In the Matter of AMERICAN TELEPHONE
AND TELEGRAPH CO. (A.T.&T.) "Foreign Attachment" Tariff Revisions
in
A.T. & T. Tariff FCC Nos. 263, 260,
and 259
FEDERAL COMMUNICATIONS COMMISSION
15 F.C.C.2d 605 (1968); 15 Rad. Reg.
2d (P & F) 91
RELEASE-NUMBER: FCC 68-1234
December 24, 1968 Adopted
BY THE
COMMISSION: COMMISSIONER COX CONCURRING IN THE RESULT; COMMISSIONER
[*605] 1.
We have before us new tariffs and supporting papers filed recently by
the American Telephone and Telegraph Co. (A.T.&T.) in behalf of itself and
other telephone companies wherein it is proposed to effectuate significant
changes in the foreign attachment provisions now appearing in certain tariffs
of .T.&T. These provisions govern
the connection or attachment of customer-provided facilities to common
carrier-provided facilities used in furnishing interstate or foreign
communications services to the public.
The particular services affected by these new tariffs are
long-distance-message telecommunications service or message toll telephone
service (tariff No. 263); private line service (tariff No. 260), and wide-area
telecommunications service or WATS (tariff No. 259). The new tariffs are published to become effective, in part, on
January 1, 1969, and, in part, on January 1, 1970. Appendix A hereof identifies the aforesaid new and revised
schedules and supporting documents submitted by A.T.&T. In addition, we have before us a number of
formal and informal pleadings and comments that have been submitted in response
to the new tariffs. See appendix B.
2. Many of the responsive pleadings request us
to reject, suspend, or investigate the new tariffs in whole or in part. Others submit comments and observations on
the new tariffs without requesting any specific action by the Commission at
this time. A.T.&T. urges us to
permit the new tariffs to go into effect as scheduled without hearing or
investigation. We believe that it will
be useful to outline the salient features of the changes proposed by the new
tariffs and the questions presented before stating our disposition of the
matter before us.
[*606]
3. The pleadings and comments
are addressed principally to the new tariffs as they affect A.T.&T.'s
tariff FCC No. 263. This tariff applies
to the message toll telephone service, which is to be renamed
"long-distance-message telecommunications service" under the new
tariffs.
4. The nature of the changes proposed for A.T.
& T. tariff FCC No. 263 will be more easily understood by making clear at
the outset the nature of the service offered by the telephone companies under
this tariff. This service utilizes the
nationwide switched network of more than 2,000 cooperating telephone companies
extending throughout the country. The
network consists of (1) the telephone set, usually located on the customer's
premises; (2) the pair of wires, or loop, and its supporting structures, which
connect the telephone set to the central office; (3) the switching equipment in
the central office; and (4) the trunk facilities that connect central offices
to each other.
5. For years the tariffs on file with this
Commission governing this service offering have made it clear that this service
consists of the furnishing of facilities for the public to make interstate or
foreign telephone calls between telephones, that is to say the service is now
and has for many years been offered only as a complete service that includes
the furnishing of the telephone itself with certain exceptions hereafter
noted. Thus, the presently effective
Tariff 263 states that the service offered there under "is that of
furnishing facilities for telephone communication between telephones in
different local service areas" and that the interstate and foreign toll
charges shown in the tariff "are in payment for all service furnished between
the calling and called telephones" (2.1.1(A)). (Our italic.)
6. With respect to the revisions in the message
toll tariff, several important features emerge. First, the new tariffs would delete currently effective paragraph
2.6.1 which, in pertinent part, now reads as follows:
No equipment, apparatus circuit or device not furnished by
the telephone company shall be attached to or connected with the facilities
furnished by the telephone company, whether physically, by induction or
otherwise * * *.
Also
they would delete currently effective paragraph 2.6.9 which begins with the
following language:
The provisions of paragraph 2.6.1 preceding shall not be
construed or applied to bar * * *.
