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

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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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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

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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.

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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.

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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

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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