FCC Filings #88-57

Before the Federal Communications Commission
Washington, D.C. 20554

In the Matter of	)
Review of Sections 68.104 and	)	CC Docket No. 88-57
68.213 of the Commission’s Rules	)
Concerning Connection of Simple	)
Inside Wiring to the Telephone	)
Network	)
	)
and	)
	)
Petition for Modification of Section	)	RM-5643
68.213 of the Commission’s Rules	)
filed by the Electronic Industries	)
Association	)

COMMENTS

The Telecommunications Industry Association ("TIA") User Premises Equipment Division ("UPED") hereby submits these Comments in response to the FCC's Second Further Notice of Proposed Rulemaking ("SFNPRM") in the matter of Review of Sections 68.104 and 68.213 of the Commission’s Rules Concerning Connection of Simple Inside Wiring to the Telephone Network and Petition for Modification of Section 68.213 of the Commission’s Rules filed by the Electronic Industries Association ("EIA"),

RM-5643, released June 17, 1997, FCC 97-209. This SFNPRM is in response to the Building Industry Consulting Services International ("BICSI") proposal for enhanced wire quality standards and additional proposed changes in the Commission’s demarcation point rule.

Growing Problem of Cross-Talk

In its SFNPRM, the Commission agrees that the use of poor quality inside wiring can create a risk of harm to the network and that the BICSI proposal should effectively address the cross-talk problem. However, the Commission questions whether or not the use of poor quality inside wiring in one building would affect service in other buildings. TIA UPED agrees that the use of poor quality premises wiring can affect third parties and, thus, qualifies as harm to the network as defined in Part 68 of the Commission’s Rules and Regulations. TIA also suggests that not only can third-party harm to the network occur between adjacent buildings but harm can also occur to disparate parties within the same structure. Repeatedly in the life of a building, the use of the structure changes from its originally intended purpose and varies according to its current occupancy. For example, what may have originally been constructed as a single-family structure may eventually be used as both a home and a business with multi-unit dwelling, or even a multi-tenant structure with dissimilar businesses operating in it. What was once a large residence, may be office space for several professionals sharing the building costs. Thus, while poor quality premises wiring may not cause third-party harm if cross-talk is experienced in a single family structure occupied by an individual subscriber, that same poor quality premises wiring could cause harm to the network in that same structure if the cross-talk is experienced by distinct and unassociated users. TIA's standard focuses on residential and light commercial wiring systems of up to four access lines (the new FCC definition of simple wiring), and not on a particular classification of subscriber or use since that use is likely to change over the life of the wiring system.

Interim Standard

In the SFNPRM, the Commission indicates its intention to adopt the BICSI proposal as a two-year interim standard and has requested a recommendation on what industry body should be the entity through which industry members could work to develop a permanent standard. TIA UPED submits that ANSI/EIA/TIA-570-91,"Residential and Light Commercial Telecommunications Wiring Standard," already fulfills the requirement for a permanent industry standard. This American National Standard was developed within the Engineering Committee TR-41 sponsored by TIA’s User Premises Equipment Division and involved telecommunications industry representatives with the participation of other industry standards organizations involved in telecommunications, and the standard is intended to be implemented on new construction of, and additions to, residential and light commercial buildings and their subsequent rearrangement. ANSI/EIA/TIA-570-91 describes a premises wiring system intended for connecting one to four exhange access lines to various types of customer premises equipment. This voluntary industry standard, which has been available since 1991, has been largely ignored by the construction industry, which selects premises wiring on the basis of cost rather than performance. TIA standards such as these are periodically reviewed and revised, rescinded, or reaffirmed, as part of the ANSI process and thus such standards keep up with technological, regulatory, and other changes in the industry. Congress, in the National Technology Transfer and Advancement Act ("NTTAA"), has specifically directed federal agencies to use and rely on such voluntary consensus standards in their regulatory missions unless such use would be impractical or otherwise contrary to law, neither of which applies in this instance.

