Business and data lines routinely represent 70% to 90% of copper wires in service. When you count all active services, 30 to 50 million copper access lines across AT&T territories could be hidden from the FCC’s analysis. Carriers dump nonregulated and wireless expenses onto local service utility books to artificially generate "losses," then claim landlines are unprofitable to justify shutting them off. We note: it seems that AT&T CA’s full financial report for the state public utility is not publicly available. Before the FCC or state utility commissions grant streamlined copper discontinuance, we demand a full, independent audit of all active copper lines and state utility books.