Second,
in addition to canceling the above-cited paragraphs, the new tariffs would
publish new provisions as follows:
2.6.1
Customer-provided terminal equipment may be used with the
facilities furnished by the telephone company, for long-distance-message
telecommunications service, as specified in 2.6.2 through 2.6.6 following;
2.7.1
Customer-provided communications systems may be connected
with the facilities furnished by the telephone company for
long-distance-message telecommunications service as specified in 2.7.2 through
2.7.10 following. (Our italic.)
[*607]
7. As indicated above, the new
tariffs will permit any kind of customer-provided communications system (e.g.,
a private microwave system) to be attached to or connected to the telephone
company facilities subject to the specifications set forth in the new tariff. Thus, an important feature of the revisions
is the new set of conditions, referred to above, that are to govern the
interconnection of such terminals and systems.
8. In the case of both customer terminals and
systems, it will be the general responsibility of the customer to assure that
his terminal or system shall not interfere with any of the services offered by
the telephone company, nor endanger the company's employees or the public, or
damage or change the company's equipment or facilities (2.6.2 and 2.7.2). Also in the case of both customer terminals
and systems, all network control signaling functions are to be performed by
equipment that is furnished, maintained, and instilled by the telephone company
(2.6.3 and 2.7.3), with exceptions. These
exceptions, which have been in existence for some time, apply under limited
conditions to systems of power, pipeline, and railroad companies, National
Aeronautics and Space Administration, U.S. Army, Navy, and Air Force, and to
systems or terminals of customers located in isolated, sparsely developed,
hazardous, or inaccessible locations (2.7.4, 5, 6, and 7). Network control signaling is defined in the
new tariffs as the transmission of signals used in the telecommunications
system which perform functions such as supervision (control, status, and
charging signals), address signaling (e.g., dialing), calling and called number
identification, audible tone signals (call progress signals indicating reorder
or busy condition, alerting, coin denominations, coin collect and coin return
tones) to control the operation of switching machines in the telecommunication
systems. The ordinary telephone set as
used in the message toll service is a network control signaling unit.
9. The new tariffs divide customer terminals
into three categories: Data transmitting or receiving equipment (data), voice
transmitting or receiving equipment (voice), and accessories.
10. At the customer's option the aforementioned
data terminals may be connected to the telephone company facilities either by
direct electrical connection (i.e., physical connection of electrical
conductors) or indirectly (i.e., acoustic or inductive connections). If the option is for direct electrical
connection, the data customer has a further choice of (a) using either the
telephone company's dataphone set, which performs not only the network control
signaling functions but also the functions of a modem (modulation and
demodulation of signals), or (b) using an interface called a data access
arrangement, furnished by the telephone company, 2n lieu of the dataphone. Such an interface does not perform the modem
function, so that this option allows the customer to provide his own modem
rather than using that of the telephone company. If the customer's option is for a direct electrical connection
through a data access arrangement rather than through a dataphone, then the
customer's data terminal must meet certain technical criteria that are set
forth in detail in appendix C hereof.
11. If instead of a direct connection, the data
customer chooses to [*608] connect his data terminal indirectly, he may
do so by acoustic or inductive connections made externally to the telephone
company's network control signaling unit.
No telephone company interface is required therefore and no technical
criteria are specified for such indirectly connected data terminals in the new
tariffs published to be effective January 1, 1969. However, the new tariffs specify that, effective a year later, on
January 1, 1970, the technical criteria for such indirectly connected data
terminals shall be as shown in appendix D hereof.
12. The second, or voice, category of customer
terminals may also be connected either directly or indirectly. If direct connection is used, such a
terminal must use a telephone company interface called a connecting
arrangement, and the terminal must meet the technical criteria set forth in
appendix C hereof. If indirect
connection is used, such connection must be made externally to the telephone
company's network control unit. However
no other interface is required and no technical criteria will apply until
January 1, 1970. On and after that date
the criteria shall be as shown in appendix D.
13. Accessories are customer terminal devices of
a mechanical nature that do not involve electrical connection, directly or
indirectly, to the telephone company facilities. These terminals are not subject to the technical criteria
required for data and voice terminals, but are subject to the other
requirements of the tariff applicable to all terminals.
