 e-mail: doug.burrus@telecom.co.nz TELECOM ACCESS STANDARDS NEWSLETTER NO. 104 CONTENTS TELECOM TELEPERMIT: CONTRACTUAL RELATIONSHIPSREPAIR OF NON-TELEPERMITTED EQUIPMENT NETWORK CHANGES IMPACTING IN-SERVICE CPE DIGITAL PAIR GAIN AND OTHER "DERIVED LINE" SYSTEM INTERFACES DPGS INCOMPATIBILITY WITH 2-WIRE BOTHWAY DDI SIGNALLING MOBILE NETWORK INCOMPATIBILITY WITH SOME EARLY ANALOGUE PHONES L1 SERVICE WITHDRAWAL FREQUENCIES FOR DIGITAL CORDLESS TELECOMMUNICATIONS MINISTRY OF COMMERCE AUCKLAND TEST LABORATORY CLOSURE TEST LABORATORY NAME AND ADDRESS CHANGES USE OF TELEPERMIT LOGO IN PRODUCT ADVERTISING return to index TELECOM TELEPERMIT: CONTRACTUAL RELATIONSHIPS Although telecommunications in New Zealand has been deregulated since 1987, we still get numerous enquiries, mainly from "new entrants" to the market, as to what the Telepermit system is all about. In view of this, readers may be interested in the following brief outline of the way the system ties in with Telecom's contracts and such legislation as the Fair Trading and Consumer Guarantees Acts. Each network operator in New Zealand is entitled, under Section 6 of the Telecommunications Act, to set conditions for the connection of terminal equipment to its network. Telecom New Zealand Ltd ("Telecom"), which owns and operates the main public telecommunications networks, has established its "Telepermit" system, under which Telecom sets and publishes technical requirements for terminal equipment. Products which are shown to comply with Telecom's specifications are granted the right to bear a "Telepermit" label. This clearly indicates to Telecom's customers that a product may be connected to the Telecom network. In legal terms, three sets of inter-related contracts exist:-
To support these contractual relationships, Telecom publishes full details of its network compatibility requirements via its PTC and TNA specifications and Newsletters. This information is provided so that equipment suppliers can design their products to meet their obligations to Telecom and their customers. Under New Zealand law, the supplier is responsible for product offered for sale, not Telecom. A Telepermit only indicates that Telecom agrees to the connection of the equipment to its network. It is NOT an endorsement of the product or any form of warranty. As a network operator, Telecom's primary concern is that products are compatible with its network. It is also important that they work properly and do not degrade the standard of service offered by the Telecom network. Telecom's aim is to avoid problems at the manufacturing and design stages. This minimises the risk of having to overcome operational problems after a product has been released to the local market, a process that is more costly and troublesome to the suppliers, the retailers, and their customers. This aim is shared by the majority of equipment suppliers, whose good reputations are very dependent on customers experiencing reliable service and performance that matches the claims made for a product. One of the conditions of granting a Telepermit is that suppliers are to ensure that each product offered for sale for connection to the Telecom network bears a "green tick" Telepermit label, which is not easily removed. Thus, if a product does NOT have such a label, the customer should assume that the product does not have a Telepermit. Modems and other analogue line interfaces are included in this rule. PC's and other computer hardware connected on the customer's side of a Telepermitted network interface are generally not subject to Telepermit requirements. However, Telepermit is required for PC cards or peripherals which determine signal levels, voice quality, etc, as perceived by other users of the network. This applies even when such devices are connected behind other Telepermitted devices. REPAIR OF NON-TELEPERMITTED EQUIPMENT Should a service company repair or attempt to modify any non-Telepermitted equipment which is subject to Telepermit requirements, that company is effectively "aiding and abetting a breach of Section 6 of the Telecommunications Act". A typical situation is that a customer purchases terminal equipment overseas (telephones, cordless telephones, modems, fax machines, etc), then suffers difficulties and seeks support from a local agent. There is no evidence that the overseas product is fully compatible with the Telecom network and, in many respects is unlikely to meet Telecom's requirements. This is especially important with respect to compliance with the New Zealand Electricity Regulations. Despite the many design variations for different countries, overseas products often have the same brand and model numbers as those sold in New Zealand. This allows the manufacturer to have one set of brochures world-wide. However, the local New Zealand agent usually has no service data available for the overseas product and is unlikely to have all the exact spare parts. As a result, the local agents can give no assurance that the product will comply with Telepermit requirements after attempted repairs. Even if it does appear to function correctly, they certainly cannot meet their legal obligations to Telecom with respect to network compliance. In view of the above, service companies are advised to decline to handle such products. NETWORK CHANGES IMPACTING IN-SERVICE CPE The Telepermit system