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THE TRADE WAR AND TELECOM
The Battle to Open World Markets to the Provision of
Customer Installed Telecom Apparatus Is Being Waged
at the Highest Levels at Home and Abroad.
Telecom is a battle front in the great trade war. Locked
in technological and political combat are the governments,
bureaucracies and telecom industries of most of the in
dustrialized world. At stake is an annual market estimated
at 100 billion dollars.
An open market for any commodity is rare. But telecom
became the Reagan Administration's watershed, in part
because it exemplifies the worst in trade barriers. In the
name of universal service, governments around the world
divided telecom into local monopolies, in the United States
the monopoly belonged to AT&T, in Germany IDBP, and in
Japan NTT. No matter what initials it went by, the rules of
the game were clear. All service and equipment was theirs
to make, lease and service. Now, say the freetraders, times
have changed and the monopolies are no longer needed.
This article focuses on opening world markets to the sale
of "customer premise equipment" or CPE. These are
devices, from telephones to PBX's, which can attach to the
telephone network. Trade battles in telecom are fought on
other fronts as well, for example the provision of long
distance services such as MCI and Sprint, or even the tradi
tional monopoly of the local operating company. But the
battle for the right to attach customer premise equipment
and its corollary, the right to sell and profit from it, is cen
tral to the telecom trade wars.
A Problem in Depth
Originally, a monopoly over telecom was thought to be
needed primarily for two reasons. First, expansion to rural
areas could not be achieved if rural customers had to pay
for the cost of long lines. "Universal service'' was, there
fore, one goal. Second, making telecom a competitive
market would increase the number of lines and create
economic waste; hence the notion of a "natural
monopoly." But by the l960's and 70's, it was generally
conceded that universal service had been achieved, and
technology laid waste to the natural monopoly argument.
Nonetheless, some still argue for continued monopoly,
especially foreign governments, idealism alone is not
behind the crusade. Money, symbolized by a 150 billion
dollar trade deficit, is. It's that deficit, still growing despite
a weakening dollar, that has Congress's attention, opening
markets, particularly telecom, is the cure.
In the US
To be sure, it's not completely fair to blame the rest of
the world for having closed off its telecom market for so
long. After ali, for the bulk of its existence, the US telecom
market was and solely in the hands of AT&T.
In order to serve a territory as large as the United States,
the telephone network naturally breaks down into three
constituent parts. Each area is served by a local bank of
switches known as the "central office" or "local
exchange.'' These serve to interconnect local customers
with communications between local exchanges being
handled by long lines. Today, the primary mode of long
line communication is via satellite.
In most countries, and in the US until recently, the
monopoly servicing the long distance transmission and
local exchange is the same. That monopoly may also have
the right to build and supply "customer premise equip
ment."It can build that equipment itself, as was the case in
the United States through the relationship between AT&T
and Western Electric, or purchase it from others, as the
Deutsche Bundespost in West Germany does primarily with
Siemens. Nonetheless, the provision of customer premise
equipment, local exchange and long distance traffic in the
United States was all AT&T's concern until 1956.
It was in that year that the monopoly began to break
down. In the Hush-a-Phone and later the Carterphone
case, companies began to earn the right to attach other-
than-Bell equipment to the telephone network. Originally,
what was required was an interface known as a DAA which
would protect the network from harm potentially caused bythe non-Bell equipment. Finally, in 1976, the FCC pro
mulgated rules in Part 68 which prescribed certain tests
which have to be performed on all customer premise equip
ment. If the tests are passed successfully, upon a grant of
FCC registration the device can be hooked to the telephone
network without the need for a DAA. From 1976 on, the
000A'
FIGURE I
How the network is structured. Each telephone subscriber has his
"customer premise equipment" CPU connected to the localtelephone company central office, a part of the "Bell OperatingCompanies" BOC. The BOC switches local traffic. Longdistance is handled by "other common carriers" 0CC such asMCI, AT&T and Sprint, in the US, "CPE" and "0CC"businesses are competitive. BOCs are still Bell monopolies.