14. Insofar as the interconnection of customer
systems is concerned, the new tariffs impose the same technical criteria on
these customer-provided facilities as apply to terminals. Thus, the new tariffs will permit either
direct connection thereof through a connecting arrangement interface provided
by the telephone company or through an indirect acoustic or inductive
connection made externally to the telephone company's network control signaling
unit. If a customer system is to be
interconnected directly, it must meet the technical criteria set forth in
appendix C. If it is to be connected
indirectly by acoustic or inductive means, no technical criteria will apply
until January 1, 1970, when the criteria shown on appendix D must be met.
15. A.T.&T. states that the purpose of the
1-year postponement of the technical criteria in appendix D for indirect
connections is to give customers having acoustic or inductive devices that do
not currently meet the new criteria additional time to accommodate themselves
to these criteria.
A.T.&T.
TARIFF FCC NO. 259
16. This tariff applies to wide-area
telecommunications service or WATS. It
is a voice grade service that is provided over the same nationwide switched
network used for message toll service.
The new and revised tariffs propose in substance to make the same
revisions in WATS as outlined above for the message toll service.
A.T.&T.
TARIFF FCC NO. 260
17. This tariff applies to private-line
service. This is a separate service
that does not use the switched telephone network. Changes comparable
[*609] to those referred to
above for message toll and WATS are not being proposed at this time for the
private-line service. However, the
private-line-service tariff is being revised, effective January 1, 1969, to
make a new private-line offering whereby customers may obtain private lines of
not more than 25 airline miles to connect their own voice grade private
channels to the telephone company message toll telephone network. These private-line facilities are called
entrance facilities. They may not be
used to connect a customer terminal or system to private-line facilities of the
telephone company.
18. A.T.& T. has advised the Commission by
letter dated December 6, 1968, that it expects to make further revisions in its
private-line service tariff comparable to those made in the message toll and
WATS tariffs, shortly after January 1, 1969.
II. Questions Presented
19. As heretofore stated, the objections that have
been filed are aimed principally at the revisions in the message toll tariff
No. 263. The contention is made that
these revisions do not comply with our Carterfone decision, In the Matter of
Use of the Carterfone Device in Message Toll Telephone Service, 13 FCC 2d 420,
14 FCC 2d 571. Objections are also made to the revisions in the WATS and
private-line tariff for the same reason.
20. Accordingly the principal question raised by
the pleadings and comments is whether the new and revised tariffs, in whole or
in part, are in violation of our decision in Carterfone, and, if so, what
action we should take with respect thereto.
In addition, the question is raised as to whether, apart from compliance
or noncompliance with Carterfone, there appear to be any other question of
lawfulness that would warrant suspension, investigation, or action by the
Commission at this time and, if so, the nature thereof.
III. Discussion
21. The contention is made that the new and
revised message toll tariffs do not comply with our decision in Carterfone
because the new filings bar the use of any customer-provided network control
signaling units irrespective of whether they are harmful or harmless to the
rest of the message toll telephone system.
It is argued that such a bar is an a priori assumption of harm that we
found in Carterfone to be unreasonable.
22. We believe that this particular objection is
based upon a misconstruction of what we decided in Carterfone. We were concerned in that case with the
lawfulness of tariff provisions that prohibit a customer from making harmless
interconnection of his terminals or systems with the message toll telephone
system of the telephone companies. As
we have heretofore stated, this telephone system includes the telephone instrument
which performs the network control signaling functions for message toll
telephone service. We were therefore
concerned with what could be connected or attached to this telephone system. Our decision in Carterfone does not hold
that a customer may substitute his own equipment or facilities (whether it
be [*610] telephone instruments, loops, poles, or central office
equipments) for that furnished by the telephone company in providing message
toll telephone service as that service is defined in the tariff. Our decision dealt with interconnections and
not replacements of any part of the telephone system. We emphasized this in our decision where we stated that "our
conclusion here is that a customer desiring to use an interconnecting device to
improve the utility to him of both the telephone system and a private radio
system should be able to do so, so long as the interconnection does not
adversely affect the telephone company's operation or the telephone system's
utility to others." 13 FCC 2d at page 424. In denying petitions for
reconsideration we again made this clear by stating that "General has
contended that the Commission has 'opened the door to customer ownership of
telephone handsets.' The facts of this case did not involve the furnishing of purely
telephone system equipment telephone-to-telephone on the message toll telephone
system." 14 FCC 2d 571 at page 572. (Our italic.)