has been in operation since 1987 and some of the first Telepermits were granted to "grandfathered" Post Office products from the early 1980's which were still being supplied when CPE deregulation took place. We also "converted" a number of the old "Type Approvals" to Telepermits where the products concerned were expected to continue to be produced. As a result, the earliest Telepermitted products may be to designs that are close to 20 years old. Many of these items have since been withdrawn from service, but there are still many in use and some companies continue to refurbish them and offer them on the second-hand market. Needless to say, the vast changes in technology since the early 1980's have impacted on the suitability of the earlier products to support new services and maintain full compatibility with later network systems. Over this period, the switching network has moved from a high proportion of electro-mechanical exchanges to 100% digital. Similarly, not only have our backbone transmission network and inter-exchange junction network gone to full digital operation, but our local customer network reticulation practices have also moved rapidly from copper cable to various digital systems. While the existing copper is used as the "bearer", the actual services provided are often digitally based. These changes are now having more and more impact on the earlier types of CPE. For example, some earlier PABX systems monitored the 50 V exchange battery on an idle line to determine whether the line was available for use. New digital systems often use open circuit voltages around 35 V - 40 V, leading to these PABX's "rejecting" the exchange lines concerned. Another growing problem is that these digital systems cannot support some of the earlier signalling protocols, as explained in item 5 below. Specification PTC 100 explained that Telecom would need to make network changes from time to time and that these changes could impact on CPE operation. Similarly, our customer contracts warn that Telepermitted equipment may not always remain compatible with the network. Needless to say, Telecom cannot ensure "compatibility in perpetuity" and some customers may face situations where their equipment will need to be modified or withdrawn from service. The following items outline some specific examples. DIGITAL PAIR GAIN AND OTHER "DERIVED LINE" SYSTEM INTERFACES Like any other network operator, Telecom now has to buy its equipment on the world market and accept that the equipment purchased will not always present network interfaces identical to those of our NEAX exchanges. In effect, we can only buy what is available as most manufacturers are quite reluctant to modify their equipment to meet the "special requirements" of a relatively small network operator like Telecom. We now endeavour to align our network equipment purchasing with one or other of the world's major markets, such as the USA or Europe. By buying to established specifications, we not only have a greater choice of product, but also have a much better chance of buying network components that fit properly together. Our Digital Pair Gain Systems (DPGS), such as 30-channel PCM systems and "0+2" systems, are examples of this shift in design emphasis, in that they have interfaces slightly different to those of our NEAX 61 exchanges. I mentioned the different line voltage above, but there are also slight differences in their signalling protocols, ringing characteristics, etc. A wide range of factors govern our local reticulation requirements. The high population growth in some areas, combined with the increased emphasis on telecommunications and the rise of the internet have led to the demand for more and more exchange lines. Customers demand and expect rapid provision of their needs and this requires greater flexibility on the part of the network operator. DPGS are the preferred solution in these cases, as they allow rapid implementation, when and where needed, even by one line at a time, if necessary. We use the installed cables as the bearers for DPGS and, as a result, there is less cable available for traditional uses such as direct current signalling leased circuits (see "L1" service withdrawal, in item 6 below). Because of this stage by stage implementation of DPGS, sometimes at short notice, we are not easily able to advise customers exactly when their existing copper circuits may be replaced by some form of digital access. On the other hand, we can clearly warn CPE suppliers, especially those dealing with second-hand items, that progressive network changes are likely to impact on their equipment in the future. Those suppliers are advised to warn their prospective customers of this possibility, especially where the product concerned was Telepermitted more than 5 years ago. DPGS INCOMPATIBILITY WITH 2-WIRE BOTHWAY DDI SIGNALLING As explained above, the DPGS systems we are now purchasing do not present the same network interface as our NEAX 61 exchanges. One area of difference is the lack of support for 2-wire bothway operation of our Direct Dialling In (DDI) service. Bothway and unidirectional DDI is still supported by these digital systems, but only where the interface with the PABX, voice mail, paging system, etc, is digital. The 2-wire analogue interfaces required by some of these earlier systems are now only provided by modern