January 28, 2022
Decommissioning 3G Networks: Impact on Consumer Devices
Background
continue to report challenges transitioning customers to
About every 10 years, a new generation of wireless
new devices, Public Knowledge, a public interest advocacy
technologies emerges, offering greater capacity, higher
organization, called on the FCC to oversee the 3G
speeds, and new features. Private telecommunications
decommissioning. It asserts that while it supports the phase-
providers invest billions into their networks to migrate to
out of 3G, “the FCC must exercise oversight to ensure that
next generation technologies—3G, 4G, 5G—to improve
the transition is safe, orderly, and protects public safety and
network capacity and performance, offer new devices and
vulnerable customers.”
services, attract new customers, and generate revenue.
A challenge for Congress is deciding whether regulation of
When providers migrate to next generation networks, they
the decommissioning process or other actions are necessary
often decommission (i.e., shut off and dismantle) older,
to protect the ability of consumers to access critical
obsolete networks. Around 2016, providers began planning
communication services.
their 5G networks, using existing 4G infrastructure.
Simultaneously, providers began planning to decommission
Stakeholder Views
their 3G networks and notify customers of
The AICC and commenters to its petition raised a wide
decommissioning dates. The dates varied by provider but
array of concerns and identified potential impacts from 3G
generally ranged from February 2019 through early 2022.
decommissioning.
For network operators, decommissioning allows them to
AICC
focus resources on 5G networks, which many in Congress
The AICC noted that “tens of millions” of Americans may
see as critical to maintaining U.S. leadership and
be affected by loss of 3G services, including
competitiveness in the global telecommunication market.
Meanwhile, consumers who have older (3G) devices have
people who use 3G-based home alarm systems;
voiced concern to Members that once providers turn off 3G
businesses, hospitals, and government facilities that
networks, they will no longer be able to use their cell
depend on 3G-based security alarms;
phones to access critical services, including 9-1-1.
courts and criminal justice agencies that use 3G-based
electronic monitoring devices;
While providers have informed consumers of the 3G
motorists who depend on 3G-based in-vehicle safety
decommissioning and offered upgrades to newer-generation
services and highway call boxes;
phones, there are often added costs to consumers.
those seeking emergency assistance in elevators;
Additionally, other devices, such as home alarm systems,
workers in agriculture, oil, and other industries using 3G
personal medical alert systems , court-ordered ankle
devices for tracking and safety in the field; and
monitors, and vehicle safety technologies rely on 3G
the elderly who use personal emergency response
networks and may be affected by the 3G shutdown.
systems (PERS) that allow them to live independently at
U.S. wireless providers began announcing shutdown dates
home; the American Association of Retired Persons
in 2016, then extended decommissioning dates several
(AARP) estimates there are 3 million PERS users.
times, due to many reasons, including delays associated
with the Coronavirus Disease 2019 (COVID-19) pandemic.
School Bus Technologies
AT&T expects to finish shutting down its 3G networks in
A U.S.-based company that manufactures school bus
February 2022, Verizon by December 2022, and T-Mobile,
connectivity technologies noted that “over 100,000 school
which is shutting down its 3G networks in segments—by
buses and other vehicles, including first responder, utility,
March 2022, June 2022, and July 2022.
and construction vehicles, and over-the-road freight carriers
rely on 3G services for safety, compliance with federal
In May 2021, the Alarm Industry Communications
mandates, and logistics.” The National Association for
Committee (AICC) filed an emergency petition with the
Pupil Transportation cited obstacles to transitioning buses
Federal Communications Commission (FCC), asking it to
related to the COVID-19 pandemic, including those
direct AT&T to delay the discontinuance of its 3G data
associated with the global semiconductor shortage.
service until December 31, 2022. Other industry and
consumer groups filed comments in support of the petition,
Connected Car Technologies
while AT&T argued that device makers had ample time to
General Motors claims that 20 million global OnStar
ensure consumers had upgraded devices, and many
subscribers—its navigation and communication system—
manufacturers and suppliers had successfully transitioned.
may be affected. OnStar is to push a free software upgrade
The FCC did not act on the petition, thus AT&T is
to mitigate issues for owners of post-2015 car models.
proceeding with its 3G decommissioning as planned. As
However, owners of older cars may lose service. The
decommissioning dates approach and device makers
Alliance for Automotive Innovation noted that Jaguar Land
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Decommissioning 3G Netw orks: Impact on Consumer Devices
Rover has approximately 260,000 vehicles in the United
industry officials report the number is closer to 1.5 million
States that may be impacted by the 3G sunset.
