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Declaratory Rulings Filed at FCC to Improve MDU Inside Wiring Rules
IMCC has filed four letters asking that the FCC to make Declaratory Rulings to clarify the intent and implementation of the MDU Inside Wiring Rules adopted in 1997. Franchised cable companies have abused the rules and endeavored to frustrate MDU owners who which to utilize the rules to contract with PCOs and other alternative providers. For example, franchised cable companies have said the unit-by-unit wiring rules do not apply in states with mandatory access statutes. They also have tried to tell MDU owners that even if the MSO is not using the inside wiring for video distribution because the Right of Entry Agreement has expired, the MDU owner can not follow the rules and allow a PCO to utilize the home run wiring because the MSO "intends" to use the wiring for other telecommunications services in the future.
In March of 2003, the FCC published the IMCC letters and requested public comment. It is hoped the FCC will act promptly and adopt the IMCC position in each instance. One of the letters has already been adopted by the FCC. That issue was expanding the definition of "physically inaccessible" in the MDU Inside Wiring Rules to include wiring that is behind sheetrock/plaster board when it exits the residential unit. By adopting this view, the demarcation point is not 12 inches outside the residential unit, but is moved to the lock box or other place where the wiring becomes dedicated to the individual unit.
The four IMCC letters requesting Declaratory Rulings follow: (also see issue entitled MDU Inside Wiring)