transmission systems on a unidirectional line basis. We have so far used the smaller DPGS systems mainly for residential customers, who do not usually have PABX systems. However, there are always exceptions to the general rule and cases will arise where a residential customer does have a small PABX system or where DPGS is used for business customers. Where bothway DDI is in operation or the PABX is one of those that "expects" 50 V line feeds, it will be necessary for the customer to consider whether to modify or replace the PABX, or convert to unidirectional trunks. While it limits Telecom's ability to move as quickly as we would wish, we will endeavour to give adequate notice of any network changes impacting on the customer. Suppliers are invited to comment on Telecom's likely progressive withdrawal of 2-wire bothway DDI operation as the local network is converted to digital transmission, especially as regards the expected impact on existing customers. Since it is fairly certain that we will have to withdraw this particular service feature within, say, 5 years, it is recommended that new equipment designs do not provide this capability. This will help to reduce the incidence of problems arising with relatively new equipment. MOBILE NETWORK INCOMPATIBILITY WITH SOME EARLY ANALOGUE PHONES This question of the ongoing network compatibility of earlier CPE also impacts on our mobile network. During the introduction by Telecom's mobile network of its digital "Short Messaging Service" (SMS) in accordance with the IS 136 standard, it became apparent that some earlier analogue mobile phones would be "confused" by the digital control channel messages. This came about because the manufacturers concerned had applied some unused (but reserved) parts of the air interface protocol for their own purposes. As a result of pre-launch testing, which revealed these incompatibilities, Telecom increased the delay between successive control channel signals. This permitted the majority of these earlier mobile phones to "recover" from any confusion. Recent reports indicate that a very few early model analogue mobile phones are not only still being "confused", but that they fail completely after an initial period of correct operation. This situation is difficult to detect with test equipment because it is intermittent, may not occur for an hour of operation and, even then, seems to affect only some samples of the same model. The outcomes also vary in that some phones switch off and then cannot be switched on again unless the batteries are first removed. Others fail to respond to allocated voice channels. The models affected are up to 7 years old now and really beyond economic repair. Even the economics of battery replacement are doubtful, as they use heavy lead-acid batteries, which are now very expensive and hard to obtain. Since SMS was introduced, we have checked for these problems as part of our local Telepermit testing, so no recent or new phones are likely to be affected. However, the basic issue of potential non-compliance of earlier CPE with new services needs to be faced, as the network is obviously subject to ongoing development and problems are bound to arise from time to time. This situation is further complicated by the fact that nearly 250 different makes/models have been granted Telepermits since 1987. It would seem that the only practical approach is to accept that "compatibility in perpetuity is an impossibility". As a result, suppliers of second-hand mobile phones and any customers still using these earlier models need to accept that problems may arise such that replacement is the only real answer. "Obsolescence" has been accepted for computer equipment for many years, and it must also be accepted for telecommunications equipment in view of the wide range of new services and features now being developed. As a result of the network changes outlined above, we can no longer guarantee continued support for our "L1" leased services. These are based on the provision of copper pairs and are commonly used for alarm services using direct current signalling. We have been advising the alarm industry to go to voice frequency signalling for some years and most modern systems are based on this. As part of the "migration process" to new services, Telecom advised the industry in 1996 that L1 services would not be provided for new customers. Also, that additional L1 services would only be available to existing L1 users until April 1997. At that time, it was also announced that the service would be withdrawn from 1 April 1998. This situation has since been modified in view of the slower than intended progress towards new services and technologies. The current position is:-
