Telecommunications Industry Association
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Project Number
Document Title
ACTA Report to SDO TR41.9 – Portland
John Bipes, ACTA OIP-Primary and ACTA SDO Representative to
TR41.9
Source
Contact
Distribution
Intended Purpose
of Document
(Select one)
John Bipes, ACTA OIP-Primary
MOBILE ENGINEERING
906 Adams St.
Mankato, MN 56001 U.S.A.
Phone: 507-345-7169
Fax: 507-345-8626
Email: mobeng@hickorytech.net
TR-41.9
X
For Information
The document to which this cover statement is attached is submitted to a Formulating Group or
sub-element thereof of the Telecommunications Industry Association (TIA) in accordance with the
provisions of Sections 6.4.1–6.4.6 inclusive of the TIA Engineering Manual dated March 2005, all of
which provisions are hereby incorporated by reference.
Abstract
ACTA activities since the last meeting of TR41.9 – ACTA Representative to SDO. Report on ACTA’s 6th
March, 2008 Face-to-Face meeting and subsequent ACTA activities.
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Administrative Council for Terminal Attachments
ACTA Public Meeting(s):
Recent Meeting:
6th March, 2008 (Face-to-Face Meeting)
At the March meeting of the ACTA:
It was queried if the TIA-168-B, replacing TIA-TSB-168-A, would be forwarded to
the ACTA. On 6th March it was not known where the document was in the TIA
publishing process. (In late April TR41.9 chair Phil Havens and ACTA SDO
Liaison John Bipes corresponded via e-mail on the same subject. John
recommended Phil to check with Stephanie Montgomery, TIA, to see what the
document hold-up was. No word has been received by John Bipes as of 5 th May,
2008.)
A big issue before the ACTA in March was the meeting with FCC, which happened a
week after the March ACTA meeting. (Details later on in this report.)
ACTA-08-005, Connector Attestation (Trone Bishop)
http://www.part68.org/documents/meetingrec/08-02-06/ACTA-08-005.doc NOTE: The
ACTA’s adoption of ANSI/TIA-1096,
ACTA-08-003, Point-of-Sale Observation – 19 th February, 2008 (John Bipes)
http://www.part68.org/documents/meetingrec/08-0206/Report%20to%20the%20ACTA%20on%20SDO%20TIA%20TR41.pdf (See the
reference in the ACTA’s presentation to the FCC on this enforcement issue later on in
this report.)
ACTA-08-006, Observations of Industry Canada (Claude Beaudoin).
http://www.part68.org/documents/meetingrec/08-02-06/ACTA-08-006.pdf
Also, another big issue in March; the ACTA’s announcing the Filing Fee increase,
effective 1st May, 2008.
PUBLIC NOTICE
No.: PN08-01
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Adjustments to ACTA’s Filing Fees
March 14, 2007
Effective May 1st, 2008 the Administrative Council for Terminal Attachment (ACTA)
will adjust its fee for processing Telephone Terminal Equipment (TTE) information
submitted for inclusion in the centralized database of Part 68 equipment to $425.00
per submission. The adjusted fee applies to submission of Original, Modifications,
Notice of Change, Re-certification/re-declarations, and Request for Responsible Party
Codes. Additionally, the fee for processing, posting, and maintaining a Responsible
Party’s Supplier’s Declaration of Conformity (SDoC) on the ACTA website will be
adjusted to be $425.00 (per submission) to parties issuing notice to post its SDoC.
As a result of the above adjustments, the Guidelines and Procedures for submittal of
information for inclusion in the ACTA database of approved Telephone Terminal
Equipment ("TTE"), Revision 3.0, December 2006 will be revised to reflect this
change.
Telephone Terminal Equipment (TTE) approved for connection to the PSTN must
comply with all applicable rules and regulations of FCC Part 68, and with the
applicable technical criteria adopted by ACTA.
Parties responsible for TTE, whether they obtain their approval from a
Telecommunications Certification Body (TCB) or utilize the Supplier’s Declaration of
Conformity (SDoC) process, must submit to the ACTA database administrator all
information required by ACTA for inclusion in the centralized database of approved
Part 68 products.
