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
> 
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