23. Although the tariff bar against any customer
providing his own network control signaling unit is not in conflict with our
Carterfone ruling, the question remains as to whether the telephone companies
should make provision in their tariffs by which subscribers may have access to
the so-called switched telephone network through the use of their own provided
network control signaling equipment. On
the basis of the pleadings and comments before us, we are in no position to
determine the extent to which any such provision may be consistent with
efficient and economic telephone service and otherwise in the public interest. In our opinion, these and other matters
warrant further consideration by the Commission before it determines whether
and what further action, if any, may be required. We believe that we will be in a better position to make these
determinations after we have had a reasonable opportunity to closely observe
the effects of the substantial changes now being effectuated by the telephone
companies in their interconnection tariffs, the extent to which such changes
satisfy reasonable requirements of their subscribers for data transmission and
other communication services or facilities, and the implementation by the
telephone companies of their representations that they are actively engaged in
devising equipment and operating procedures to meet the expressed needs of
customers for flexible access to the switched network. Thus, we will permit the tariff revisions to
become effective as scheduled with the understanding that in doing so we are
not giving any specific approval to the revised tariffs.
24. We are also instructing the chief of the
Common Carrier Bureau to initiate promptly a series of informal engineering and
technical conferences with the telephone industry and interested manufacturers,
user groups, and Government agencies to ascertain what further changes are
necessary, desirable, and technically feasible in the various tariff offerings
of the telephone companies. It is our
intent that these further informal proceedings shall be broad in scope and that
they will provide a principal forum for the identification, examination, and,
subject to Commission review, resolution of any questions presented by the
tariff revisions. We are aware, for
example, that there [*611] are a number of unresolved specific
questions, which we need not delineate herein, that are raised both in the
pleadings and in the separate analysis of our own staff. These may require further action by the
Commission. Some of these problems can
reasonably be expected to be satisfied by further tariff amendments, such as
additional revisions in the private-line tariffs which are scheduled to be made
early in 1969, and provisions for unattended operation of a large variety of
customer data terminals, which provisions, according to the telephone
companies' commitment, will become possible by the middle of 1969 when
appropriate equipment and arrangements therefore will have been developed. Other tariff changes may be necessary or
desirable, both of a substantive and clarifying nature, to respond to other
questions that have arisen and that are likely to arise. Accordingly, the further proceedings will
include, among other things, consideration of what changes, if any, should be
made in the technical criteria and other conditions for interconnection and
other matters of clarity and substance raised by the pleadings and
comments. The staff will submit
periodic reports to the Commission, with appropriate recommendations, and the
Commission will be prepared to take such further action as it deems necessary
or desirable to resolve outstanding issues.
25. We are of the opinion that the further
informal procedures that we are here initiating, together with the information
gained from the pending computer inquiry (docket No. 16979), will greatly
assist the Commission in carrying out its statutory obligations herein. Through such procedures we expect to obtain
valuable technical and operational information on a current and continuing
basis and from a variety of sources that will aid us in our evaluation of the
public interest factors involved in the new tariffs now being put into effect,
as well as any new or revised tariffs that are expected to be proposed for the
future or that may otherwise be required.
26. We will also welcome the cooperation and
participation in the further proceedings of the National Association of
Regulatory Utility Commissioners on behalf of the State regulatory commissions
which have a substantial interest in the matters yet to be determined herein.
IV. Conclusion
27. In view of the foregoing, we conclude that
we should permit the new and revised tariffs to go into effect, as now
scheduled, on January 1, 1969, without scheduling a formal investigation or
hearing at this time. Our action is not
to be construed as approval thereof and these tariffs are subject to such
further action as the Commission may wish to take with respect thereto.
