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Why the Switched Telephone Network’s Existence Is Essential

May 28, 2018


Why the Switched Telephone Network’s Existence Is Essential

Public Comments Submitted by L. Lloyd Morgan,
Sr. Research Fellow, Environmental Health Trust

A Critical Public Infrastructure

The Switched Telephone Network (i.e. telephone lines and switching centers) is a critical national resource, which if dismantled would have dire consequences.  This fully capitalized infrastructure, paid for by every citizen who has paid a telephone bill is not, in the broad sense, private property, but public property.  This is implicitly recognized by the requirement that the Federal Communication Commission must approve its dismantlement.


A Critical Resource in an Extended Emergency

While still serving millions of citizens, the Switched Telephone Network is under-utilized.  However, in an emergency, the Switched Telephone Network is independently powered, so communications remain available when the emergency includes the loss of power from the electrical grid.  In contrast, the cellphone network will not operate during an extended-duration power outage.  While cell towers (base stations) may, or may not have battery backup, or even diesel generators, the batteries in cellphones would soon be depleted.  How would anyone be able to contact emergency services?


Improved Utilization

The Department of Energy (DOE) program to improve the electrical grid system throughout the United States is called the “Smart Grid”.  One of the DOE listed goals of the Smart Grid system is “Operating resiliency against physical and cyber attack” (

One Example of Improved Utilization of the Switched Telephone Network

Wireless smart meters do not have to be wireless. They can use the Switched Telephone Network to communicate time-of-day electrical power usage.  There are twisted-pair telephone wires at every location where electricity is used.  Some may no longer be in use but they run back to the telephone switching facilities where they can easily be reconnected.

One can imagine many other uses for the Switched Telephone Network. In our entrepreneurial society—it is hard to imagine that other uses of the enormous and fully-capitalized investment—would not find additional uses.


Wired Broadband Access First

Before dismantling the Switch Telephone Network, an independently powered (necessary to maintain communication capability during an extended-time electrical power failure) alternative must first be installed.  A fiber-optic connection, requiring no electricity to make emergency calls, could be used to:

  1. Call ambulance;
  2. Call police;
  3. Call fire department;
  4. Call doctor;
  5. Notify the electrical utility of a power outage;
  6. Call a nearby neighbor or family member for help.

The Federal Communications must consider what is optimal for our nation, rather than what is optimal for the Telecommunication Industry.

Before authorizing dismantlement of the Switched Telephone Network, the Federal Communications Commission must mandate installation of an independently powered high bandwidth communication system that does not consume scarce spectrum.



  1. The Switched Telephone Network is a critical public infrastructure.
  2. It has been fully capitalized by telephone users.
  3. The Switched Telephone Network is a critical resource in an extended emergency.
  4. The Switched Telephone Network’s utilization can, and should be improved.
  5. A prerequisite for dismantling the Switched Telephone Network is universal installation of a high bandwidth capability into all American homes.