Thread Subject: Updated list of 255 covered products and services

Return to this mailing list's archives

From: BLACKLER, ELLEN (ATTSI)
Date: Wed, Dec 19 2007 7:40 AM
Subject: Updated list of 255 covered products and services

Below (and attached) is an update to the list of things covered by
section 255 to reflect the clarifications we discussed on the last call.
Karen Peltz Strauss has also reviewed.







Background on Things Covered by Section 255 Rules

(Updated December 19, 2007)



I. Entities Covered by Section 255



There are seven distinct categories of products and services covered by
the Section 255 rules. They are:



1. Any provider of telecommunications services (47 CFR 6.1)



* Definition of Telecommunications Service is from the 1996
Telecom Act - essentially it is "offering telecommunications for a fee
to the public"



2. Any manufacturer of telecommunications equipment or customer
premises equipment ( 47 CFR 6.1)



* Definition of Telecommunications equipment- telecommunications
equip is equipment used by a carrier to provide telecommunication
service
* CPE - equipment employed on the premises of a person other than
a carrier to originate, route or terminate telecommunications.



3. Any telecommunications carrier (47 CFR 6.1)



4. Any provider of interconnected VOIP service (47 CFR 6.1)



* The FCC has established a 4 part definition of interconnected
VOIP. Interconnected VOIP is a service that:

(i) Enables real-time, two-way voice communications;

(ii) requires a broadband connection from the user's location;

(iii) requires internet protocol-compatible customer premise equipment
(CPE);

(iv) permits users generally to receive calls that originate on the
public switched telephone network and to terminate calls to the public
switched network.



Note: The definition of interconnected VOIP does not depend on whether
the service is offered for a fee. The definition does include the
ability both to terminate and to originate calls on the PSTN. For
example, the FCC has determined that neither SKYPE, SKYPE IN or SKYPE
OUT meets the definition at this time.



5. Any manufacturer of equipment or CPE specifically designed to
provide interconnected VOIP (47 CFR 6.1)



6. Any provider of voicemail or interactive menu service (part 7.1)



7. Any manufacturer of telecommunications equipment or CPE which
performs a voicemail or interactive menu function. (part 7.1)



II. Covered Functions



1. Part 6.11 and 7.11 Information, documentation and training



"Manufacturers and service providers shall ensure access to information
and documentation it provides to its customers, if readily achievable.
Such information and documentation included user guides, bills,
installation guides for end-user installable devices, and product
support communications, regarding both the product in general and the
accessibility features......"





2. "An entity the provides both telecommunications services and
non-telecommunications services, however, is subject to section 255 only
to the extent that it provides a telecommunications service" (September
1999 255 Order, paragraph 80.)



3. "In connection with multipurpose equipment, we adopt our tentative
conclusion that CPE is covered by section 255 only to the extent that it
provides a telecommunications function." (September 1999 255 Order,
paragraph 87)