28. Accordingly, it is ordered, That the various
pleadings and requests for rejection and suspension or formal investigation of
the aforementioned new and revised tariffs Are hereby dismissed without
prejudice.
FEDERAL
COMMUNICATIONS COMMISSION, BEN F. WAPLE, Secretary.
[*614] DISSENTING
OPINION OF COMMISSIONER NICHOLAS JOHNSON
The
11-year-long saga of the Carterfone case involves, in general, the competitive structuring
of this country's communications network.
A small manufacturer, Tom Carter, sought to market an invention enabling
the user to couple a telephone handset to a mobile radio transmitter. The telephone company, through its
jingoist-titled "foreign attachment" tariff, opposed his
efforts. For A.T. & T. has
consistently held to the position that it is entitled to a monopoly not only of
the Nation's switching system and communications lines, but of all consumer
equipment "attached" to its system as well. (A distant analogy might be suggested if an electric power
company were to insist on a monopoly of the manufacture, installation, and
repair of toasters, television sets, and all other electrical appliances that
could be plugged into an electric wall socket.) Yielding not an inch, A.T.
& T. has consistently and successfully fought off for years the Tom Carters
of the communications industry.
[*615]
But Tom Carter persisted. For 11
long years he persisted. And then,
finally, earlier this year, the FCC held the foreign attachment tariffs illegal
and authorized Tom Carter to go ahead with the sale of his device. Carterfone, 13 FCC 2d 420 (1968). The
Commission's opinion was heralded as a commendable effort to open up
competition in the communications business.
As
experienced reformers have long since discovered, however, the political
victories that are won after long struggle under the light of public scrutiny
can be very quickly lost in the dark backrooms of practical implementation. The new legislation or agency decision is
praised and then forgotten. And when --
if ever -- anyone goes back to see how it all worked out he finds the situation
very little changed from before. The
swamp waters have returned to their former level.
And so
it was, shortly after the Commission's Carterfone decision, that A.T. & T.
petitioned for a stay of its effectiveness and for a reconsideration of the
decision. The Commission's Common
Carrier Bureau did not oppose the stay, and the Commission granted it until
November 1, 1968 -- over the dissents of Commissioner Cox and myself. Carterfone, 14 FCC 2d 149, 151 (1968). When
the Commission affirmed its decision on reconsideration, Carterfone, 14 FCC 2d
571 (1968), the telephone company went to court. Subsequently, A.T. & T. asked for and was granted, another
extension of the stay of the effective date of the decision from November 1,
1968, to January 1, 1969. Carterfone,
15 FCC 2d 31 (1968).
All
these delaying tactics are well known, and fully exercised by A.T. &
T. What A.T. & T. had not counted
on, however, was that its first tariff proposal would be watched by small
businessmen from across the country in addition to Mr. Carter -- and that they
would send up howls of protest when they saw what A.T. & T. was trying to
do. For A.T. & T.'s first proposals
were designed to be drawn very narrowly in an effort to render this landmark
decision of limited practical effect.
Having
been publicly caught in this untenable posture,
These
new tariffs raise three separate questions.
First, who is to own and control the network signaling device -- the
dial mechanism that imparts control signals to the telephone system?
Secondly,
there is the question of how well these new tariff provisions are going to
work, what their effect will be, and what the literal words of the tariff mean
operationally. This is the arena, of
course, [*616] in which this ballgame will ultimately be
won or lost. Disagreement between the
parties is most likely in view of the past history of the foreign attachment
question.
Finally,
a number of parties have raised specific questions about parts of the tariffs
We are
now confronted with a proceeding in which virtually every party -- other than
the telephone company and the Common Carrier Bureau -- opposes part or all of
these tariffs. And yet they are allowed
to go into effect, with differences to be resolved in informal closed-door
sessions.