SATELITE
00
215
FCC widened its rules to cover more types of equipment
until today, practically any type of equipment from coin
phone to digital PBX can be bought from a non-AT&T
source and attached to the network. In fact, after
divestiture, AT&T was treated no differently from any
other telephone equipment manufacturer, and had to
register its new equipment as well,
Similarly, on the long distance side of the equation, com
petition prevailed. Companies such as MCI and Sprint
earned the right to have equal access to the local operating
company's long distance lines, and, at the customer's re
quest, provide long distance service. Competition then was
nearly complete, with two of the three major portions mak
ing up the network affected. Only the local operating com
pany, by virtue of the vast number of lines hard wired into
the local geographic area, escaped divestiture and competi
tion, still a oatural monopoly. Even this last vestige of the
old Bell network, however, is under scrutiny.
At best, it can be claimed that other countries simply lag
behind the United States in opening up both customer
premise equipment and long distance service to the com
petition. At worst, it can be said they don't want it to be so.
In any event, prying open those markets yields potential for
trade war, with the focus primarily on Japan and the
Federal Republic of Germany.
Japan
As the deficit deepened, its leading component, trade
with Japan came into focus. Polite overtones to the
Japanese to drop trade barriers especially in telecom met
with polite responses, but no more, Progress was virtually
nil. The frustrations felt by US negotiators show up in
metaphor. One negotiator said that the Japanese rules are
"like peeling an artichoke. First we have Ordinances
then behind them are Ministerial Guidelines, now
we've discovered a whole other layer, Ministerial Direc
tives." Another likened them to landmines: "You never
know when one of them is going to pop up." All is seen
widely as a subtle attempt to block off foreign imports,
subsidize industry in its infancy, and build capacity and ex
port in a cut-throat fashion. Theodore White summed up
the US mood as it turned from frustration to anger. Said
White, "Today, 40 years after the end of World War II, the
Japanese are on the move again in one of history's most
brilliant commercial offensives, as they go about dismantl
ing American industry. Whether they are still only smart,
or have finally learned to be wiser than we, will be tested in
the next ten years. Only then will we know who finally won
the war."
On April 3, 1985, in rare unanimity, the Senate voted
92-0 for a resolution condemning Japanese trade practices.
Soon after the House Finance Committee pushed for-
BILLIONS
160
100
ward retaliatory trade legislation by a 12-4 vote, Tip O'Neill
D-Massachusetts stating, "They'd better make some con
cessions or they've got trouble." Bills introduced by Con
gressman Worth and Florio, as well as those by Matsui
Gregg, moved quickly to the House of Representatives,
ushered through by the efforts of Speaker O'Neill. Finally,
in May 1986, the House passed by a vote of 295-115 an Om
nibus Trade Bill, laying out the steps which would be taken
to retaliate. The bill included the following:
Retaliation. The President would be required to
retaliate where there is "excessive'' trade surplus
garnered through unfair trade practices if the trading
partner failed to agree on a 10¾ annual reduction.
Telecommunications. The US Trade Representative
would investigate the foreign markets for telecom
munications. Those that were not open to the US
manufacturers would be identified. If successful
negotiations are not completed in 18 months, the
President must take retaliatory action.
The Japanese appeared to be genuinely stunned by the
moves. It announced a number of reforms, including the
lowering or eliminating of many tariffs, reforming its elec
trical safety code to include most electronics devices in
"self certified" categories, and allowing U.S. engineers to
join Japanese standards making committees - Also among
those reforms was the reduction of technical standards for
telecom equipment from 30 to 21. Still some are skeptical,
predicting that the new reforms simply added a pleasant
veneer to still solid wall. Predicted Yoshio Terasawa, chair
man of the Nomura Securities International in New York,
"Even though NTT says, `Oh, we will open it' [telecom
market], and the standard looks generous, American
manufacturers will see bureaucrats stick their big nose in
with a lot of red tape . . . that'll make Americans more
frustrated in [the months that follow] and they will see it as
a dirty trick."
Whether the new Japanese telecom trade regulations lead
to an open telecom market is simply an unknown. Some say
they will not, that Terasawa's prediction will come true,
that reforms, fair on their face, will not yield open markets.