to 2 million customers. Medical alert suppliers are
informing users that devices may stop working at any time,
Court-Ordered Electronic Monitoring Devices
as AT&T is already decommissioning towers. On January
Alcohol Monitoring Systems, Inc. (AMS), a U.S.-based
11, 2022, Consumer Reports stated that carmakers have
manufacturer of electronic monitoring devices and offender
upgraded many cars; however, in some cars, upgrades are
monitoring services to the criminal justice system, noted
not possible—leaving millions of cars unable to
that the monitoring industry is collectively tracking a
automatically contact first responders after a crash.
quarter of a million offenders at any given time. AMS noted
FCC Authorities
some devices are dependent on 3G services, and that the
Federal law (47 U.S.C §214) and the FCC’s implementing
COVID-19 pandemic, along with global chip shortages,
regulations (47 C.F.R. Part 63) prevent telephone
delayed upgrade plans. The North Dakota Attorney General
echoed AMS’ concerns.
companies from abruptly discontinuing, reducing, or
impairing wireline telecommunications service without
Manufacturers of Medical Alert Devices
proper notice. The FCC has forborne from applying Section
214 rules to wireless services.
Telit, a manufacturer of connected devices, such as medical
devices, stated that as of May 2019, “more than 80 million
devices still use 3G networks in North America.” AARP
AICC argued the FCC has the authority to direct AT&T to
notes that while AICC “has attempted to implement a
delay its 3G network decommissioning, since the action
would promote safety of life and property, a key FCC
stopgap technology called CellBounce to assist with the
transition to 3G services … it is not sufficient for use with
function described in Section 1 of the Communications Act
PERS and does not meet commercial fire code standards.”
of 1934, as amended (47 U.S.C. §151). Further, the AICC
argues the FCC has authority over AT&T as a “common
carrier,” subject to FCC regulations aime
Rural Wireless Providers
d at ensuring just
and reasonable terms of services (e.g., reasonable pricing
The Rural Wireless Association (RWA) wrote in support of
rates, non-discriminatory practices).
the AICC petition and extension of 3G services, expressing
concern that customers were experiencing degradation in
AT&T acknowledges it provides common carrier services
service even before the decommissioning was complete. It
in the form of mobile service to customers, and has assisted
conducted a survey of its members —small and regional
them with the transition. However, AT&T asserts that
wireless providers—and reported degradation in services in
enterprise Internet of Things devices—home alarm systems,
many areas. The RWA requested extension of services for
medical devices—are not common carrier services and thus
all three providers until December 31, 2022, to allow
are exempt from FCC common carrier regulation.
smaller wireless carriers more time to transition and to test
services for their customers (e.g., elderly, farmers,
Public Knowledge agreed that current FCC rules do not
ranchers).
require mobile providers to obtain permission to shut down
their networks (47 U.S.C. §214(c)). But it argued that this
Mobile Virtual Network Operators (MVNO)
does not mean the FCC has relinquished its authority to act;
In its guidance to consumers, the FCC noted carriers such
it has authority over common carrier network operators
as Cricket, Boost, Straight Talk, and several Lifeline mobile
pursuant to 47 U.S.C. §201(b), which prohibits any unjust
service providers that use AT&T’s, Verizon’s, and
or unreasonable practice, and gives the FCC broad
T-Mobile’s networks—known as MVNOs—may be
regulatory authority to prescribe such rules and regulations
affected.
as may be necessary and in the public interest. Public
Knowledge urged the FCC to exercise its regulatory
Consumer Groups
authority to ensure a safe and orderly transition, to compel
According to Public Knowledge, research released in
stakeholders to provide the FCC with detailed information
December 2019 “indicates that 15%-20% of wireless users
on the impact of the shutdown, and to protect consumers
are still primarily or entirely reliant on 3G for wireless
from loss of vital services.
service.” In some instances, the research notes, 3G users
may have 4G devices, but do not use them often because
Congressional Considerations
they do not have 4G service in their area.
Congress may consider short- and long-term actions
concerning decommissioning. Short-term options could
Efforts to Transition Consumers and Devices
include encouraging the FCC to facilitate coordination
In October 2021, the FCC issued guidance to consumers,
among stakeholders and establish a process to identify and
notifying them about potential impacts to devices and
address any loss of vital services for consumers. In the long
services, and advising them to work with their providers to
term, Congress could direct the FCC to collect data on
obtain an upgraded phone. Some providers have offered
challenges and best practices during the 3G
customers new 4G or 5G phones; others have not. Many
decommissioning and use the data to improve future
local public safety offices redistributed the FCC guidance to
transitions, or to establish formal processes and timelines to
alert residents that 3G phones would be inactive and unable
guide future transitions.
to dial critical services, including 9-1-1.
Jill C. Gallagher, Analyst in Telecommunications Policy
Since the filing, some manufacturers have made progress.
AICC reported that at the end of 2020, close to 6 million
IF12029
customers nationwide still needed upgrades; in 2022,
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Decommissioning 3G Netw orks: Impact on Consumer Devices
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