To all in the NEBS compliance world,
It has recently been stated that Verizon has established a new program, called 
Phase 3 for their ITL program.  This Phase 3 requires that any laboratory that 
would like to submit data for NEBS testing MUST sign up with Verizon for this 
Phase 3 program.  What Verizon is saying is if you want your NEBS data accepted 
by Verizon, you MUST be a part of the Verizon ITL program.  This no longer 
means that a laboratory can have an option to participate in the original ITL 
witnessing program, it is now mandatory to even have any NEBS data accepted by 
Verizon. The extremely high cost to participate in this program will in turn be 
passed on to the manufacturers, which in turn will be passed on to the end user 
(RBOCs).  The program is patently unfair in that it only allows laboratories 
that have the financial resources to participate, but not necessarily those 
labs that have the technical capabilities to participate in the tests.  This 
program will limit the available facilities for manufacturers to test their 
products to the NEBS standards.  What does that do to the price of a NEBS 
program?  Less labs = higher prices.  Simple math, obvious answer.  How can 
test labs that have been submitting data for 15 plus years ALL OF A SUDDEN be 
required to pay a large fee to have NEBS data reviewed?  Suddenly, the NEBS 
data is not acceptable?  Unfortunately, this will put some laboratories out of 
business.  It will also leave labs that have invested hundreds of thousands of 
dollars in equipment to test to the NEBS standards with equipment that is, in a 
lot of cases, NEBS specific.  Now this equipment will be useless, and the 
initial investments lost.  This program FORCES labs to participate, or not have 
their NEBS data accepted by Verizon, which, in my opinion borders on 
restriction of trade.  There is no apparent justification for the fees and 
commissions other than Verizon creating a revenue source for themselves at the 
expense of the test laboratories, equipment manufacturers and other operating 
companies.  To my knowledge, no other RBOC or independents has entertained the 
idea of this type of program, nor has supported it to date.  If Verizon moves 
forward with their program, it is the telecommunications industry that will 
become the losers as greater costs for tests will be passed on to equipment 
manufacturers and service providers, while shutting the doors for smaller 
capable test laboratories with no benefit to anyone.  Are these labs really 
ITL's anymore, or VTL's........?  
Don Bennett
Director of Telecom Compliance
Garwood Laboratories
7829 Industry Ave.
Pico Rivera, CA 90660
Ph: 562-949-2727
Fax: 562-949-8757
www.garwoodtestlabs.com

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