Subject: [NEXTEL-1] E.F. Johnson Company On Interference Immunity Performance ET Docket No. 03-65

From: [email-masked]
Date: Fri, 08 Aug 2003 04:09:08 -0400

Before the FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of

Interference Immunity Performance
Specifications for Radio Receivers ET Docket No. 03-65

COMMENTS OF E.F. JOHNSON COMPANY

E.F. Johnson Company would like to file comments in response to the Notice of
Inquiry in the above captioned proceeding.

E.F. Johnson Company, a subsidiary of EFJ, Incorporated, is a manufacturer of
Private Land Mobile equipment, with offices in Washington, D.C, Lincoln, NE, and
Waseca, MN.  E.F. Johnson has been a manufacturer of radio equipment for 80 years,

with a history of private radio equipment manufacturing for over thirty years.
Currently
our products cover Public Safety systems, as well as Business and Industrial
products.
E.F. Johnson Company?s experience is principally focused on Private Land Mobile
Radio systems.

Therefore, the comments that are offered are directed principally toward those
radio services. Current Private Land Mobile equipment that is on the market
represents some of the highest performing receiver products that are available in
any service.  In many respects, performance this class of product approaches
state-of-the-art.  Although there are multiple tiers of product offered by the
various manufacturers, receiver standards tend to be of a fairly high
specification level throughout.  E.F. Johnson believes that the Private Land
Mobile radio market would not be best served by mandated receiver standards.

We believe that there are several reasons for this.
Competitive pressures within the industry cause manufacturers to focus their
design efforts on product performance.  This marketplace is a highly competitive
one, in
which product performance, including receiver specifications, can be a product
differentiator.  In addition, customers in this marketplace tend to be very
technically
astute, and understand the implications of factors, such as receiver performance.
This
causes manufacturers to focus on receiver performance, and to offer products of
high
standards.  In addition, voluntary industry standards, such as the various
standards
published by the Telecommunications Industry Association (TIA), serve as a minimum

standard for these types of products.  These standards are developed by industry
consensus, and in many cases, have user input in their formulation.  Recent TIA
standards for Private Land Mobile Radio have been updated to include two levels of

specifications, the higher level being recommended for mission critical
communications.
The state of technology is changing rapidly.  Technology improvements that may
result in receiver performance improvements are being made, and will continue to
occur
in the future.  Mandating requirements based on current state-of-the-art may
result in a
stifling of innovation.  Industry standards development organizations, in
contrast, meet
regularly and update their standards periodically.  The result is a standard that
is up-to-
date with current technology.

Many of the receiver standards are interdependent.  In many instances it is
possible to improve a specific performance parameter at the expense of other
performance parameters.  Manufacturers often make decisions on performance
trade-off
when designing equipment.  This is often done with specific applications in mind.
Quite
often, sacrificing some receiver performance parameter may be advantageous if some

other receiver parameter is more desirable.  Mandated specifications may limit the
ability
to design product for specific applications.

Additionally, in many markets, the cost of the highest specification products may
not be justified by the application.  In many sparsely populated areas,
interference may
not be an issue.  In some applications the reliability of the communications may
not be
paramount.  In such applications the availability of less expensive products may
be more
desirable.  As such, the requirements of the market, as opposed to mandated
technical
requirements, may result in more economical products.  Mandated technical
requirements, on the other hand, will tend to drive the cost of equipment higher.
As a result of the above factors, E.F. Johnson believes that mandated receiver
standards are not the most effective way to ensure that interference issues are
minimized,
and that spectrum is efficiently utilized.  We believe that this is best
accomplished by
competitive pressures to provide receivers of the highest standards, along with
the
demands of critical users for interference free operation.  In addition, we
believe that
industry standards, such as the various TIA standards, are effective in setting
minimum
performance standards, while allowing for flexibility for manufacturers to
innovate
performance improvements, or to manage design trade-off issues.

E.F. Johnson Company would like to express its appreciation for the opportunity
to comment on these matters.

Respectfully Submitted,
/S/ John S. Oblak
John S. Oblak
Chief Engineer
E.F. Johnson Co.
299 Johnson Ave, S.W.
July 21, 2003 Waseca, MN  56093

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514286651

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