Others say that the Japanese reformed telecom rules are for
real, but not for the reasons America would like. Japanese
technology has simply caught up and there's no need to
keep the Americans out any longer.
West Germany
West Germany's market for customer premise equipment
is nearly as restrictive as Japan's, but the Germans have not
felt the wrath of US trade negotiators, possibly for two
reasons: First, the deficit with West Germany pales in com
parison with that of Japan's. Second, and more important
ly, there is the notion that West Germany's barrier may be
due more to its history than its predatory instincts -
In a way, the current situation in Germany is illustrative
of European telecom markets as a whole. The Postal,
Telegraph and Telephone PTT service has absolute con
trol over the equipment and services related to telephone
communications. The United Kingdom was the leader in
deregulation, but the rest of Europe has failed to follow.
The PiT in the Federal Republic of Germany is
Deutsche Bundespost DBP. It is an all powerful monopo
ly, wielding constitutionally based authority to run the
telecommunications network. Under guidelines, the
Federal Minister for Post and Telecommunications, Chris
tian Schwarz-Schilling, controls the DBP's philosophy, ac
ting pursuant to Germany's "Telecommunications Installa
tion Act." That act provides that telecommunications is a
140
120
Its
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216
state sovereign right. The state, in turn, must offer service
to the general public everywhere in the country on equal
conditions with equal charges and equal quality. In its ef
forts to fulfill the law, the Deutsche Bundespost has created
the most complex set of statutes and regulations over
telecommunications found anywhere in the world. Their
regulations are measured more conveniently in meters than
in pages. Unlike in the United States, Canada and Japan,
the regulations in West Germany require more than the in
terconnection be free from the potential for network harm,
Rather, pursuant to its view that quality service must be
provided by law, the German regulations also state in detail
performance characteristics, sometimes prescribing the ex
act design of an interface.
Equally troublesome to the volume and complexity of the
standards is the fact that they are derived in a closed en
vironment. The Germans do not allow foreigners to par
ticipate in their standards activities. In contrast, voluntary
standards groups in the United States, such as the IEEE,
routinely open their proceedings to all interested parties,
and rulemaking efforts by federal agencies are published
under constitutionally and legislatively guaranteed right to
notice and consent. But the German standards arise out of
complete secrecy, and, when completed, are not even sent
to the US Department of Commerce as required by the
General Agreement on Trade and Tariff.
The technical regulations are drafted by a branch of the
Deutsche Bundespost known as the FTZ, located in Darm
stadt, Germany. They are heavily influenced by major Ger
man manufacturers, principally Siemens. Equipment ap
proval itself is performed by the ZZF, located in Saar
brucken. All testing on equipment must be performed in
Germany, a notable advantage to German manufacturers,
and all appllcations must be processed through a German
agent. Completing an application and satisfying the ZZF
usually takes on the order of two years.
Needless to say, American manufacturers have found
this quite difficult. Even Nixdorf, a German based com
pany, found it took nine years to type approve a single
PBX. Still, fully 18¾ of the PBX market is not provided
by leased equipment from the Deutsche Bundespost. In
dividual equipment connection is permitted, though the
process is painful.
Even after licensing, vendors still must face a host of
rules. For one, the first telephone in any facility must be
leased from the DBP. Second, any vendor must be in a
position to service the equipment within 24 hours, requiring
a legal presence in Germany. Installers, like the equipment
they install, must be licensed by the Deutsche Bundespost,
and there is no effective appeal from denial of license by the
DBP.
The Department of Commerce and the US Trade
Representative's office have made known their dissatisfac
tion. Recently, Commerce Secretary Baldridge wrote to
PTT Minister Schwarz-Schilling, laying out his objections.
These objections, to be the subject of future bilateral
negotiations, were 1 the necessity for manufacturing
presence and for test results to be generated within Ger
many, 2 burdensome regulations which focused on more
than mere network harm, 3 lack of openness in the pro
cess of creating new regulations and violations of the
GATT agreement, and 4 unnecessary maintenance and in
stallation requirements.
Reform will undoubtedly come, but US pressure will
likely not be its impetus. Rather, the most likely path for
reform is via the directives of the European Communities
Common Market.
