The Privatization of the Federal Communications Commission’s Part 68

1. ThePrivatization of the Federal Communications Commission’s Part 68 By: Ed Hall Vice President, Technology Development Alliance for Telecommunications Industry Solutions (ATIS)

2. Part 68: History • Before the establishment of the FCC Part 68 rules & regulations, telephone equipment was manufactured almost exclusively by Western Electric whereby: • Inhibiting the proliferation of technical knowledge of telephone equipment and networks outside the Bell System • Creating a monopoly in the development and manufacturing of telephone equipment • Promoting a closed-system architectural & infrastructure

3. Part 68: Purpose • The purpose of the Part 68 rules and regulations is to provide for uniform standards for the protection of the telephone network from harms caused by the connection of telephone equipment and associated wiring • Part 68 also provides for compatibility of hearing aids and telephones so as to ensure that persons with hearing aids have reasonable access to the telephone network

4. Part 68: Influence • Since Part 68 was established, the marketplaces for telephone equipment and local exchange service have changed dramatically whereby: • Vibrant competition has emerged • Basic voice telephones and new types of terminal equipment, including advanced telephones, computer modems, and equipment for individuals with disabilities, have become widely and competitively available • Private standards-setting bodies and testing laboratories for telecommunications equipment have become well established

5. Part 68: Biennial Review • The Telecommunications Act of 1996 directed the FCC to review its rules every even-numbered year and repeal or modify those found to be no longer in the public interest • Because of the rapid pace of change in both network and telephone equipment technologies, the FCC found it increasingly difficult for the regulatory process to keep pace thus creating a public disservice

6. Part 68: Privatization • Pursuant to the Federal Communication Commission’s (FCC) Report and Order CC Docket No. 99-216, FCC 00-400, the FCC minimized the government’s role in Part 68 by privatizing significant portions of its rules governing the connection of customer premises equipment (telephone equipment) to the public switched telephone network and privatized the standards development and terminal equipment approval processes

7. Part 68: Privatization • To ensure continued uniformity and a level playing field that will assure robust competition, the FCC mandated the establishment of the Administrative Council for Terminal Attachments (ACTA) to assume functions privatized • ACTA was formed through the co-sponsorship and support of the Alliance for Telecommunications Industry Solutions (ATIS) and Telecommunications Industry Association (TIA)

8. TheAdministrative Council forTerminal Attachments (ACTA) By: Tim Jeffries Director, ACTA & Technology Development Alliance for Telecommunications Industry Solutions (ATIS)

9. Administrative Council • A non-governmental telecommunications industry driven entity not controlled or dominated by any particular industry segment • Is impartial, fair, balanced, and open • Represent all segments of the industry including: • Local Exchange Carriers (LEC) • Interexchange Carriers (IXC) • Terminal Equipment Manufacturers (TEM) • Network Equipment Manufacturers (NEM) • Test Laboratories (LAB), and • Other Interested Parties (OIP)

10. Administrative Council • Each segment elects 3 representatives to serve a two-year term • 18 Council Members, Chair, & Secretariat (ATIS) • Council meets at least 4 times a year; open to the public • Work with government agencies, standards development organizations (SDO), telecommunications certification bodies (TCB), manufacturers, carriers, and the public

11. Administrative Council: Mission • Adopt mandatory technical criteria for terminal equipment to prevent network harm (Section 68.3) through the act of publishing such criteria developed by the American National Standards Institute (ANSI) accredited standards development organizations; and • Establish and maintain database(s) of equipment approved as compliant with the technical criteria

12. Administrative Council: Responsibilities • Council’s responsibilities must be performed in an equitable and nondiscriminatory manner, and include: • Adopt technical criteria submitted from ANSI-accredited standards development organizations or committees • Provide 30-day public notice to inform industry of proposed technical criteria • Operate and maintain an accurate database of compliant equipment • Establish and maintain an appropriate labeling methodology