I cannot
agree that the validity of the telephone company's refusal to permit
subscribers to provide their own telephones purchased in a free market is a
question which can appropriately be determined through informal
discussions. The Carterfone case is a
testimony to the tenacity of the little fellow who won out over a procedural
system which for years permitted the telephone companies to monopolize the
connection of private communications systems with the telephone network. While the Carterfone decision does much good
in permitting beneficial interconnection, the Commission's present treatment of
a far more important question will result only in unnecessary delay before it can
be resolved. It is tough enough for the
little operator to win out in formal proceedings before this Commission and the
courts. It is virtually impossible
without such protections.
No one
will disagree with the importance of the issue presented by the insistence of
A.T. & T. and the other telephone companies that they must be the sole
provider of all equipment which initiates signaling. But this issue, of such great importance to every telephone
company subscriber, is now on the road to being settled through a process in
which the ordinary person will have no effective voice and of which, indeed, he
is likely to be totally unaware. The
telephone companies will be well represented.
Large corporations seeking more flexibility in the use of telephone
facilities will be well represented. The
ordinary person who cannot understand why he should not be permitted to buy his
own telephone will not be represented at all, except indirectly by some other
party or by the "referee" Commission staff.
I recognize
that the entire process of reviewing telephone company tariffs is not conducive
to ordinary consumer participation.
This makes it all the more important that a question so vitally
affecting the ordinary [*617] consumer be examined and decided under the
light of day in fully public proceedings rather than in informal
negotiations. It seems highly unlikely
that negotiations can lead to any substantial changes in the telephone
company's position on this issue.
Therefore, if there is any doubt as to whether the proposed tariff
provisions are unreasonable, the question must be explored in a full hearing
under section 205 of the communications act, since Commission action to remedy
an unreasonable tariff must be after hearing.
There is no point in not instituting such a hearing at the outset, and
the failure to do so can only result in unnecessary delay. Informal procedures have no advantage over
the formal hearing process in this situation.
This is not a negotiation among sovereigns where forcing a party to take
a public position may make it more difficult for him to back off
gracefully. It is a matter for decision
by a public body entrusted with the duty to make a decision, and with the power
to enforce it. Furthermore, the
Carterfone proceeding furnishes ample evidence that the hearing process is an
excellent means of testing technical claims.
I do not
urge that the proposed tariffs must necessarily be rejected or suspended. I do urge that it is a great mistake to
enter upon this new exploration to which Carterfone was a prelude in a
semiprivate bargaining session rather than in the full hearing process in which
the public may justifiably have confidence.
APPENDIX:
APPENDIX
A
TARIFFS
AND SUPPORTING DOCUMENTS
1. A.T. & T. transmittal letter No. 10240,
dated September 13, 1968 (relating to proposed revisions in A.T. & T.
tariff FCC No. 263).
2. A.T. & T. transmittal letter No. 10249,
dated October 2, 1968 (relating to proposed revisions in A.T. & T. tariff
FCC No. 263).
3. A.T. & T. (unnumbered) letter to FCC,
dated October 4, 1968, stating, among other things, intent to offer in future
station equipment to permit unattended operation of data terminal (i.e.,
automatic calling and answering), and to require A.T. & T. dataphone sets
to meet tariff technical criteria (relating to proposed revisions in tariff FCC
No. 263).
4. A.T. & T. transmittal letter No. 10267,
dated October 18, 1968 (relating to proposed revisions in A.T. & T. tariff
FCC No. 263).
5. A.T. & T. transmittal letter No. 10270,
dated October 22, 1968 (relating to proposed revisions in A.T. & T. tariff
FCC Nos. 263 and 260).
6. A.T. & T. (unnumbered) letter to FCC,
dated October 29, 1968, stating intent to offer facilities by middle of 1969 to
permit automatic connection of customer provided PBX and intercom-type system
to the long-distance telecommunication network (tariff FCC No. 263).
7. A.T. & T. transmittal letter No. 10281
to FCC, dated October 30, 1968 (relating proposed revisions in tariff FCC Nos.
263 and 260).
8. A.T. & T. transmittal letter No. 10291,
dated November 12, 1968, and revised pages to A.T. & T. tariff FCC No. 263
submitted therewith; reissuing and revising tariffs submitted under transmittal
Nos. 10240, 10249, 10267, 10270, and 10281.