The Common Market was once envisioned as a "United
States of Europe" capable of confronting the economic
power of the United States and Japan. Ironically, the
mechanisms of the EC will almost certainly become the way
in which US and Japan enter a newly deregulated and
lucrative European market for telecommunications.
Directives adopted by the Common Market's Council of
Ministers are superior to the law of all 12 member states.
They must harmonize their laws with those of the EC Direc
tive or risk sanctions from other Common Market
members. Where these directives have been most effective
has been in the area of technical standards. For example,
the Low Voltage directive harmonized safety standards for
most electronic equipment 73/23/EEC. Those standards
once were the same jumbled morass that telecom standards
are today. But through that Directive, the standards of the
IEC arid the regional body CENELEC have become the na
tional standard of each Common Market member. Except
for minor variations allowed under the Treaty, manufac
turers in the United States can know what safety standards
they have to meet simply by reading the applicable
CENELEC or IEC document. The same result will soon be
obtained for technical standards related to telecom equip
ment as well.
To achieve this, the EC has enlisted the aid of the Con
ference of the European Post and Telecommunications Ad
ministrations CEPT, an organization consisting of 26
PPT members. It last year agreed on entering into efforts to
unify standards for customer premise equipment. Once the
CEPT agrees on standards, they will be referred through
the EC hierarchy to the Council of Ministers. A favorable
vote there will finally unify standards throughout Europe.
Such unification is expected within the next few years.
Turning to Technology
Countries like Japan, the United States, Canada, and the
United Kingdom have reached the point in a free market
evolution where technical standards are in place. To vary
ing degrees, the political intrigue has ended there, and the
need to master the technology impllcated in these complex
regulations begins.
CANADA
Specifications issued by the Telecommunications
Regulatory Service of the Department of Communications
are exhaustive, notable for their detailed description not
only of the parameters, but of the test methods. However,
among the standards of the four open markets, they are
generally considered to be both the most comprehensible
and comprehensive. Regulation CS-01 covers voice equip
ment, while CS-02 covers private line data. Most devices,
however, will fall under Issue 6 of CS-03 released on
January 25, 1986. Certification procedures themselves can
be found in a companion docket, CP-Ol, released on Oc
tober 7, 1985. Certain US based laboratories have been ap
proved by the DOC, speeding US access to Canadian
markets and expediting the applications process.
Signal Power
The Canadian specifications cover many more potential
sources of signals than do those of the FCC. Both AC and
DC signals presented to the network are regulated.
On hook, voltages greater than plus or minus 25 mY
should not be present on tip and ring or between either tip
and ring and ground. Off hook, the voltages to ground
should not exceed 0, nor be less than - .5 V DC.
Measurements for AC energy begin at 10 Hz. Over the
range from 10 to 100 Hz, on-hook signal power is limited to
218
-33 dBm. C message band power must be less than 17
dBrnC.
Off hook, signals must meet the levels in the figure
measured using the same apparatus as used for FCC tests.
In band, signals must be less than -9 dBm when averaged
over three seconds. Brief bursts not exceeding 250 msec.
can be as strong as + 3 dBrn. The band immediately around
4kHz is restricted, requiring signals no stronger than -29
dlini for voice and -20 dllm for data.
Canadian rules view the transmission characteristics of
live voice with much greater concern than the United
States. In the United States, a voice input, whether it be a
hands-free speaker phone or a conventional telephone, is
tested simply by applying enough signal at 1 kHz to pro
duce an output on the telephone lines of - 13 dBm. While
out-of-band components are measured, sensitivity of the
transmitter is not.
In Canada, more is required. In measuring the response
characteristics of telephones, methods employed in IEEE
269-1971 are used. A signal is produced by an "artificial
mouth," the signal source being "simulated speech" whose
characteristics are available from the DOC. In-band
transmission and out-of-band characteristics must meet
prescribed limits,
In the United States, no tests of dialing characteristics
DTMF or Dial Pulse [DP] are required other than a
general requirement that DTMF signals be less than 0 dBm.
Here, too, in Canada more is needed.