Telecom is investigating other options which may be more appropriate for simple alarm systems. For example, Cellular Digital Packet Data (CDPD) may offer advantages in some cases. In the meantime, the alarm industry in particular is advised to be aware of these changes and to investigate their own options just in case we have to curtail an individual customer's L1 service at relatively short notice. FREQUENCIES FOR DIGITAL CORDLESS TELECOMMUNICATIONS The Ministry of Commerce recently announced the creation of a General Licence for the operation of "low tier" cordless telephones from 1 March 1998. This covers the use of Digital Enhanced Cordless Telecommunications (DECT) and Personal Handyphone System (PHS) telephones, using the frequency band 1881.5 - 1920 MHz. The lower end of the band may be extended down to 1880 MHz following a review later this year. The current limitation of the lower frequency is intended to reduce the risk of interference with existing services in channel M5#. One year long geographical restrictions will also apply in many areas to give existing fixed service licensees the opportunity to move to different frequency bands if they believe interference is possible. Operators of DECT and PHS within these initial exclusion zones will need to apply to the Ministry to operate their systems before the end of February 1999. As usual, radio Type Approval by the Ministry of Commerce applies to all DECT and PHS devices, in addition to Telepermit requirements for those systems connected to the Telecom network. For devices which are approved and Telepermitted, each user will not require a separate licence (other than for operation within the exclusion zones). This continues the arrangements currently used for any other cordless telephones which are classed as "level 1" ( "restricted radiation radio apparatus"). However, there are also some specific requirements:- DECT devices are required to comply with European Technical Standard ETS 300 176 and maximum permitted power output is 250 mW peak within the band 1881.5 - 1900 MHz. Services permitted initially are "wireless PBX" and "wireless local loop", but NOT home cordless or public access systems. PHS devices are required to comply with ARIB Standard RCR STD-28 Version 2 and maximum permitted power output is 160 mW peak within the band 1895 - 1920 MHz. Services permitted initially are "wireless PBX" and "wireless local loop" and home cordless, but NOT public access systems. Because initial restriction zones for the use of DECT are numerous and widespread, for more information relating to the General Licence suppliers of DECT and PHS are advised to check out the Ministry of Commerce website "www.moc.govt.nz". Otherwise, they can contact Dave Kershaw at the Ministry of Commerce for further details of the co-ordination zones. Dave can be contacted by telephone on (04) 474 2186, by fax on (04) 499 0797. Type Approval matters should be raised with Andrew Dyke, who can be contacted by telephone on (04) 474 2640, by fax on (04) 473 2489, or by Email to "andrew.dyke@moc.govt.nz" The above conditions will be published in the next amendment to PTC 200. In the meantime, any prospective suppliers of these classes of equipment need to be aware that special conditions have been set by the Ministry of Commerce. MINISTRY OF COMMERCE AUCKLAND TEST LABORATORY CLOSURE The Ministry of Commerce has announced that its Auckland RFI (EMC) test laboratory will be closing on 31 March. It is hoped that the laboratory will move to private ownership at some time in the future and that low power radio device testing operations will be resumed. Until this occurs, the nearest comprehensive RFI testing services to New Zealand are the Australian Communications Authority laboratory in Melbourne and AUSTEST in Sydney. TEST LABORATORY NAME AND ADDRESS CHANGES Detecon Inc, one of our accredited test laboratories listed in the "Telepermit Overview", has advised that they are now a subsidiary of TUV Rheinland of North America. As a result, they are now operating under the name "TUV Telecom Services, Inc". The address and contact details and the range of testing carried out, as published in the current "Telepermit Overview", are otherwise unchanged. Certelecom Laboratories Inc have advised that they are relocating from Ogdensburg, New York, to Lewisville, Texas on 31 March. Their new address and contact numbers are as follows:- 802 N.KealyLewisville Texas 75057 USA Telephone +1 972 436 9600 This laboratory is now also offering a test service to AS/NZS 3548 (RFI testing to Ministry of commerce requirements). The range of testing carried out, as published in the current "Telepermit Overview", are otherwise unchanged. Certelecom Laboratories Inc also have a branch office in Canada, which can carry out the same range of Telepermit testing. Address details are as follows:- 3325 River RoadR.R. No. 5 Ottawa Ontario Canada Telephone +1 613 737 9680 USE OF TELEPERMIT LOGO IN PRODUCT ADVERTISING A reminder to suppliers that the Telepermit name and logo are Telecom copyright. In granting a Telepermit for a product, we permit and encourage the Telepermit holder and authorised agents of the Telepermit holder to use the Telepermit name and logo in any promotions of that particular product. However, to use the name and logo to advertise non-Telepermitted products is a breach of the Copyright Act. It is also misleading under the terms of New Zealand consumer protection legislation. I have recently seen advertisements, usually covering several different products, in which the Telepermit logo is placed such that it implies all of the products shown hold Telepermits. While this may not be intentional, advertisers are asked to ensure that their copy is not misleading in this respect. Another issue is claiming that a product has Telepermit before a Telepermit has been granted - sometimes even before the application has been submitted. This again, could be deemed to be misleading practice. DOUG BURRUS Manager, Access Standards |