GARDNER, CARTON 0. DOUGLAS
1301 K STREET, N. W.
SUITE 900, EAST TOWER
WRITER'S DIRECT DIAL NUMBER
SUSAN H.R. JONES
WASHINGTON, D.C. 20005
FACSIMILE, (202) 289-1504
January 12, 1995
JAN 12 \995
Mr. William Caton
Federal Communications Commission
1919 M Street, N.W.
Washington, D.C. 20554
fEDERAL COMMUNICATIONS COMMISSION
OffiCE OF SECRETARY
OOCKET FILE COpy ORIGINAL
Re: Corrected Page 5 to Comments ofE.F. Johnson Company in CC Docket
No. 94-102, In the Matter of Revision of the Commission's Rules to Ensure
Compatibility with 911 Emergency Calling Systems.
Dear Mr. Caton:
Transmitted herewith, on behalf of E.P. Johnson Company, is a corrected page 5 to its
Comments, submitted in the above-referenced proceeding. In the originally submitted pleading,
footnote 4 was inadvertently noted as "[cite]." This corrected page includes the appropriate
Ifyou should have any questions related to this pleading, please contact the undersigned
counsel, at the direct line noted above.
Susan H.R. Jones
No. of COpies rec'd 0 J J
different services within the wireless industry.4 B.P. Johnson has supported this approach, and
has proposed as a guideline that "local" two-way radio operators lack market power when
compared with frequency reuse, mobile telephone-like systems offered by cellular licensees or
wide-area SMR operators. Typically, "local" operators have only a few channels with an area of
operation defined by their transmitter site.
The scale and scope of such "local" radio operators is smaller than the scale and scope of
broadband wireless communications providers and thus, the costs of providing 911 emergency
compatibility would be a far greater burden to a "local" operator and less easily absorbed into the
operational costs. The costs associated with implementing 911 emergency compatible
equipment for a smaller operator, for example, might drive the cost for basic communications
service prohibitively high.
In addition, the consumer market for the small or "local" SMR operator is significantly
different than the market for broadband CMRS systems. A "local" SMR operator is likely to
serve businesses with two-way radio and dispatch needs, even though interconnection to the
public switched network is permitted through this type of smaller system. Broadband wireless
systems, in contrast, clearly target the individual consumer as a potential customer. This user
views the cellular telephone and other forms ofbroadband wireless services as a mobile
extension of the wireline telephone service. In view of this disparity between the type of
services provided and the customer's expectations regarding that service, the Commission's
expectation that "[w]ireless customers clearly expect access to 911 services, and may be unaware
that their mobile radio services do not provide ... [the same 911 services] as the wireline
4 See Notice of Proposed Rule Making and Notice ofInquiry, In the Matter ofEqual Access and
Interconnection Obligations Pertaining to Commercial Mobile Radio Services, CC Docket No. 94-54, 9 FCC Rcd
5408 (released July I, 1994).