For pulse dialing, pressing a certain number has to pro
duce the correct number of digits. The minimum make in
terval is prescribed as 33 msec., with a break interval being
between 53 and 80 msec. Pulse rate can vary from 8 to 11
pulses per second. The break interval resistance must be
greater than 20 K.
The DTMF signals transmitted must conform to CCITT
specifications with a frequency tolerance of L5% see
figure. Rise time of the DTMF wave form to 90% must
be less than 5 msec.
Balance
The Canadians have rejected the FCC method of perfor
ming balance tests, opting instead for a method based on
IEEE 455-1976. The balance limits are somewhat stricter
than those prescribed by the FCC.
Impedance
The Canadian rules require tests for DC and AC im
pedances both on and off hook. On hook, measurements
are made not only of the impedance of the ringer, which
must be greater than 1400 ohms at 20 Hz, but of the audio
transmission circuitry as weli. Metallic impedance in this
range should exceed 16 K at 500 Hz and 5 K at 200 Hz.
Longitudinal impedances during simulated ringing must ex
ceed 14K ohm at 20Hz. As for DC parameters, the rules
require 2 megohms or greater DC resistance tip to ring and
from either tip or ring to earth ground. Voltages applied for
this DC test are up to 100 volts.
Off hook, a "return loss" test is applied. Return loss is a
measure of impedance match. Circuits which match im
pedances well will not reflect back signals, causing echo or,
in severe cases, oscillation known as "singing". Return
loss is a function of frequency and is measured a number of
ways. "Single Frequency Return Loss" applies sinusoidal
signals 500-2500 Hz. The amount of reflected signal is
measured and compared to the drive signal. Usually the
worst case return loss is specified. For "Echo Return
Loss," Single Frequency Return Loss figures are averaged
over a prescribed frequency range.
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FIGURES
219
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Off book, the Telco terminal characteristics must fill in the al
lowS region for Canadian approval.
Mathematically, Single Frequency Return Loss equals:
Return loss Z0 + ZL
Z0 -
where
= impedance of the line usually specified as 600
ohms or 600 ohms in series with 2.16 4= impedance of the device under test
In Canada, Echo Return Loss must be greater than 11 dB
from 500 Hz to 2500 Hz measured against 600 ohms in
series with 2.16 jif. Over the wider band from 200 to 3500
Hz, Single Frequency Return Loss must be greater than 3
dB.
Billing Protection
In the United States, proper billing is assured by requir
ing that the amount of current drawn when going off hook
either exceeds that from a 200 ohm resistor or the current
wave form has less than 25Wo overshoot, hi Canada, the
rules attempt to achieve the same objective by requiring
that the amount of current drawn off hook fall within the
allowable region shown in the figure. In addition, equip
ment which automatically goes off hook cannot be allowed
to return to the on-hook state in less than 5 seconds.
As in the US, energy in the band from 800 to 2450 Hz
must be greater than energy in the band from 2450 to 2750
Hz.
Environmental
Canadian specifications dispense with temperature,
humidity and vibration cycles. Simulated lightning strikes
are required, and can use the same test methods prescribed
by the FCC. Leakage and hazardous voltage tests are ab
sent from the Canadian rules, although the rules require
either CSA certification or proof of compliance with the
dielectric test of C22.2. The tests consist of applying a
voltage ramp from 100 to 1000 volts over 30 seconds and
maintaining the 1000 V for 60 seconds. As is the case with
US testing, excessive current flow during the interval in
dicates a dielectric breakdown.
In.
ALLOWABLE REOIO¼I
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FIGURE 7
TABLE 1, FIGURE 7 and 8
In the UK, signal power limits are complex. Devices must be measured to comply with
the limits in the tabte 10 Hz bandwidth and the graph 3 kHz bandwidth Figure 7.
Off-hook DC characteristics must fail beneath the cone of Figure 8.
CURRENTmA
FIGURES
5 10 50 100 500
TABLE 1
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20
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223
UNITED KINGDOM
Unlike Japan, the United Kingdom required no proddingto open up the telecommunications markets. In doing so, itwas the first of the European nations to join with theUnited States and Canada in opting for a deregulatedtelecommunications system. Through the Telecommunications Acts of 1981 and 1984, the British adopted some ofthe characteristics of the US system. Provision of customerpremise equipment is entirely competitive, with subscribers
being able to purchase equipment from any number of ven
dors.
