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