In a message dated 7/28/00, Allan Carr writes:

>  COMMISSION DECISION of 26 May 2000
>  concerning the request by France to maintain pursuant to Article 18(3)of
>  Directive 1999/5/EC of the European Parliament and of the Council (the
>  "R&TTE Directive") a requirement for telecommunications terminal
>  equipment intended for connection to the analogue public switched
>  telephone network of France Telecom  (2000/373/EC)
>  
>  This requires limiting of the line current for TTE used in France.
>  
>  There are no other Harmonized PSTN Standards so you can self-declare
>  that you comply with all the applicable specifications under the R&TTE
>  Directive (which is NONE.!) unless you are selling into France.


Hi Allan:

I have a slightly different interpretation of the Commission Decision that 
you reference.  My interpretation is that the Commission specifically 
declined to require current limiting.  Instead, they said that manufacturers 
must provide information to users about the intended use of the TE.  TE 
without current limiting must contain a warning that it should not be used on 
lines that require current limiting.  

To me, this sounds like a political solution, where the Commission tried to 
appear sympathetic to France Telecom's request, but basically refused to 
impose current limiting for France.

Thus, it appears to me that it is up to the manufacturer to decide whether to 
implement current limiting for France.  I would not necessarily recommend 
that a manufacturer leave out current limiting, but it does appear to me that 
they have this option.  

There are some situations where exercising this option might make sense.  For 
instance, if the manufacturer has an existing design that is otherwise 
compliant with EU requirements, and service personnel would be installing the 
equipment in only a few known locations, it might make sense for the 
manufacturer to confirm that the local phone lines do not require current 
limiting instead of undertaking a costly redesign to add current limiting.

In France Telecom's filing with the Commission, they stated that 22% of their 
existing lines require current limiting, but that steps are underway to 
upgrade these lines.  They also stated that this process would be completed 
within the maximum 30 month delay that the RTTE directive allows member 
states to request.  My guess is that with the response that they got from the 
Commission, France Telecom may feel compelled to accelerate their retrofit 
program.  

Do you agree that manufacturers have the option to omit current limiting 
(with appropriate warnings), or have I misunderstood the Commission decision?


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
http://www.randolph-telecom.com


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