The Telecommunications Acts have delegated theregulatory responsibility to the Secretary of State of Trade
and Industry. Through his "Statutory Instruments" and``Designations," the Secretary of State's ofice defines thestandards which customer premise equipment must meet.Testing to determine if the equipment meets those standards is the job of the British Approvals Board forTelecommunications BABT. Most of the standards areadaptations of those of the British Standards InstituteBSI. Where no standard has been designated, the BABTsometimes issues "Special Investigation Test Schedules" tocover those areas.
The basic technical provisions can be found in BS 6305
1982. The object of British law is to protect against net
work harm, as in the United States. But the scope of what
constitutes network harm is more broadly defined and, like
Canada, more complex.
Signal Power
Paralleling the Canadian rules, the British standards
prescribe signal limits for voice data and dialing. Voice and
data transmission is generally limited to -9 dBm as in the
United States and Canada. On hook which the British call"off line", signal power must be less than -65 dBmp
psophometric with respect to one milliwatt. Out-of-band
signals must meet the limits in the figure. The upper limit is10 MHz, considerably higher than in the US 6 MHz or
Canada 1 MHz.
Standards for pulse dialing require break current less
than 500 microamps with a pulse rate of 10 plus or minus 1
pulse per second. The break percentage must be 67% plus
or minus 4%. DTMF signals must meet CCITT specifica
tions with a rise and fall time of 15 and 10 milliseconds
respectively.
Balance
The British standards break up balance into two types,"Earth impedance" balance and "Signal balance aboutearth." Earth impedance balance is the kind of balance
referred to in US and Canadian specifications, measured
using test methods similar to IEEE 455. Balance must be
greater than 46 dB from 300 Hz to 3.4 kflz. Signal balance
about earth is really a measure of longitudinal signal power.
The limit is generally -55 dllm.
Impedance
On-hook DC resistances between tip and ring referred to
as "A" and "B" leads in Britain must be greater than 5
meg between those leads and earth ground. DC resistance
between tip and ring is specified as a function of the ringer
equivalence and is equal to 30 times the ringer equivalence
in microamps.
Off hook, the DC characteristics must meet the limits in
the figure.
Ringer equivalence is measured using the circuit shown.
When the device is hooked to the A and B terminals, it
21 5Hz
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Line Segment
To test for Ringer E4IIivaIence in the UK, the line is loaded with anumber of devices to be approved until the BT No. 59D belt stopsringing.
should ring. A second,.third, fourth device, up to lOin all,
are then hooked in parallel until the line is loaded so heavilythat the British Telecom 59 D bell no longer functions.
Ringer equivalence is then calculated by taking three and
dividing it by the number of devices which caused the bell
to stop functioning.
In addition, on hook, the device should have an im
pedance between the A and B leads of greater than 10 k
from 300 Hz to 3.4 kflz and greater than 300k from either
of the leads to ground.
Off hook, most speech devices are required to have
Single Frequency Return Loss of greater than 12 dB with
respect to 600 ohms in the range of 300 Hz to 3.4 kHz and
Echo Return Loss greater than 16 dB. Non-speech ap
paratus must generally have a Return Loss greater than 14
dB measured over 200 Hz to 4 kHz. For these, reactive
component must not be greater than 50 ohms.
Billing Protection
The "forbidden bands" in Britain differ from those in
the United States and Canada. There are two of them, one
from 450 Hz to 900 Hz "C" band and one from 2130 to
2430 "A" band. If any signals exist in either of these
bands, it must be accompanied by signals in the band from
900 Hz to 2130 Hz which are within 12 dB of the total
power contained in either "C" or "A" band. In any event,
it is recommended that the total signal power in the A band
be less than -33 dBm.
