Purpose of Telepermits

1. Legal aspects

Section 6 of the Telecommunications Act 1987 states that "No person shall, without the agreement of the network operator, connect any additional line, apparatus or equipment to any part of a network owned by that operator." It also states that it is an offence to "aid or abet" such a connection.

Telecom provides agreement for connection by Access Standards granting a "Telepermit" to any supplier who submits satisfactory evidence that the product concerned 'matches' the Telecom network. Thus, the supplier enters into a contract with Telecom and agrees to satisfy Telecom's requirements. In turn, Telecom grants permission for the product to be labelled as suitable for connection to its network. This label includes the "Telepermit" name and logo which are registered as Telecom Trade Marks.

When a customer applies for service, a contract is established with Telecom whereby the customer agrees to connect only Telepermitted equipment to their lines. The customer is liable for any damage or service problems caused by the connection of non-Telepermitted equipment and may even be called upon to pay for the costs incurred by Telecom in determining the cause of such problems.

Under New Zealand customer protection legislation, any goods supplied are expected to be suitable for the customer's intended purpose. A sale is, in Law, a contract between the supplier and the customer. Thus, any supplier advertising or selling equipment which is not Telepermitted, but is clearly intended or offered for connection to the Telecom network, is likely to be in breach of the Fair Trading Act 1986, the Consumer Guarantees Act 1993, or the Sale of Goods Act 1908. Under this consumer protection legislation, a customer may have grounds for a claim against the supplier for reimbursement of the cost of the product, and also for any charges levied by Telecom.

These three inter-related contracts help ensure that Telecom's network, together with the equipment connected to it, performs effectively and meets customers' expectations.

2. Label Format
This is what a Telepermit usually looks like, although the size will vary with the room available on the product concerned:-

A separate Telepermit number and label is issued for each product and for each party holding a Telepermit for the same product. The product name is clearly shown so that a purchaser can see that the label details match up with the name on the product. This helps stop fraudulent use of these labels.

3. Status of Telepermitted products

A Telepermit indicates that a product may be connected to the Telecom network. The Telepermit is not a measure of the quality of any individual item of equipment, nor does it imply any warranty or endorsement of that product by Telecom.

Product quality, its suitability for purpose and warranty provision are matters to be settled between the buyer and the seller of the item concerned.

4. Why Telepermits are needed

In a competitive environment each network operator needs to protect the service quality of its network. The equipment connected and used by customers is a vital part of the overall system. The Telepermit label shows customers that equipment "fits" the Telecom network and that it may be connected under the terms of their service contract with Telecom. Network requirements can be very subtle. For example, a telephone may appear to work well from the user's viewpoint, but it may cause speech to be faint or distorted at the other end of a call. To perform correctly, a telephone or any other terminal equipment must fit the network it is connected to.

The Telepermit system is an essential part of Telecom's undertaking to other network operators and overseas administrations that we will ensure that overall network and terminal equipment transmission quality and signal levels are maintained within accepted international standards.

Formal Telepermit testing also ensures that a design meets appropriate standards for :-

(a) Transmission performance
Failure to meet these requirements can lead to distortion, echo, crosstalk (such as picking up parts of other conversations), noise or unsatisfactory levels. The result may be high error rates in modems and fax machines or difficulties in understanding speech in telephone conversations (too loud, too soft, or distorted speech, presence of echo etc).

(b) Signalling parameters
Failure to meet these requirements may lead to wrong numbers being called, inability to detect or answer incoming calls, or initiate outgoing calls.

(c) Avoiding nuisance to other customers
Incorrect calling and answering procedures lead to inconvenience and annoyance to other customers.

(d) Electrical Safety
Basic electrical safety to both the user and to Telecom staff working on the network. This is especially necessary where equipment is powered externally from the 230V mains supply. There is also the need to ensure that there is adequate protection from hazardous voltages appearing on a Telecom line caused by lightning or power faults. These voltages frequently extend for long distances from the point of breakdown or contact and can also be hazardous to both the user and Telecom staff.

These are important issues for ALL telecommunications users. Calls always involve at least two users. It only needs one of them to have unsuitable equipment for a call to be affected. Users may not notice any problems that their equipment causes other people. Everyone needs to use properly designed terminal equipment if problems are to be kept to a minimum. Telecom considers that everyone has the right to expect a good standard of communication, especially the person who is paying for the call!