Compliance with Part 68 and ACTA Adopted Technical Criteria is mandatory for
terminal equipment (TE) connected to the Public Switched Telephone Network
(PSTN) or wireline facilities owned by wireline telecommunications providers and
used to provide wireline subscriber services. Penalties for failure to comply with the
requirement fall under US federal jurisdiction. Penalties can be found in 47 U.S.C.
Section 503.
Questions and comments about this notice should be submitted to the ACTA
Secretariat via E-mail at acta@atis.org, or by phone at +1.202.628.6380.
Reports on the ACTA/FCC meeting, 13th March:
Marlene H. Dortch, Secretary
Federal Communications Commission
Office of the Secretary
th
445 12 Street, S.W.
Washington, D.C. 20554
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Re: WT Docket No. 99-216 Ex Parte Presentation
Dear Ms. Dortch:
On March 13, 2008, representatives from the Administrative Council for Terminal
Attachments (ACTA) met with representatives of the Federal Communications
Commissions’ Wireline Competition Bureau and Enforcement Bureau. The purpose of
the meeting was to discuss Part 68 compliance concerns, to discuss opportunities for
enhanced Part 68 enforcement by the FCC and to make the FCC aware of recent
changes to the ACTA Operating Principles and Procedures.
The individuals representing the FCC’s Wireline Competition Bureau’s Industry
Analysis Technology Division at the meeting included: Rodger Woock, Division
Chief; Cathy Zima, Deputy Division Chief; Kirk Burgee, Chief of Staff; John Vu,
Electronic Engineer; Michael Goldstein, Senior Engineer; and Darryl Cooper,
Attorney. The individuals representing the FCC’s Enforcement Bureau’s Spectrum
Enforcement Division at the meeting included: Kathryn Berthot, Division Chief;
Ricardo Durham, Deputy Division Chief; and Neal McNeil, Senior Electronics
Engineer. The individuals representing ACTA at this meeting were: Jim Haynes,
ACTA Chair and Vice President, Engineering and Regulatory Affairs, Uniden; Patrick
Donovan, Director, Government Affairs, Telecommunications Industry Association
(TIA); Jean Paul Emard, Director, ATIS; Paul Anderson, ACTA Administrator;
Thomas Goode, General Counsel, ATIS; and Deirdre Cheek, Attorney, ATIS.
The discussion at the meeting was consistent with the presentations that are enclosed
with this letter. Pursuant to Section 1.1206(b) (2) of the Commission’s rules, one copy
of this letter is being filed electronically for inclusion in the public record of the
above-referenced proceeding.
Sincerely,
Thomas Goode
General Counsel
Attachment (MS PowerPoint© presentation to the Commission which follows.)
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Administrative Council for
Terminal Attachments
(ACTA)
March 13, 2008
•Background: Mission and Structure
of ACTA Sponsorship
•Changes to the ACTA Operating
Principles and Procedures
•ACTA Meetings
•Part 68 Compliance Concerns:
ACTA Actions to Promote
Compliance, Request for Enhanced
FCC Enforcement
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ACTA: Mission and
Structure
•ACTA is an open organization that:
(1) adopts technical criteria for terminal equipment
to prevent network harm (as defined in Section 68.3 of
the FCC’s Rules) through the act of publishing such
criteria developed by the American National Standards
Institute (ANSI) accredited standards development
organizations; and
(2) establishes and maintains a database of
equipment approved as compliant with the technical
criteria.
•ACTA is jointly sponsored by the
Alliance for Telecommunications Industry
Solutions (ATIS) and the Telecommunications
Industry Association (TIA).
•ACTA has established Operating
Principles and Procedures (OPP) that detail
the mission and membership of ACTA, as
well as the processes governing the operation
of ACTA.
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•Membership in ACTA is open to any
organization, company or group having an
interest in the business of ACTA.
•The membership is represented by “Interest
Segment Representatives, “who are elected by a
majority of votes from their respective segment
participants to serve two-year terms.
•“Invited Observers” under the OPP include
FCC, Industry Canada, and Commision Federal de
Telecomunicaciones.
•The sponsors (ATIS and TIA) ensure
that the ACTA is populated in a manner
consistent with the criteria established by
ANSI for a balanced and open membership
•On December 3, 2007, ACTA modified its
Operating Principals and Procedures (OPP) to
reduce the number of interest segments from six
to four.