JAPAN
Japan's new "Telecommunications Business Law" went
into effect on April 1, 1985. Under that law, Nippon
Telegraph and Telephone public corporation NTT was
reorganized as a private company and competition allowed
in customer premise equipment. Article 49 of the law re
quires that common carriers provide service to anyone who
has equipment which has been certified under the regula
tions of the Ministry of Post and Telecommunications
MPT. Ministerial Ordinance No. 31/1985 prescribes the
Japanese standards. It is only a fraction of the size of the
US, Canadian or British standards. In most respects, it
parallels those, but has some notable differences.
Signal Power
In-band power is limited to - 15 dBm, but makes the
measurement at the central office rather than at the
customer equipment. Line loss, therefore, enters into the
224
calculation. If 6 dB of line loss is assumed, the levelsallowed would be -9 dBm, the same as in US, Canada or
the UK. Out-of-band signals must be 20 dE down from thein-band peak level from 4 to S kllz, 40 dB down from S to12 kHz, and 60 dB down above 12 kHz. Curiously, theregulations do not specify an upper frequency limit. Whenon hook, background noise must be less than -64 dBm.
Dial pulses can be at either a 10 pulse per second or 20
pulse per second rate. The ratio of make to break is 33%
plus or minus 3%. For DTMF signals, the CCITT specified
frequencies plus or minus 1.5% must be met.
Balance
Curiously absent from the Japanese specifications are
any balance requirements or any requirements specifying
longitudinal signal levels.
Impedances
On hook DC resistance between telco lines or between
telco lines and ground must be greater than 1 megohm. Off
hook, the DC resistance must be between 50 and 300 ohms
or up to 550 ohms during pulse dialing.
For AC impedances, both the measure of ringer im
pedances and Return Loss are required. The Return Loss
tests are described in MPT Notice No. 563 and are some
what at odds with the tests used in the United States,
Canada and the UK. The ringer is measured with a 75 volt,
16 Hz signal applied, and the ringing impedance must be
greater than 2 kilohms. Capacitance and reactance of the
loop either on or off hook must be less than 3 4.
Environmental/Safety
There are no environmental specifications in Japan, but
devices sold may also have to meet Japanese Electrical Ap
pliance and Material Control Law. In addition, Japanese
regulations require .2 megohm impedance between primary
and secondary transformers and require that any exposed
metal be grounded through 100 ohms or less.
Billing Protection
Forbidden bands are not specified in the Japanese regula
tions. Other than the requirement of a DC off-hook
resistance of between 50 and 300 ohms, there are no billing
protection specifications in the Japanese regulations.
LOOKING FORWARD
The future of competitive access to foreign markets
seems to be bright. On its face, the Japanese market looks
open, and its new standards are tolerable. But what seems
clear on its face may not in reality produce what America
wants. Japanese technology may have caught up, or clear
regulations may mask a more murky bureaucratic process.
In Europe, the EC's efforts to harmonize will aid US
manufacturers as well, opening a new and lucrative market.
On the balance, all looks well, but in the midst of a trade
war, no one can know for sure.
Signal Power -
Metallic Diff.
Inband
Signal Power
Longitud. Cmn.
Mode
ground
1500 V/lU mA limit
primary to ground
Application of 120
VAC to case, I/O
should not result in 70
V or more on Telco
lines
Canada United Kingdom
1000 VAC Stress ap- BS 6301
plied telco to gnd,
1500 VAC primary to
ground
Not required ES 6301
Covers 100 Hz-6 MHz Covers 10 kHz-1 MHz Covers DC-b MHz
Japan
Primary to Secondary
impedance > .2 meg
600 VAC applied
Not required
Unspecified frequency
range
-15 dBm, but line
loss is considered
20 dB down 4-S kflz
40 dB down 8-12 kHz
60 dB down 12 kHz
up
Not regulated
-30 dBV See Figure 3
-30 to -40 dBV 4 to See Figure 3
12kHz
-40 to -62 dBV 12
to 42 kHz
-62 dBV 42 to 270
kHz
-30 dBV 270 Hz - 6
-55 dBm
-55 dBm
Test Req. United States
INTERNATIONAL REQUIREMENTS
FOR TWO WIRE LOOP START DEVICES
AC Stress/Leakage
Current
Hazardous Voltage
1000 V/l0 mA Limit
telco connection to
Covers 200 Hz-6MHz Covers 10 Hz-I MHz
-9 dBm permissive Same as US
mode
Out of band -14 to -20 dBV 4-12
kHz
-2Oto -SSdBV
12-90 kHz
-55 dBV 90-270 kHz
-15 dBV 270kHz-
6MHz
Covers DC-b MHz
Same as US.
