Thanks to Steve, Vic, Henry, Graham, Larry, et.al. for your comments... So, summarizing here, I'm sensing two schools of thought: 1) when changing the T1 interface to an HDSL interface, no change is required for the FCC Reg. No. code "DD" already on the product, since no rules are in place for HDSL (althought there is a proposed "DL" code for xDSL modems), and the issues of interface, billing protection, etc., are not affected by the change in interface; OR,
2) when changing the T1 interface to an HDSL interface, one should remove the "DD" from the FCC Reg. No., since the "DD" implies that the interface is appropriately registered to published requirements, and a phone company could question same. I suppose as with any new technology one can just plow on ahead and mark their product any way they choose, hoping that it will be a long while before any error catches up with them, but this is not prudent in this day and age. Any final comments on this? I'll email Bill Howden with the question and report back his comments...thanks again. D Graham Rae Dulmage wrote: > > Dear Dwight, > > I would have to agree with VIC that the Canadian officials are a very > responsive bunch. In my dealings with 100+ jurisdictions they always > won the quick draw. Telecom New Zealand was a close second at times > as was TAS(Singapore). > > You do raise a point about the FCC registration. As HDSL has no > FCC rules as of yet I don't believe that the modified interface > can continue to be marked as a DD interface. This gets into areas > of tariff issues and how phone companies look at FCC registration > as indicating a regulated interface. If the product contained > an FXO and a T1 interface and an HDSL than DD-T would be appropriate to > cover registrered interfaces. Presumably the > HDSL interface would be marked as HDSL. It is an interesting > question and I would like to here other comments on this as well. > You however do not need to formally deregister the existing T1 > interface. > > Regards > > G. Rae Dulmage, B. Comm., > President > TelApprove Services Corporation > (613) 257-3015 > Dwight Hunnicutt wrote: > > > > Regarding HDSL interfaces and FCC Part 68: > > > > Our company has a product with T1 and FXO interfaces (FCC registered > > with a -DD-T suffix on the FCC Reg. No.). We will change the T1 > > interface to an HDSL interface (via a piggyboard). > > > > Question: does this change affect the "-DD-T"? > > > > We know that FCC has not published rules for xDSL technologies, so no > > blessing is required from FCC until they publish same (can't use the > > "DL" code yet). > > > > (Industry Canada has new rules for ADSL, yes? Would this change affect > > the I.C. sticker?) > > > > Also, the "DD" simply indicates that the equipment provides CSU > > functions, along with billing protection, etc., and the "T" indicates > > DTMF out the FXO port. > > > > Since the HDSL is simply a different interface for the same data as the > > T1 interface, I would think that based upon the the definition of the > > "DD" code, no change would be needed to our FCC Reg. No. ending with > > "-DD-T"? Or would we drop the "DD" (and therefore have to reregister)? > > > > Anybody out there agree? thanks... > > > > D > > > > -- > > > > DWIGHT HUNNICUTT > > Sr. Compliance Engineer > > > > **************************** > > * <[email protected]> * > > * (510) 413-1349 direct * > > * (510) 492-0808 fax * > > * VINA Technologies,Inc. * > > * 42709 Lawrence Place * > > * Fremont, CA 94538 * > > ****************************
