5. PROPOSED PTC 100 AMENDMENT TO COVER NEW REQUIREMENTS
From time to time, new products submitted for Telepermit raise issues which have not been
addressed in our PTC Specifications. This is not surprising when it is considered how
quickly new technologies and features are being developed. Our approach to date has been
to discuss the issues in-house and with the supplier concerned to determine some provisional
connection requirements with minimal delay. This approach allows us to avoid restricting
access to market for a product simply because our specifications do not cover it.
Another related issue is where some aspect of a product's performance is regarded as
unsuitable from either the network or the customer's viewpoint, but there is no specific
PTC clause to define how the matter should be dealt with. Again, we raise our concerns
with the supplier and discuss the issues in-house. Often, such problems can be covered
by a product modification or by some sort of special condition applied to the Telepermit grant.
One approach is a suitable explanatory note in the User Instructions for the product concerned.
However, many customers do not read the User Instructions and most seem to lose them soon
after the product has been purchased, so this is not an assured solution.
Sometimes conditions are marginal - not quite bad enough to decline a Telepermit, but not
really such that the product would be viewed as "satisfactory" by a customer. We are
concerned that customers do not get the impression that any such perceived shortfalls
in product performance are due to network faults. Also, some product shortfalls impact
more on the other party to a call than to the user of the product. Our consumer protection
legislation requires that a product is fit for its intended purpose and, where a product's
performance has some specific shortfall, which the "average customer" would consider
unsatisfactory, it is only reasonable that the supplier describes the condition and
explains that this is not due to the Telecom network.
Clause 10.4 of PTC 100, "Telecom Telepermit General Conditions, provides for Telecom to take action where a product "is found to be causing service disruption to a customer" or "where service experience reveals that the network is being disrupted or adversely affected". Otherwise, the requirements for product modifications in PTC 100 apply only where that product does not meet Telecom specifications. If the specifications do not cover a particular feature or parameter, there are no firm legal grounds for Telecom to require remedial action. So far, this has not proved to be a serious omission, as most suppliers are willing to take appropriate action if some shortfall or potential service problem is pointed out to them, especially if it impacts on their product. However, there are exceptions.
To formalise what has been fairly common practice over the past several years, it is now proposed that PTC 100 be amended to better provide for the above situations, as follows:-
"3.4 Matters not defined in Specifications
(1) Where a product submitted for a PTC introduces some feature or performance aspect not directly addressed in the PTC Specifications, such as a new technology or a feature not previously encountered in the class of product concerned, Telecom reserves the right to set appropriate conditions to cover the matter in question. Until such time as the relevant PTC specification requirements have been finalised, such conditions will be applied not only in relation to the product concerned, but also in relation to any subsequent products exhibiting similar features. Such conditions may take any or all of the following forms:-
(a) provisional PTC requirements;
(b) special conditions in relation to any PTC granted to the product concerned;
(2) Any such provisional PTC requirements will be published in the Access Standards
Newsletter with the joint purpose of notifying the industry as a whole and gaining industry
comment on those requirements.
(3) Where a feature or performance aspect is likely to become common to other products,
such provisional PTC requirements or special conditions will generally be developed further
with the aim of incorporating them into formal PTC Specifications. In such instances, unless
the provisional requirements have resulted in service problems, a PTC holder operating under
the provisional conditions may either continue to operate under those conditions or apply the
published requirements, whichever are considered less onerous or more favourable to that
supplier's product.
(4) Where a proposed amendment to a PTC Specification has been outlined in the Access
Standards Newsletter and industry comment has already been invited, Telecom will not be
obligated to publish a further draft amendment prior to its formal incorporation into PTC
requirements".
While it does not represent any significant departure from our established practices, the
above is proposed as a formal change in our PTC specifications in line with (4) above. In
view of our undertaking to offer proposed changes for public comment, I would be interested
in receiving comments from CPE suppliers on the above amendment. Those readers who do not
have a current copy of PTC 100 to refer to may download a copy from our internet site.
6. FINALISATION OF PTC 222: RESIDENTIAL-TYPE TELECOMMUNICATIONS CABLE
PTC 222 was issued in draft form in 1997 seeking industry comment. To date, we have received several applications for 2-pair and 4-pair cable, based around the AS/NZS 3080 requirements for these classes of cable, but no applications for 3-pair cable. We now propose finalising the specification, but with a few changes.
a. We will require solid (not foamed) polyolefin insulation. While foam insulation may be able to meet the technical requirements, we are concerned at the possibility of water ingress and transport through this type of insulation;
b. We now intend to drop the various 3-pair cable options. Telepermits will be granted only for 2-pair and 4-pair cable;
c. We are elaborating on the test information to be supplied with any applications, to ensure that the physical properties of the cable are also specified by the applicant.
d. We now have a strong preference for striping or marking the white wire of each pair with the colour of the other wire of the pair. This will help maintain pair integrity should the customer or installer untwist the pair completely.
I would be interested to learn of any further comments from suppliers and cable manufacturers.
7. TELEPERMIT GRANTS DURING 1998
The final tally for last year was 636, making a grand total of 4931 Telepermits issued since
we started in October 1987. Neither figure includes Limited Permits. This implies that the
5000th Telepermit is likely to be issued during the February - March period.
DOUG BURRUS
Manager, Access Standards
