Tom -

The only flaw here is that the Part 63 only says the carrier
has to report outages and come up with a plan to reduce
outages from the same source.  There's little or nothing to
*require* a reliable network.

Aside from which, the existence of Part 63 infers that
outages are expected and does not use the words "reliable,"
"guarantee" or "reliability."

>From a document on the TIA web site (Project 25), "The
purpose is to assist with analysis of issues that can affect
reliability and to determine best practices to recover from
natural or man-made outages, including those that might be
caused by a computer hacker or terrorist.

http://www.tiaonline.org/standards/project_25/CIP_HS.pdf

Project 25's front page web site states, "Recognizing the
need for common standards for First Responders and Homeland
Security/Emergency Response professionals, representatives
>from the Association of Public Safety Communications
Officials International (APCO), the National Association of
State Telecommunications Directors (NASTD), selected Federal
Agencies and the National Communications System (NCS)
established Project 25 (P25), a steering committee for
selecting voluntary common system standards for digital
public safety radio communications."

The TIA document also references the NRIC (Network
Reliability and Interoperability Council).  Their latest
charter looks primarily at emergency services and homeland
security.  Much reference is made to "best practices."  It's
interesting to note that the NRIC has statements on certain
of their web pages stating, "Implementation of NRIC Best
Practices is voluntary."  It's also interesting to note that
the web server appears to reside on a bell-labs.com domain.

http://www.nric.org/

So this whole reliability thingy is primarily aimed at
making certain communications systems are up for emergency
service providers, especially government entities, with at
least some nodding to e911.  Nearly everywhere is that word,
"voluntary."

According to ANSI T1, the NRIC is the successor to the NRC.

http://www.t1.org/html/nric.htm


Regards,

Peter L. Tarver, PE
[email protected]


> -----Original Message-----
> From: William Thomas (Tom) Sykes
> Sent: Tuesday, November 23, 2004 9:04 AM
> To: [email protected]
> Subject: RE: Should telephones still work during
> power loss?
>
>
> All:
>
> It is in 47 CFR, but not Part 68, but Part 63.
>
> It has partial roots in the FCC's Office of
> Engineering and Technology (OET) Rules and
> Regulations regarding Service Outages and
> Reporting.  If a service outage of a certain
> number of customers, or of a certain type,
> exceeds a certain duration, it must be reported
> to the FCC, along with Root Cause Analysis, etc.
>
> See Title 47 CFR 63, Section 100 [47CFR63.100]
> http://frwebgate.access.gpo.gov/cgi-bin/get-cfr.cg
> i?TITLE=47&PART=63&SECTION=100&YEAR=2001&TYPE=TEXT
>
> If this link came thru too broken, one can link
> to it from the FCC OET's Rules and Regulations page
> http://www.fcc.gov/oet/info/rules/
> and click on "Outage Reporting Rules Section 63.100"
>
>
> William T. Sykes
> Lucent Technologies EH&S
> Product Safety/Conformance Manager
> Room 7B-516A
> 600-700 Mountain Avenue
> Murray Hill, NJ  07974-0636
> (908)582-6937
>


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