Draft agreement on coordination between stations in the land mobile service of the Estonia Administration and stations in the aeronautical radionavigation service of the Russian Federation Administration in the frequency band - Vastus

General Radio Frequency Centre Federal State Unitary Enterprise Building 15, 7 Derbenevskaya Embankment 117997 Moscow RUSSIAN FEDERATION Your 03.07.2015 No. MC-1749 Our 13.08. 20 15 No. 18-5/15-0092-022 Draft agreement on coordination between stations in the land mobile service of the Estonia Administration and stations in the aeronautical radionavigation service of the Russian Federation Admin istration in the frequency b a nd 694-790 MHz Dear Sirs, We would like to thank you for the draft Agreement on 700 MHz. Having studied it , we can agr ee to it in general. There are some remarks and questions raised by our mobile operators: As we have relevant CEPT regulation in place we would like to add a reference to it. Add a point before 1.6 “ The frequency arrangement for LMS conforms to the FDD frequency arrangement and parameters of transmission for base and user statio ns in accordance with ECC/ DEC( 15 )0 1 ” . In our opinion it is not feasible to regulate usage of user equipment. In addition, it is difficult to control the requirement. We suggest deleting points 1.3 and 4.9 . Regarding point s 2.1 and 2.2, the BS number per 100 km 2 with in distance up to 100 km from the border causes difficulties to cover towns (especially in Tartu) in sufficient quality. We would suggest excluding the in-building Base Stations and BS in urban areas with antenna height less than 25 m , also we can add obligatory down tilt . The Tables 1 and 2 will still apply. O ther possible option would be to split the 100 km distance in point 2.1 such that beyond 45 km from the border the BS density is not specified anymore and only the Field Strength value thresholds apply. Any other solution to get better indoor coverage within cities is welcome. We would appreciate your opinion on this matter to conclude the Agreement within next months. Yours sincerely, Priit Soom Deputy Director General Head of Electronic Communications Division