If one has to modifiy a product to meet the B-Type surge, for example, a modification filing would be in order not a reregistration. A modification filing will not change your registration, it just informs the FCC of the changes and ensures the product is still in compliance. A Reregistration is used when an equipment code changes or the manufacturing facility changes, which would change the Registration #.
Bill Von Olven had thrown out 10/20/99 as a date that Continuing Compliance had to meet the new requirements but, nothing is really etched in stone B. Alves -----Original Message----- From: [email protected] [mailto:[email protected]] Sent: Monday, April 05, 1999 8:46 AM To: [email protected] Cc: [email protected] Subject: FCC Part 68 re-registration (?) In a message dated 4/5/99 Tania Grant writes: > Does anyone have any information regarding the outcome of the above Public > Notice, released by FCC on February 17, 1999 on the subject of clarification > of paragraph 68.2 (j)(3)? > > I agree that the original paragraph is murky. However, the above Public > Notice clarifies nothing except to spread panic among certain of our > suppliers that they can no longer supply us with their registered, directly > connected equipment, after May 19, 1999. > > FCC is seeking comment from manufacturer's whether to "clarify 47 C.F.R. > 68.2(j)(3) requiring re-registration of previously registered equipment > after May 19, 1999." Tania: I'm glad that you have raised this question to the group. I have a client whose interpretation of the February 17 Public Notice is that he must re-register an older modem design. Since the older design does not survive the Type B surge, re-registration means a redesign of his product. This, in turn, affects his UL compliance as well, not to mention all of the product that he has in the manufacturing pipeline. All in all, not a pretty picture. My own interpretation of clause 68.2(j)(3) is that it applies only to previously unregistered PSDS (public switched digital service) devices. Unfortunately, I can not find any other language in Part 68 that specifically grandfathers equipment previously registered under the old rules. I can not believe that the FCC would require re-registration of all previously registered equipment. This would be contrary to the basic regulatory philosophy that the FCC has exhibited in the past. It would also incur a HUGE cost burden on the industry, while securing only a modest technical benefit. Can anyone in the group shed some light on this issue? Do we just have to wait until the FCC issues a clarification, and hope that reason prevails? Or is there some existing documentation that clearly shows that re-registration is not required? Joe Randolph Telecom Design Consultant Randolph Telecom, Inc.