TIA UPED agrees with the Commission’s comment that the use of good quality wiring involves little additional cost and concurs with the Commission‘s plan to institute a proceeding to re-examine the scope of all Part 68 rules as well as any long-term enforcement mechanisms for ensuring the enforcement of Part 68 in this and other Part 68 areas. Commission enforcement of the use of these American National Standard's performance criteria would provide the end user, who in most cases has no choice in the type of wiring that is installed, the assurance of good quality premises wiring and it would prevent the network harm that is occurring. Requiring the use of Category 3 or higher simple wiring is recommended as a solution to the cross-talk harm problem. To prevent the construction industry from reverting to the use of poor quality premises wiring materials after the two-year period, TIA UPED strongly recommends that the Commission make the new rule changes to � 68.213 a permanent requirement.

Copper Wiring

The Commission seeks comment on whether the BICSI proposal is overly restrictive, particularly with respect to the requirement that only copper be used. In the current Part 68 rules, the only medium addressed by the rules is copper wiring. Other media, such as optical fiber or coaxial cable, are not currently addressed within the Commission’s rules. Indeed, only with copper premises wiring is cross-talk an issue. The current specifications for wire in the rules are inadequate to prevent the harm that is occurring. If new media are added to the rules, then appropriate specifications, if any, needed to prevent harm could be generated at that time.

Wire Marking and Marking Interval

In its SFNPRM, the Commission proposes requiring that wire meeting the proposed interim standards be marked at specific intervals to ensure that the markings can be seen, and the quality, thus, identified, even if only a short length of wiring installed in the walls is exposed. As is recommended by ANSI/TIA/EIA-568-A-95, "Commercial Building Telecommunications Cabling Standard," TIA UPED supports the marking of the cable jacket with performance markings in the same manner, and at twenty-four-inch intervals to accommodate even the shortest length of wire being used. TIA UPED further recommends the labeling of the packaging containing the wiring so that the consumer and other purchasers can easily identify the type of cabling being purchased or installed.

Gold and Gold Equivalency

The Commission cites �68.500 as having been amended to incorporate TIA’s standard for determining gold and gold equivalency, acknowledges that TIA provided a standard for determining whether a material meets the requirements for gold and gold equivalence in comments filed in response to the original Notice of Proposed Rulemaking, and seeks comment on whether gold or gold equivalence is necessary in all cases, and whether the new standard in �68.500 of the Commission’s Rules, for determining whether a material meets the requirements for gold or gold equivalence, should also be an interim standard effective for two years until industry develops a permanent standard.

ANSI/TIA/EIA-568-A-95, "Commercial Building Telecommunications Cabling Standard," recommends connector contact material, and Telecommunications Systems Bulletin (TSB)-31-A, "Rational and Measurement Guidelines," includes test procedures for evaluating materials for connectors as specified, and covers test procedures, test equipment, and guidelines for determining compliance with requirements of Part 68. As with ANSI/EIA/TIA-570-91, this American National Standard and TSB were developed within Engineering Committee and Subcommittees sponsored by TIA’s User Premises Equipment Division by telecommunications industry representatives with the participation of other industry standards organizations involved in telecommunications, and already fulfills the requirement for a permanent industry standard. These standards are a direct result of the harm to the network created by poor quality connectors being manufactured and sold by some manufacturers who were interpreting the rules loosely. The gold and gold equivalence rule, a direct result of a petition filed by TIA, has raised the quality of the connectors and eliminated the majority of the harm-to-the-network problems caused by the poor quality connectors. TIA strongly recommends permanent adoption of the gold and gold equivalency rule.

CONCLUSION

TIA UPED commends the Commission on its proposal to adopt the changes to � 68.213 and strongly encourages the Commission to make the new rule a permanent requirement. Only in this way can the construction industry be prevented from returning to the use of poor quality premises wiring materials at the end of the two-year period, causing network harm, and requiring consumers to have to replace substandard wiring systems. TIA UPED also strongly encourages the Commission to institute the proceeding to review the scope of all of Part 68, especially given the mandate of the NTTAA, and possible methods of enforcement mentioned earlier. TIA UPED further recommends that in the review of all the requirements under Part 68 it may be appropriate to revisit the rules adopted in this proceeding if other effective means of achieving the same goals as Part 68 are determined.

Respectfully submitted,

Telecommunications Industry Association
User Premises Equipment Division
Dan Bart, Vice President,
Standards and Technology
Ronald Angner, Chairman, User Premises Equipment Division

2500 Wilson Blvd, Suite 300
Arlington, VA 22201
July 17, 1997 703-907-7703