13. Administrative Council: Responsibilities • Council’s responsibilities (cont.) • Respond to inquiries from the public regarding its technical criteria • Manage such other tasks as necessary and within the Council’s scope that were formerly part of the FCC’s Part 68 functions • Ensure that the management, activities, and decisions of the Council are independent from all external influences • Coordinate, if necessary, which industry SDOs will take on a particular development project

14. Administrative Council: Database • The continuation of a uniform, nationwide database is essential to protecting the public interest • Maintaining a centralized, accurate database that is readily available and accessible to the public, including individuals with disabilities will: • Permit interested parties such as the FCC, U.S. Customs, and providers of telecommunications services to track and identify suppliers or importers of non-compliant equipment

15. Administrative Council: Database • Database advantages (cont): • Ameliorate concerns regarding the potentially adverse impact of non-compliant terminal equipment on the public switched telephone network (PSTN) by ensuring that suppliers are held accountable for any damage their equipment may cause • Provide the public with the means to identify the party ultimately responsible for the product

16. Administrative Council: Database • Entities submitting information to the database, whether they obtained their approval from a TCB or utilized the supplier’s declaration of conformity (SDoC) process, must submit pertinent information regarding their identity and approved equipment to the database administrator • ACTA assumed the FCC Part 68 database which (currently) maintains records for 34,000+ products • Database is accessible via the Internet

17. Administrative Council: Questions www.part68.org acta@atis.org +1.202.628.6380

18. Administrative Council: Website

19. Administrative Council: Website-Query

20. Information & Guidance for Submissions to the ACTAfrom aSubmitter’s Perspective By: John Bipes Owner/Engineer Mobile Engineering, Inc. OIP Segment Representative, ACTA MOBILE ENGINEERING

21. Submission to the ACTA • via TCB (Telecom Certification Body) • Lab evaluation and Certification of the TTE* (Telecom Terminal Equipment) by one of the commercial labs granted TCB status by FCC • via SDOC (Supplier’s Declaration of Conformity) • Lab evaluation of the TTE* (Telecom Terminal Equipment), and Declaration by the supplier. *Sometimes called TE (Terminal Equipment) or CPE (Consumer Premise Equipment)

22. ACTA Standards • The Administrative Council for Terminal Attachment (ACTA) has adopted technical criteria for Telephone Terminal Equipment (TTE). Equipment approved for connection to the public switched telephone network shall comply with all applicable rules and regulations of Part 68, and with the applicable technical criteria adopted by ACTA. The “dBs/Volts/s.” of FCC’s CFR47, Part 68, Subpart D

23. ACTA Standards • TIA/EIA/IS-968, Telecommunications -- Telephone Terminal Equipment -- Technical Requirements for Connection of Terminal Equipment to the Telephone Network, June 2001 • TIA/EIA/IS-883, Telecommunications -- Telephone Terminal Equipment -- Supplemental Technical Requirements for Connection of Stutter Dial Tone Detection Devices and ADSL Modems to the Telephone Network, June 2001 • TIA/EIA/TSB-168, Telecommunications - Telephone Terminal Equipment - Labeling Requirements, June 2001

24. Questions re. ACTA Standards • Inquires in regards to the technical content of any adopted specification, or interpretation thereof, should be sent to the organization (SDO) that submitted the specification. For information on contacting the appropriate SDO, refer to the technical specification. • A website of Frequently Asked Part 68 Questions is maintained by TIA under Committee TR41.

25. Origination of ACTA Standards • As provided for in the FCC Order [Report and Order in the 2000 Biennial Review of Part 68 of the Commission's Rules and Regulations, CC Docket No. 99-216, FCC 00-400, adopted November 9, 2000 and released December 21, 2000], any ANSI-accredited Standards Development Organization (SDO) observing ANSI consensus decision-making procedures may establish technical criteria and submit such criteria to the ACTA for adoption. • T1 Committee T1E1 • TIA Committee TR41

