For Immediate Release
ATIS 1200 G Street, NW Suite 500 Washington, DC 20005	Contact: Trish Gessner Phone: 202-434-8851 E-mail: tgessner@atis.org www.atis.org

Standards and Technical Planning Organization Supports BellSouth’s Petition Involving Non-Intelligent Network Elements

March 3, 2005, Washington – ATIS filed comments on behalf of its Network Reliability Steering Committee with the Federal Communications Commission (FCC) Wednesday in support of BellSouth’s petition that the reporting of outages involving non-intelligent network elements should not be based on the Commission’s “user-minute” metric.

“Applying the user minute threshold to non-intelligent network elements would do little to augment the accurate assessment of outages, while burdening the industry with substantial costs and lost productivity,” said ATIS President & CEO Susan M. Miller.

In August 2004 the FCC released the Report and Order (R&O) New Part 4 of the Commission’s Rules Concerning Disruptions to Communications (ET Docket No. 04-35), which revised and expanded its communications outage reporting requirements. The new outage reporting metric is based on the number of “user minutes,” defined as the duration of the outage as expressed in minutes multiplied by the number of users potentially affected by the outage.

ATIS supports BellSouth’s position that the inclusion of outages involving non-intelligent network elements, such as feeder cables and digital loop carrier (DLC) systems, in the FCC’s “user-minute” outage reporting metric will present an undue burden on communications companies. ATIS also supports BellSouth’s alternative recommendation that these outages be reportable only if they affect 600 or more cable or derived pairs and last longer than five calendar days after discovery.

Since non-intelligent elements are passive in nature and incapable of electronic failure, BellSouth and other carriers would have to manually determine the number of assigned/working numbers affected by the outage of such elements – literally sorting through thousands of “false positives” to discover a few reportable events.

About ATIS
ATIS is a technical planning and standards development organization that is committed to rapidly developing and promoting technical and operations standards for the communications and related information technologies industry worldwide using a pragmatic, flexible and open approach. Participants from more than 350 communications companies are active in ATIS’ 22 industry committees and its Incubator Solutions Program. www.atis.org

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