PTC and TNA Specifications (see Appendix 2 for complete list)

PTC Specifications, derived from the term "Permit To Connect", describe the important characteristics necessary for compatibility of terminal equipment with Telecom's networks. The information provided is particularly useful to an overseas manufacturer who needs to know how to design or modify a product to suit the Telecom network (see the 'Telepermit Category & Specification Guide' on page 12 ).

TNA Specifications, derived from the term "Telecom Network Advisory", describe various background aspects of the Telecom network. Many do not directly relate to the granting of Telepermits, but provide design and other information of assistance to suppliers of equipment for the Telecom network.

Telepermit Ownership

Telepermit holders must be subject to New Zealand law. As a result, overseas suppliers need to appoint a New Zealand resident as their local agent or representative.

The Telepermit Application Form (copy attached) calls for the party owning the test results to be named if it is not obvious whether these are owned by the applicant. Such test results will not be applied to another party's application without the formal agreement of that owner. Given this agreement, any number of parties nominated by the owner may hold Telepermits for the same product based on the same test results, and each can then act independently.

This is particularly helpful to an overseas supplier who is concerned about giving up any rights to ownership of test results and does not wish for them to be transferred to their agent (the Telepermit holder). Should difficulties arise later between the supplier and the agent, the supplier then has the option of applying for a fresh Telepermit for a new agent based on the original test results.

The transfer of Telepermit ownership to another party is permissible at any time on condition that both parties are agreeable to the transfer. A "Transfer of Telepermit Ownership" application form is available from Access Standards and agreement of all parties involved must be indicated on the form.

Testing Laboratories

1. Relationships between Telecom, the Testing Laboratory and the Applicant.

Testing laboratories have a direct contractual relationship with their clients and Access Standards does not have automatic access to their test reports, even including those from laboratories which are operated by Telecom. Although Access Standards needs to receive test results in order to assess the degree of compliance, they are only provided with the agreement of the applicant. Normally, the applicant receives the results from the testing laboratory and submits them to Access Standards as part of the Telepermit application.

If it appears that design modifications are necessary to a product to achieve Telepermit compliance, Access Standards cannot be involved in any discussion on detailed solutions. Telecommunications consultancy services are available in the local market, and some of the testing laboratories are prepared to assist in this area. The selection of consultants is the responsibility of the applicant.

Access Standards is also careful to maintain confidentiality of all information obtained during Telepermit processing. We will not disclose such information to any third party, even to other Telecom Companies or branches, without the specific permission of the owner of that information. The possibility of breaching this undertaking is one reason for not entering into any design consultancy arrangements.

2. Laboratory Accreditation
A list of Telecom accredited or recognised laboratories is included in this Overview (see pages 6-8). A separate publication covers the conditions applicable for accreditation by Telecom as a Telepermit testing laboratory. This publication can be obtained on request from Access Standards.

Test Reports to Overseas Specifications

1. Australia

There is on-going interaction between Access Standards and the Australian Communications Authority (ACA). The joint aim is the achievement of as high a degree as possible of harmonisation of network interface standards. There are however some distinctive differences, particularly for analogue PSTN connections.

As a result of these differences, the only test reports to ACA Technical Specifications normally acceptable to Access Standards without qualification at present are those for safety against TS 001. TS 001 and Telecom's PTC 101 both refer to the joint standard AS/NZS 3260: 1993 (which is equivalent to the international standard IEC 950:1991).

Acceptance of test reports against other ACA specifications is on the same basis as for other administrations indicated below.

2. Other Administrations
The normal Access Standards requirements for Telepermit purposes consist of test reports to the appropriate PTC/TNA specifications. Apart from safety, test reports to the requirements of other administrations are normally insufficient for Telepermit applications.

In certain exceptional circumstances, some test reports to overseas requirements may be accepted. However, any areas where requirements differ in any way to those of Telecom will have to be tested by a Telecom accredited Laboratory. In all such cases, Access Standards reserves the right to make additional charges for the extra processing time involved.

For electrical safety testing, test reports to derivatives of IEC 950:1991 (e.g. EN 60950/EN 41003in U.K./Europe) from overseas laboratories are acceptable provided that the laboratory concerned is acceptable to the Energy Inspection Group, Operations and Risk Management, Ministry of Commerce, (see list in Electrical Code of Practice, NZECP 3, Appendix B). This generally includes all laboratories accredited by IANZ (or any other national accreditation body recognised by IANZ, such as NATA, NAMAS, HOKLAS, etc) for electrical safety testing.
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