Old OPP (v. 1.9)
•Local Exchange Carriers (“LEC”)
•Interexchange Carriers (“IXC”)
•Terminal Equipment Manufacturers (“TEM”)
•Network Equipment Manufacturers (“NEM”)
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•Testing Laboratories (“LAB”)
•Other Interested Parties (“OIP”)
New OPP (v. 2.0)
•Service Provider Segment (“SPS”)
•Manufacturer Segment (“MS”)
•Testing Laboratories Segment (“LAB”)
•Other Interested Parties (“OIP”)
•This change better reflects the current make up
of the industry; ACTA membership remains
balanced and open.
•No one segment may dominate ACTA.
ACTA Meetings
•Representatives from the FCC are
welcomed at all meetings, which occur four
times annually; two face-to-face meetings in
Washington, DC, and two virtual meetings.
•The schedule of ACTA meetings is
maintained on the Part 68 website
(www.part68.org).
•The next meeting of the ACTA (virtual
meeting) will take place on June 12, 2008.
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•Industry Canada typically attends
ACTA meetings.
•Greater FCC participation in ACTA
meetings is desired.
Compliance Concerns
•While consumer telecommunications and enterprise
equipment production has risen yearly by 5.3-6.0% since
2002,* ACTA has observed a significant decrease in filings
over the past several years.
•Several potential causes for this decrease have been
suggested, including the failure of some parties to test
equipment for compliance and register with ACTA under Part
68.
•In May 2006, ACTA raised the issue of the sale of noncompliant customer premises equipment with the FCC.
•A recent ACTA contribution notes the continued availability
of devices not listed in the Part 68 database that could cause
damage to the PSTN.
•Industry Canada findings (submitted as a contribution to
ACTA) detail three specific instances of non-compliance within
Canada; the equipment at issue also may be available in the US.
•There may also be confusion among some in the industry
regarding the respective roles of ACTA and the FCC regarding
equipment certification and compliance.
*Source: TIA 2008 Telecommunications Market
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Review and
Forecast; Chapter
3 –Enterprise and
Consumer Market.
Compliance Concerns: ACTA
Activity
In support of its mission, the ACTA has and
will continue to:
•Inform the FCC of instances of non-compliance
with the Part 68 rules of which ACTA becomes
aware.
•Work one-on-one with current database filers to
ensure correct filings (via the auditing system) and
counsel filers on their obligations.
•Issue press releases/web-based notifications to
all known interested parties of new technical criteria
as they are promulgated.
•Conduct programs (such as face-to-face
seminars and Internet-based webinars) to educate
current and future filers about Part 68 requirements
and technical criteria.
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Compliance Concerns:
Enforcement
ACTA also requests the FCC to:
•Enhance its enforcement of Part 68
requirements.
•Issue industry alerts as enforcement
actions are taken in order to make potential
offenders aware of such actions.
•Continue to cooperate with Industry
Canada to ensure that manufacturers of noncompliant equipment are brought into
compliance.
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Questions or Comments?
Please direct any inquires regarding
ACTA to:
Paul Anderson
ACTA Administrator
ATIS
panderson@atis.org
(202) 434-8654
Thomas Goode
General Counsel
ATIS
tgoode@atis.org
(202) 434-8830
Later, on 31st of March, the ACTA Secretariat Paul
Anderson reported on the ACTA/FCC meeting, 13th
March:
“…It was very easy to discern the focus and interest displayed by each of the attendees
from the Commission. The explanation of the reorganization was pretty well straightforward. Additionally, it is my belief that the invitation for future FCC involvement
was well received, especially since we explained that Industry Canada was a regular
participant and that most of our issues might interest its being present. It is my
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understanding that FCC staff was not sure that they would be welcome, but hopefully
we changed that mindset. As the Ex Parte mentions, the meeting went pretty well by
the prepared handout.
The samples of the telephones [], as well as other photos and drawings, were
circulated to explain our dilemma with the non-compliant concerns. The lack of
ACTA filings was brought to the table as well. My reaction is that FCC staff,
especially the enforcement people at the table, was not aware of these issues.