26. Origination of ACTA Standards • The Report and Order: • Created the ACTA • Split out the “dBs/Volts/s.” of FCC’s CFR47, Part 68, Subpart D - from Part 68 • Mandated the ACTA adopt this unaltered item as their 1st mandatory Terminal Attachment Standard • This split-out and unaltered portion of Part 68, in ANSI format, is TIA/EIA/IS-968

27. TIA/EIA/IS-968 FCC Pt.68 TIA/EIA/IS-968 “dBs/Volts/s.” Enforcement Complaint Procedures, etc. Law

28. TIA/EIA/IS-968 • TTE Line Interface Hostilities; • 4.2 Environmental • 4.3 AC Leakage Current • 4.4 Hazardous Voltage Line Interface Network

29. TIA/EIA/IS-968 • Signal Power Limitations; • 4.5 Line Interface Network

30. TIA/EIA/IS-968 • Transverse Balance Limitations; • 4.6 Line Interface Network

31. TIA/EIA/IS-968 • On-Hook Impedance Limitations; • 4.7 Line Interface Network

32. TIA/EIA/IS-968 • Billing Protection; • 4.8 Line Interface Network

33. TIA/EIA/IS-968 • Plugs & Jacks; • 6.0 Plugs & Jacks

34. TIA/EIA/IS-968 • Grandfathered Equipment; • Annex A • Cross Reference to FCC Pt.68; • Annex B • Informative Definitions; • Annex C & D • Informative References; • Annex E

35. ACTA “Submission Form” • The newest Telephone Terminal Equipment (TTE) Submission Form Version 1.04, October 16, 2001 is now available for download. This version contains a sample SDoC submission as well as a detailed description of each line item. All submitters should use this form for future TTE submissions: • Telephone Terminal Equipment (TTE)Submission Form Version 1.04

36. ACTA “Guidelines & Procedures” • The Administrative Council for Terminal Attachment (ACTA) guidelines and procedures for submitting information to ACTA: • Guidelines and Procedures for submittal of information for inclusion in the ACTA database of approved Telephone Terminal Equipment ("TTE"), Revision 1.1., October 2001

37. Submission to the ACTA US Postage ACTA Submission c/o ATIS 1200 G St. NW Washington, DC 20005

38. The Changing World of TelecomFCC Part 68 and ACTA In Today’s World By: Jimmy Salinas Regional Manger Southwestern Bell Communications, Inc Chair of ACTA

39. Telecom: Today • This year has provided our world with many changes • Many of them have gone unnoticed by our industry to date • Minor thing like the creation of the ACTA • The changing functions of the FCC in relation to the Part 68 technical rules • Items like Sections 68.3, 68.7 and 68.105

40. Telecom: Today • 68.3 - Definitions • Demarcation Point - interconnection between the Wireline Provider and the Terminal Equipment • 68.7 - Technical Criteria for Terminal Equipment • Administrative Council for Terminal Attachments (ACTA)

41. Telecom: Today • 68.105 - Minimum Point of Entry (MPOE ) and Demarcation point • MPOE; Shall be either the closest practicable point to where the wiring crosses a property line or closest practicable point to where the wiring enters a Multiunit Building or Buildings

42. Telecom: Today • Minor Changes, but changes that carry major problems in the way we do our business • First minor item, is the fact that there are no bandwidth limitations in the new FCC Part 68 • Second, there or no facility type limits as well, just Wireline or Wireless Providers

43. Telecom: Today • And finally, the most important minor change is The President’s “Executive Order 13231--Critical Infrastructure Protection in the Information Age” Noting that the way we conduct Business, Government Operates and National Defense, depend on an interdependent network of critical information infrastructures

44. Telecom: Today • It is the policy of the United States to protect against disruption of the operation of information system for critical infrastructure and thereby help to protect the people, economy, essential human and government services, and national security of the United States

45. Questions & Answers: ACTA Panel: Ed Hall, VP, Tech. Development, ATIS Tim Jeffries, Dir, ACTA & Tech. Development, ATIS John Bipes, Owner/Eng., Mobile Engineering, ACTA OIP Rep. Jimmy Salinas, Regional Mgr., SBC, ACTA Chair