9. A.T. & T. letter (unnumbered) of
November 15, 1968, to FCC and enclosed statement in support of provision in new
and revised tariffs that connection of customer-provided terminal and systems shall
be made through a network control signaling unit furnished, installed, and
maintained by the telephone company.
10. A.T. & T. transmittal letter No. 10293,
dated November 15, 1968, and revisions submitted therewith in A.T. & T.'s
tariff FCC No. 259 (wide-area telecommunication service).
11. A.T. & T. transmittal letter No. 10294,
dated November 18, 1968, and revisions submitted therewith in A.T. & T.'s
tariff FCC No. 260 (private-line service) re entrance facilities for use in
customer connection's to the switched telephone network.
12. A.T. & T. letter (unnumbered), dated
December 6, 1968, advising it as to when further revisions will be made in A.T.
& T. tariff FCC No. 260 (private line service).
13. A.T. & T. letter (unnumbered), dated December
13, 1968, in reply to pleadings and comments filed in response to
aforementioned new and revised tariffs.
APPENDIX
B
Tel-Plan,
Inc. -- Comments on the proposed tariff revisions in tariff Nos. 259, 260, and
263, filed December 10, 1968.
Aeronautic
Radio, Inc. (ARINC). -- Comments on the proposed tariff revisions in tariff No.
260, filed December 6, 1968.
Charles
W. Schweizer Associates, Inc. -- Comments on the proposed tariff revisions in
tariff No. 263, filed December 11, 1968.
The Data
and Graphic Communications Section of the Electronics Industries Association
petition. -- Protesting and opposing proposed tariff revisions in tariff 263
and for investigation, filed December 2, 1968.
National
Retail Merchants Association (NRMA). -- Comments on the proposed tariff
revisions in tariff No. 263, and request for acceptance of the tariff filing,
filed December 2, 1968.
Bethlehem
Steel Corp. et al. -- Revised petition to reject certain tariff provisions in
tariff No. 263, filed November 26, 1968, and supplemental petition to reject
tariff filing, filed December 2, 1968.
TELCON
Associates, Inc. -- Comments on the proposed tariff revision in tariff No. 263,
filed November 15, 1968, and a supplemental statement commenting on the
proposed tariff revisions in tariff Nos. 259, 260, and 263, filed December 4,
1968.
Computer
Security Systems. -- Petition objecting to certain revisions in tariff No. 263
and asking that they be rejected, filed December 3, 1968.
Photo
Magnetic Systems, Inc. -- Letter objecting to certain revisions in tariff No.
263, filed November 22, 1968, and a petition to reject certain provisions of
tariff No. 263, filed December 2, 1968.
Ripley
Co. -- Comments on the proposed tariff revisions of tariff No. 263 and request for
appropriate relief, filed December 2, 1968.
Small
Business Administration. -- Statement supporting the suspension and
investigation of certain revisions in tariff No. 263, filed December 2, 1968.
Aerospace
Industries Association of America, Inc. (AIA). -- Petition for rejection of
certain revisions of tariff No. 263 and for other relief, filed December 3,
1968.
Altone
Systems, Inc. -- Petition for rejection
of certain revisions in tariff No. 263, filed October 15, 1968, and a
supplemental letter, filed December 2, 1968.
Xerox
Corp. -- Supplemental pleading withdrawing objection to certain revisions in
tariff No. 263 and additional comments, filed November 29, 1968.
Microwave
Communications, Inc. (MCI). -- Petition to reject certain tariff revisions in
tariff No. 263 and for other relief, filed December 3, 1968.
Thomas
F. Carter, Carter Electronics Corp. and Carterfone Communications Corp. --
Petition for rejection of tariff revisions or, in the alternative, for
suspension, investigation, and hearing, and for other relief, filed December 2,
1968.
Plessey,
Inc. -- Petition for investigation of tariff Nos. 259, 260, and 263, filed
December 4, 1968.
Marcom,
Inc. -- Supplemental petition to reject certain revisions in tariff No. 263 and
comments on network control signaling, filed December 2, 1968.
