I have read several news group articles and mail list articles about relocating smartjacks. Most say it can not be done because of FCC regulations.
Can someone point me to the specific regulation that prevents the phone company from locating the smartjack where I want it?
I would like to know if it even exists, and if so what exceptions are granted.
Michael Potter snipped-for-privacy@gmail.com
I can't cite the specific FCC regulation but it does exist and has to do with what is called the "Rate Demarcation Point" (RDP) for regulated services delivered by Telcos in the US.
In general, the RDP shall be located at the "minimum point of penetration" (MPoP) or "minimum point of entry" (MPoE) to the premesis.
The purpose of the RDP is to establish a clear separation of what cable/equipment/wiring is regulated and therefore the responsibility of the Telco and what is deregulated and therefore not directly the responsibility of the Telco (even if Telco installed it years and years ago - think "house cable").
If the premesis has an existing RDP, the smartjack will be located there so that the Telco can easily establish (via remote testing) if the circuit is performing properly all the way up to the RDP. If the smartjack is located some place *past* the RDP and is connected via house cable or customer provided wire (this is called interpositioning) then remote testing can't clearly and reliably prove that everything is OK to the RDP since the unit that allows for remote testing (the Smartjack) isn't collocated at the RDP any more.
The only exceptions that I have seen are grandfathered installations where the original "phone room" was someplace other that the MPoP. These are usually older buildings. Some larger companies will *pay* to have a special RDP installed in their space in the building. It's very expensive but can be done. It won't be done for a single circuit. Let's say you are a major customer with a large data center. The regular RDP is all the way on the other side of the very large multi-tennant building. You can pay the Telco to design and build an additional RDP right in your data center. But you'd probably have to have dozens and dozens of circuits to make it financially worthwhile.
Just exactly what is the reason you want the Smartjack moved, anyway??
John
-- John P. Dearing A+, Network+ To reply: Just drop "YOURPANTS" in my address! 8-)
go here:
I used to be able to cite the exact reference, but it has been many years since I have had the need. Buried in Part 68 is a reference for imbalance testing if the lines between the registered device and the telco interface are more than 25 cable feet apart. This is the paragraph that also states the LEC is required to install their interface at the point designated by the customer.
Now, I only used this for new installs, and I believe if you want an existing smartjack moved, then you will have to pay for it.
Rodgers Platt
As Reed already posted in this thread, that regulation is in 68.105 - but note that it is permissive for the telco - they _may_ adopt a policy of placing them at the MPoE, but don't have to. (If they don't, other rules apply, but the customer or building owner has some say in some cases too.)
As usual, most telcos teach their employees that the rules "require" them to do what they have _chosen_ to do.
However, as you say, for this issue, it usually makes sense to do it that way, since if the RDP is dependent on house cable, it doesn't really work to isolate trouble as between telco and customer.
When I was the network ops manager for a university that had spaces in several multi-building sites, we used to do this routinely, in cases like your data center example, or simply to keep the RDP in the same place as where we wanted to put our switch room. The PacBell/SBC terminology was "establishing a secondary MPoE", and they even had little plastic tags that indicated the designation to their people. And it isn't always expensive - depends on the relationship between the telco and the customer. In our case, they were always angling for a bigger share of high-profit services than we ever gave them, and I generally had good account teams, so they never charged anything at all that I remember.
Actually, in new installations, quite often _we_ installed the cable to the RDP location, and even made the cross conns to the street cable, in coordination with their "special projects" people. Very useful when trying to do a sizable cutover on a precise timeline, but probably way _more_ flexibility than the rules ever intended! ;)
But the odds of a small customer getting the same flexibility through "official" channels is pretty small - just negotiating with the installer who comes out probably has a better chance, if there is a good reason the original poster wants to do this in a particular case.
Regards,
Don Miller
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