Since assuming the job of maintaining a database of approved Part 68 equipment, the Administrative Council for Terminal Attachments (ACTA) has noted a decline in the number of terminal equipment filings. ACTA has attributed much of the decline to the telecommunica-tions industry's economical downturn. Unfortunately, ACTA is also battling a false impression that Part 68 was deregulated rather than privatized.

ACTA believes that part of the decline in filings is a result of this incorrect perception. Some responsible parties are unaware that terminal equipment under the scope of Part 68 must be listed in ACTA's database. Others believe that their equipment no longer requires approval, says ACTA. Equipment must still comply with Federal Communications Commission (FCC) rules. Those who are unaware adversely affect the telecommunications industry at large, says Timothy Jeffries. Jeffries is ACTA's director at the Alliance for Telecommunications Industry Solutions (ATIS), which serves as the secretariat for ACTA. He notes that it is crucial to continue to have approved equipment listed in the database. "This is an industry-wide concern," says Jeffries.

ACTA implemented a new filing requirement in October 2002. Product information must be retrievable from the database before the product is connected to either the public switched telephone network (PSTN) or private-line services that require such approval.

ACTA has conducted an educational conference and participated in speaking engagements to get the word out. ACTA has also enlisted the help of FCC to inform responsible parties of their duties with regard to compliance with technical criteria, equipment approval, and listing equipment in ACTA's database.

The Privatization Process

Because of the rapid changes in both network and telephone equipment technologies, FCC found it increasingly difficult for the regulatory process to keep pace. As a result, FCC privatized certain Part 68 duties and responsibilities in December 2000. Privatization occurred in two stages. First, Part 68 certification authority was allocated to private telecommunication certification bodies (TCBs) in addition to FCC. Second, ACTA was established to assume the privatized duties and responsibilities.

To transition the registration functions quickly, ACTA had to be operational within 60 days after the notice to the industry. ACTA then had only 180 days after the report and order to publish the 130 pages of Part 68 technical criteria privatized by FCC. Accordingly, Jeffries observes, "establishing ACTA within the timeline specified by FCC, in and of itself, was a monumental accomplishment." One positive by-product of the privatization process has been the clarification of Part 68 technical rules. The detailed requirements that were formerly in Subpart D of Part 68 have been removed and are now contained in TIA/EIA-IS-968. None of the requirements has been changed, but the content was reorganized into a more logical sequence and minor errors were corrected. "This by itself was a massive effort by the TIA TR 41.9 Committee," says Roland Gubisch. Gubisch, a founding member of ACTA, is chief engineer of EMC and telecom at ITS Intertek Testing Services (Boxborough, MA).

ACTA's Progress

ACTA has had a productive year with respect to preparing the industry for privatization. Technical requirements have now been extended to include asymmetric digital subscriber line (ADSL) and stutter dial tone, formerly covered by FCC waiver.

Technical criteria have been adopted for products supporting x-type digital subscriber line (xDSL) technologies. High-speed digital terminal equipment for single-pair high-bit-rate digital subscriber line (SHDSL), high-bit-rate digital subscriber line—second generation (HDSL2), and four-wire high-bit-rate digital subscriber line—second generation (HDSL4) can now be approved to T1TRQ.6. ACTA has adopted product-labeling requirements. It has mandated the provision of consumer information on all equipment approved for connection to PSTN and to certain private-line services requiring such approval.

ACTA will soon be launching its Web-based filing system (ACTA online filing [AOF]) to submit equipment information to the Part 68 database. ACTA will also continue to monitor standards activities to encompass other industry technologies, such as very-high-speed digital subscriber line equipment.

One of the tasks assigned to ACTA was the operation and maintenance of the FCC-registered terminal equipment database. ACTA converted the internal Microsoft Access database into a publicly accessible Web database. In the process, FCC's database format had to be altered, and some entries had to be corrected. Users and original equipment manufacturers can now easily check whether a specific product has been approved—something that was not possible under FCC. Network operators can now quickly trace field problems and reach a local contact if the terminal equipment is the culprit.

Equipment Approval

The mechanics of ACTA's filing process are different from the former FCC process. Although product-specific information, such as test results, product diagrams, and schematics, still must be retained, ACTA does not require nor want this type of proprietary information. Historically, this information was submitted to FCC. Now, the job of retaining such documentation for a defined period of time falls solely on the responsible party. Product information to be submitted to ACTA is outlined in the document, Guidelines & Procedures for submittal of information to ACTA for inclusion in the database of approved Telephone Terminal Equipment ("TTE"),
revision 2.3. The document is available at http://www.part68.org/documents.cfm.

Product identification has changed to a straightforward format beginning with "US." Identification also includes the ringer equivalence number (REN) and the applicant-defined field. Requirements have been added for indemnification of ACTA. The supplier's declaration of conformity (SDoC) or TCB certificate must also be provided.

To establish product credibility, manufacturers can opt for certification by a TCB. A copy of the certificate must be submitted to ACTA. Manufacturers with confidence in a product's integrity can select SDoC approval. Although the SDoC route can provide quick market access without submitting an application to a TCB, Gubisch points out that "the added step of TCB certification can occur quite quickly." In addition, manufacturers that choose the SDoC route must provide documentation that identifies and describes the responsible party and the product.

Consequences of Noncompliance

ACTA is randomly auditing compliance with its administrative procedures and is working with FCC to facilitate compliance and market surveillance. Network connection of unapproved terminal equipment is a violation of FCC rules. Should a noncompliant product be discovered, FCC maintains the authority and jurisdiction to enforce its rules. Penalties for failure to comply with terminal equipment requirements are found in 47 U.S. Code, Section 503. Complaints about noncompliant equipment may be made to FCC pursuant to 47 CFR, Part 68, Subpart E.

The Bottom Line

Gubisch concludes that "the bottom-line results of the transition from FCC to ACTA are quicker market access for manufacturers, faster adoption of new technology approval standards, a readily accessible database of approved equipment, and, soon, online filing and payment." Visit ACTA's Web site at http://www.part68.org for more information. ACTA can also be contacted by e-mail at acta@atis.org or by phone at 202-628-6380.

With the recent exchange of letters, the United States and Australia can each now test telecom equipment for export to the other country. The two countries will designate conformity assessment bodies (CABs) to begin this first phase of mutual recognition. Under the Asia-Pacific Economic Cooperation (APEC) mutual recognition arrangement (MRA), Phase I also provides for the mutual recognition of test reports for telecommunications equipment.

The exchange letters were signed in October. In Australia, the Australian Communications Authority (ACA) is both the regulatory and the designating authority under the MRA. In the United States, FCC is the regulatory authority, but the National Institute of Standards and Technology (NIST) is the designating authority.

As part of Phase I, the importing economy will accept test reports prepared by designated CABs of the exporting economy. NIST is now accepting applications from U.S.-based testing organizations for CAB designation to Australia. Nomination requirements can be found at http://ts.nist.gov/ts/htdocs/210/gsig/telapec-cabscriteria.htm under "APEC Tel MRA—List of Information Required for CAB Designation." Prospective CABs must be accredited to ISO/IEC 17025 for the covered Australian standards. Accreditors must be recognized by the National Cooperation for Laboratory Accreditation (NACLA) or recognized under the Asia Pacific Laboratory Accreditation Cooperation (APLAC) MRA. CABs can be accredited for a specific scope of interest or for all of ACA's technical regulations. NIST has posted a list of ACA technical regulations at http://ts.nist.gov/mra, under "Specific Requirements for Australia." For more information, contact NIST at 301-975-5521.