires that AT&T or Verizon failed to ‘modernize’ could have been used to hold the companies accountable for this mess

But, Brendan Carr has allowed all of these issues to be hidden — and we filed on this accounting of lines in 2017, when Carr was General Counsel.

By shrinking the size of the number of copper lines, the company got rate increases, were able to cut staff, and make it appear that the utility is just the aging copper wires…

the basic accounting of access lines is a great deal worse than broadband mapping as it is also about the manipulation of the flows of money — the ratepayer overcharging for a fiber optic future that never showed — or worse, that billions were diverted to illegally fund the wireless build out — i.e., there was fiber deployed — it was diverted to build out the wireless networks.

Part 2 Verizon New York’s Secret: How do you hide a Telecom utility with $37 billion in network in use in just one state?

Part 3: The Massive Wireless Bait and Switch