See Fig. 7On Hook
10-100 Hz -33 dBm
C Message Band 17
dBrnC
Off-Hook
See Fig. 3
In band
Out of band
MHz
Not regulated
Not regulated
226
Signal Power
Forbidden band
Dial Pulse
Parameters
Canada
Must meet CCITT
specifications
Rise time 5 msec.
3995-4005 kHz
-27 dBm voice
-20 dBm data
8-11 pps. ¾
Break 61%±3%
Break resist. >20 k
United
Kingdom
CCITT specifications
Rise time 15 msec.
FaIl 10 msec.
Not regulated
9-11 pps ¼
Break 67% ± 4%
Break crt less than 500
Not regulated
9-11 pps67%±3%
Make resistance less
than 550 ohms
Balance
Impedance
On Hook
Impedance
Ringer
Impedance
Return Loss
Billing Protection
Delay
Billing Protection
DC off-hook im
pedance
Measured by FCC
method. Limit 60 dB
200 Hz-i kHz
40 dB 1 kHz-4 kHz
0-100 VDC applied
Greater than 5 meg
100-200 VDC applied
Greater than 30 k
Between 1.6k and 40k
15.8-68 Hz, 40-150
VAC applied B type
Ringer
Not required for 2 W
loop start Terminal
devices
2 sec. delay before
transmission
<200 ohms or <25%
overshoot
Measured using
IEEE-455 1976
0-100 VDC applied
>2 meg
AC Impedance
16k - 500 Hz
5k - 200 Hz
>1.4k at 20Hz,
40-130 VAC applied
>1.0k at 30Hz
Echo return loss >11
dB, 500-2500 Hz
Single freq. return loss
>3 dB, 200-3500 Hz
Cannot return to on-
hook state
automatically in <5
seconds
Must meet Figure 6
Measured w/ method
similar to IEEF-455
46 dB 300-3400 Hz
0-100 VDC >5 meg.
to ground.
Tip to Ring crt must
be <30 x RENjtA
AC Imped., T-R> 10k
Measured by loading
typical line until a BT
59D bell no longer
rings
Voice devices
SFRL >12dB
300-3400 Hz
ERL >16dB
Data:
SFRL >14dB
200-4000 Hz
Not regulated
Must meet Figure 6
Not regulated
1 meg Tip-Ring or
Tip/Ring to Ground
250 VDC applied
>2k, 75 VAC 16Hz
signal applied
MPT Notice 563
Not regulated
50-300 ohms
Billing Protection
Single Frequency
Restriction
Environmental
Lightning Surge
Environmental
Vibration
Environmental
Temp./Hum. Cycle
Environmental
Drop Tests
Billing Protection
On-Hook Transmis
sion
Signal Power DC
Energy from 800-2450
Hz must exceed
energy from 2450-2750
Hz
See Fig. 12
.5g 5-100 Hz
.1 octave/mm.
l.5g 100-500Hz
.25 octave/mm.
-40 F/150%RH 30
mm.
90F/90%RH 30 mm.
150 F 30 mm.
See Figure 11
<-55 dBm
Not required
Not required. Equip
ment shall not detect
leaked signals
Not required
Test Req. United States
Signal Power DTMF 0 dBm max. amplitude
3995-4005 kFIz
-27 dBm permissive
mode
Not regulated
Japan
CCITT specifications
Not required
Not required
Not required
Not required
Same as US
Same as US
Not required
Not required
Not required
Same as US
<25 mV Tip to Ring.
Tip or Ring to ground
0 to .SV
CSA C22.2 0.7
See Text
Not required
Not required
Not required
Not required
-65 dBmp
-33 dBm
BS 6301Other Applicable
Safety Standards
Not regulated
UL 478
UL 1459
Electrical Appliance &
Material Control Law
227
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