Hopefully, they now have a much broader understanding, plus the parallel of ACTA
filings being down could be the result of importers not taking the Part 68 rules as
serious as they should.
All in all, the meeting lasted about an hour. In my opinion, it ended with a renewed
spirit of cooperation from the FCC. There was a sense that some action on their part to
pursue violations with a more aggressive enforcement program will be implemented,
especially if ACTA continues to provide examples. Of course, time will tell, but I
expect to see a Public Notice that highlights the need to have telephone devices tested
for compliance to the rules and that they be submitted for posting to the ACTA
database…”
Present ACTA Leadership as of:
Primary: Trone Bishop, Verizon
Tel: 301-236-3754
Email: trone.t.bishop.jr@verizon.com
Primary: Jimmy Salinas, AT&T
Tel: 713-567-8095
Email: js5906@att.com
Nominee: Amar Ray, Embarq
Nominee: Ken Biholar, Alcatel-Lucent
NOTE: Interim elections will be held during the next meeting of the ACTA on 12th
June, 2008 to fill vacant positions. Individuals elected via interim elections will
serve out the term during which they were elected. The remainder of the term
they serve will not count against the two term maximum IS Reps may serve.
Individuals who are elected during interim election procedures will be eligible for
election for two terms after their interim term ends.
Alternate: Vacant
(B) Manufacturer Segment (“MS”) – four voting members (3 + alternate
vacant)
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Primary: Roger Hunt, ATLINKS
Tel: 317-587-3095
E-mail: huntr@atlinks.com
Primary: Vacant
Alternate: Vacant
(C) Testing Laboratories Segment (“LAB”) – two voting members (full)
Primary: Mr. Scott Lambert, Intertek Testing Services NA Inc.
Tel:
Email: scott.lambert@intertek.com
Primary: Sharon Hoffman, Timco Engineering, INC.
Tel: 352-472-5500
Email: shoffman@timcoengr.com
Alternate: Christopher Brearley, Curtis-Straus, LLC
Tel:
Email: christopher.brearley@us.bureauveritas.com
(D) Other Interested Parties Segment (e.g., consumer groups and
associations representing individuals with disabilities) (“OIP”) – two voting
members (full).
Primary: Mr. Milton Bush, The M Companies
Tel: 703-533-9539
Email: themcos@aol.com
Primary: Mr. John Bipes, Mobile Engineering
Tel: 507-345-7169
Email: mobeng@hickorytech.net
Alternate: Vacant
ATIS Liaison to the ACTA:
Jean-Paul Emard
JPEmard@atis.org
202-434-8824
ACTA Manager for Database Maintenance and Support:
Mark Cassarino
Mark Cassarino <mcassarino@atis.org>
ACTA Secretariat:
Paul Anderson
panderson@atis.org
202-662-8654
ACTA Online Filing Administrator:
Meisha Goodhue
mgoodhue@atis.org
202-434-8859
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The next General Meeting for the ACTA is:
Thursday, 12th June, 2008: Virtual Meeting. We encourage any/all to dial
in and join the teleconference!
The remaining 2008 Meeting Schedule of the ACTA is:
12th June
– Virtual
September – Face-to-Face (Perhaps in combination w.
an ACTA Educational Seminar w. the release of TSB31-C and TIA968-B)
4th
11th December – Virtual
General Meetings of the Council are open to the public. Contributions to the meetings may be
made by any person or organization by the procedure described in the ACTA Operating
Principles and Procedures. Contributions should be submitted through the Contribution Template
available for download at the ACTA website and transmitted by electronic mail to the ACTA
Secretariat at acta@atis.org.
Unless otherwise announced, Face-to-Face meetings take place at the ATIS Conference Center
in Washington, DC, but will be simultaneously hosted by virtual meeting. Those wishing to attend
these meetings in-person are asked to RSVP to the ACTA Secretariat prior to the meeting date.
Information on in-person meeting attendance can be found on the ATIS website at
http://www.atis.org/directions.shtml. Information for attending the virtual meetings will be
announced prior to each meeting date by the ACTA email exploder lists.
Questions and comments about this notice should be submitted to the ACTA Secretariat via email
at acta@atis.org, or by phone at +1.202.628.6380.
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