While Donna Ballast takes a break this month (her first since she began writing for us in 1994), we bring you this column that she penned last year and remains timely today.
Q: In May 2000, Cabling Installation & Maintenance published an article stating that the FCC had passed a ruling that requires a minimum of Category 3 cable to be installed ("Category 3 minimum FCC-approved for all new copper-cabling installations," May 2000, page 119). I would like to know just what installations this is for. I see old POTS "CMX" station wire being installed in new homes. I spoke to a Verizon installer, who told me they are still using station wire, not Cat 3, for their residential installations.
I would like to know who is enforcing the standard. I brought this FCC ruling to one of our IAEI (International Association of Electrical Inspectors) meetings, and none of the electrical inspectors had heard of it. Is it time to make a proposal to the National Electrical Code for the next Code cycle?
A: A complete answer to this question requires consideration of the rule's applicability, enforcement, rationale, and implications.
To what installations is the minimum Category 3 rule applicable? The simple ones. You see, in FCC speak, "simple inside wiring" equals residential cabling and "complex wiring" equals commercial cabling.
FCC Part 68 governs the interconnection of customer premises equipment (CPE) and its associated wiring with the public switched telecommunications network (PSTN). CPE is equipment, such as telephones, faxes, modems, etc., operating on a customer's premises to originate, route, or terminate telecommunications over the network.
Part 68 sets standards to ensure that the connection of CPE to the network will not cause harm to the network, such as electrical hazards to telephone-company personnel and equipment, malfunctioning of billing equipment, and the degradation of telecommunications services to third parties.
In 1984, the Commission adopted Section 68.213 to permit telecommunications subscribers and premises owners to install and connect telecommunications equipment and inside wiring to the network.
In 2000, the Commission adopted Section 68.21(c to require that simple inside wiring be, at a minimum, solid, 24-gauge or thicker, twisted pairs, marked to indicate compliance with the electrical specifications for Category 3, as defined in the ANSI/TIA/EIA Building Wiring Standards.
Clearly, anyone installing anything less is in violation of FCC Part 68.213(c.
The Federal Communications Commission (FCC) is the primary organization responsible for enforcement of the provisions of the Communications Act and the FCC's implementing rules.
The FCC has the authority to investigate possible rule violations and to take enforcement action, if warranted. But the FCC does not have the authority to take criminal action against those who violate the Communications Act, referring cases warranting criminal prosecution to the U.S. Justice Department.
The FCC has an Enforcement Bureau, which as four divisions:
- The Telecommunications Consumer Division, responsible for enforcement regarding consumer-related obligations of common carriers;
- Market Disputes Resolution Division, responsible for resolution of complaints against common carriers (wireline, wireless, and international);
- Investigations and Hearings Division, responsible for resolution of complaints and enforcement involving broadcast stations on non-technical matters;
- Technical and Public Safety Division, responsible for resolution of complaints and enforcement involving public safety, and technical issues such as tower marking and lighting, equipment requirements, Emergency Alert System rules, and unauthorized construction and operation.
So, why the change?
It is interesting to note that none of these four divisions address the residential cabling issues, beyond suggesting that the consumer sue the builder or contractor for damages, making the consumer the "cable police."
According to the Commission, they drafted the "Inside Wiring Quality Standard" to "encourage builders to install quality inside wiring to ensure that consumers will continue to have access to widely available communications services." They understood that poor-quality, non-twisted-pair inside wiring can cause network harm in the form of "crosstalk," resulting in a loss of privacy, interference with digital transmission, and disruption of telephone conversations.
Building contractors and developers generally select telecommunications wire long before the homebuyer has entered the picture, allowing builders to choose lower cost over quality for simple inside wiring.
The homeowners become aware of the problem only when they attempt to install an additional line or when they experience audible crosstalk, which is often too late to seek damages from the builder or contractor.
The original argument presented to the Commission by BICSI, and supported by many carriers, centered on the issue that homebuyers are shut out of the inside wire selection process; but, all too often, it is the homeowner who "foots the bill" to correct the problems created by the building contractor's poor choice of wiring. Now homeowners get to choose—between paying for the recabling and paying for the litigation.
The carriers, who were the ones rolling the trucks to take care of countless trouble reports, were well served by the "Inside Wiring Quality Standard." If a carrier determines that inside wiring is not conforming to the FCC inside wiring quality requirements, they are to notify the customer of the problem and can temporarily disconnect or refuse to connect inside wiring or CPE that is likely to cause harm to the network. Their problem is resolved.
Regulations, standards, and codes
I remember well the old saying, "You get what you inspect, not what you expect." And it is certainly true when it comes to telecommunications cabling installed in both commercial and residential buildings. But the NEC deals with safety from fire, smoke, and electrical shock. What we are talking about is a performance issue—one that clearly has landed in the lap of the consumer.
For anyone who thinks the FCC rules are being followed and sufficiently enforced, I challenge you to contact your local cabling distributor and ask for Category 3, 5, 5e, or 6 cable that is marked as such every foot. Why? This is also a requirement of Part 68.213(c, and I have yet to find a distributor stocking such a cable.
Back in 2000, the FCC "envisioned" that the building code folks, such as the Building Officials Code Administrators (BOCA), the International Conference of Building Officials (ICBO), and the Southern Building Code Congress International (SBCCI), would take the initiative and write the cabling requirements into their building codes. It is my personal opinion that this can only be accomplished by having the local building codes require compliance similar to the FCC Part 68.213 (c. Why? FCC regulations are universally applicable in all 50 states, but there are no compliance inspections or anyone even raising an eyebrow without a formal complaint. Codes and standards are only applicable when adopted by a municipality or cited in contract documents, yet there are inspectors for each trade.
For a review of the complete "Third Report and Order on Review of Section 68.104 of the Commission's Rules Concerning Connection of Simple Inside Wiring to the Telephone Network and Petition for Modification of Section 68.213 of the Commission's Rules filed by the Electronic Industries Association," see the following Internet site: http://ftp.fcc.gov/Bureaus/Common_Carrier/Orders/1999/fcc99405.doc.
DONNA BALLAST is BICSI's standards representative, and a BICSI registered communications distribution designer (RCDD). Send your questions to Donna via e-mail: firstname.lastname@example.org