Secretary
of Defense (DOD). -- Petition for suspension and investigation of certain
tariff revision in tariff No. 263, filed December 2, 1968.
ACTION! Systems Co. -- Comments on the proposed
revisions in tariff No. 263, filed November 29, 1968.
National
Committee for Utilities Radio (NCUR). -- Supplemental petition for rejection of
certain revisions in tariff No. 263, filed December 3, 1968.
International
Telephone & Telegraph Corp. (ITT). -- Supplemental petition for rejection
in certain tariff revisions or, in the alternative, suspension, investigation,
and hearing, filed November 29, 1968.
Magnavox
American
Trucking Association (ATA). -- Petition to reject certain proposed tariff revisions
in tariff No. 263, filed November 29, 1968.
Business
Equipment Manufacturers Association (BEMA). -- Supplemental petition to reject
certain proposed tariff revisions in tariff No. 263, filed November 27, 1968.
American
Petroleum Institute. -- Comments on proposed tariff revisions and requests for
acceptance of the tariff filing, filed November 27, 1968.
The
American Bankers Association. -- Comments concerning the revisions in tariff
No. 263, filed November 27, 1968.
Western
Data Products, Inc. -- Letter commenting on the proposed tariff revisions,
filed November 22, 1968.
American
Trucking Association, Inc. -- Petitions to reject proposed tariff revisions to
tariff Nos. 259 and 260, filed December 12, 1968.
Magnavox
Business
Equipment Manufacturers Association (BEMA). -- Comments on the proposed
revisions to tariff Nos. 259 and 260, filed December 18, 1968.
Bethlehem
Steel Corp. et al. -- Petitions to reject proposed revisions in tariff Nos. 259
and 260, filed December 17, 1968.
APPENDIX
C
TECHNICAL
CRITERIA FOR ALL TERMINALS AND SYSTEMS CONNECTED BY DIRECT ELECTRICAL
CONNECTION, EFFECTIVE JANUARY 1, 1969
i. The power of the signal at the central
office shall not exceed 12 db below 1 mw when averaged over any 3-second
interval.
ii. The signal at the telephone company
interface located on the customers' premises shall be controlled so that:
1. The power in the band from 3,995 to 4,005 Hz
shall be at least 18 db below the power of the signal as specified in i.,
above.
2. The power in the band from 4,000 to 10,000
Hz shall not exceed 16 db below 1 mw.
3. The power in the band from 10,000 to 25,000
Hz shall not exceed 24 db below 1 mw.
4. The power in the band from 25,000 to 40,000
Hz shall not exceed 36 db below 1 mw.
5. The power in the band above 40,000 Hz shall
not exceed 50 db below 1 mw.
6. The signal shall at no time have energy
solely in the 2450-2750 Hz band and any signal power in such band shall not
exceed the power present at the same time in the 800-2450 Hz band.
APPENDIX
D
TECHNICAL
CRITERIA FOR ALL TERMINALS AND SYSTEMS CONNECTED BY ACOUSTIC OR INDUCTIVE
MEANS, EFFECTIVE JANUARY 1, 1970
i. The power of the signal at the output of the
network control signaling unit shall not exceed 9 db below 1 mw when averaged
over any 3-second interval, and such signal at such output point shall be
controlled so that:
1. The power in the band from 3,995 to 4,005 Hz
shall be at least 18 db below the power of the signal as specified in i.,
above.
2. The power in the band from 4,000 to 10,000
Hz shall not exceed 16 db below 1 mw.
3. The power in the band from 10,000 to 25,000
Hz shall not exceed 24 db below 1 mw.
4. The power in the band from 25,000 to 40,000
Hz shall not exceed 36 db below 1 mw.
5. The power in the band above 40,000 Hz shall
not exceed 50 db below 1 mw.
6. The signal shall at no time have energy
solely in the 2450-2750 Hz band and any signal power in such band shall not
exceed the power present at the same time in the 800-2450 Hz band.
Carterfone
Tariffs
(In the
matter of A.T. & T. "Foreign Attachment" tariff revisions -- Nos.
259, 260, 263)