Koordinatsioon

Mr Andrey Katkov General Radio Frequency Centre Your Ref: 16.02.2021 No МС-294 Building 15, 7 Derbenevskaya Our Ref: 27.05.2021 No 17-6/2021/0971 Embankment 11.09.2020 No 17-6/2020/1801 117997, Moscow RUSSIAN FEDERATION Coordination of frequency assignments for land mobile service Dear mister Katkov After reviewing your reply to our coordination request, we hereby ask you for some clarifications concerning the following issues: 1. Please clarify why regardless of the assigned frequency the coordination answer for frequency assignments was the same (coordinated or not coordinated). Russian Federation FX frequency assignments in MIFR show that the frequency bands 3400-3450 MHz and 3500-3550 MHz are more used near the border and frequency bands 3450-3500 MHz and 3550-3600 MHz are less used. Coordination results should have been more favourable in those parts of frequency band where there are fewer stations notified in MIFR. 2. Please clarify whether the antenna directivity was taken into account in calculations? According to our estimations for example RAPLA (EST3410RAPLA, antenna azimuth 180 degrees) or PAIDE (EST3410PAIDE antenna azimuth 200 degrees) antenna direction and beamwidth should not cause interference to the frequency assignments of Russian Federation. For clarification, the antenna parameters are: horizontal beamwidth 65°, vertical beamwidth 13°, front-to-back ratio 25 dB, downtilt -2 degrees. 3. We are of the opinion that since the Agreement between the Telecommunications Administrations of the Russian Federation and the Republic of Estonia concerning the use of the 3400-3600 MHz frequency band by the Broadband Wireless Access systems in the border areas (Moscow, 2010) covers only BWA systems and does not cover mobile systems, than the border conditions specified in ITU RR footnote 5.430A is more adequate for estimation of the impact of mobile systems with respect to FS and FSS stations in neighbouring countries. Therefore, in lack of an agreement that covers coordination of mobile services in the frequency band 3400-3600 MHz, we see the border conditions in footnote 5.430A as the proper ones. Application of the pfd limit specified in FN 5.430A for the protection of FS and FSS stations is also specified in 3.8 of section B6 of ITU Rules of Procedure. Considering the above-mentioned, we see an overestimation of interference probability to frequency assignments of Russian Federation. We kindly ask for your clarifications and re- evaluation of your findings to our coordination request. We also would be grateful for any calculation examples of your findings for comparison purposes. In addition, we agree that the discussions concerning the coordination criteria for stations in radiocommunication services in the frequency band 3400-3600 MHz at the next meeting between Endla 10a / 10122 Tallinn / ESTONIA Phone: +372 667 2000 / Fax: +372 667 2001 / E-mail: [email protected] / http://www.ttja.ee the Telecommunication Administrations of the Russian Federation and the Republic of Estonia are essential for protection of the existing stations and development of new applications in both countries. Yours sincerely, (signed digitally) Erko Kulu Head of Frequency Management Division Endrik Kriisa +372 667 2131 [email protected] 2 (2) Mr Andrey Katkov General Radio Frequency Centre Your Ref: 16.02.2021 No МС-294 Building 15, 7 Derbenevskaya Our Ref: 27.05.2021 No 17-6/2021/0971 Embankment 11.09.2020 No 17-6/2020/1801 117997, Moscow RUSSIAN FEDERATION Coordination of frequency assignments for land mobile service Dear mister Katkov After reviewing your reply to our coordination request, we hereby ask you for some clarifications concerning the following issues: 1. Please clarify why regardless of the assigned frequency the coordination answer for frequency assignments was the same (coordinated or not coordinated). Russian Federation FX frequency assignments in MIFR show that the frequency bands 3400-3450 MHz and 3500-3550 MHz are more used near the border and frequency bands 3450-3500 MHz and 3550-3600 MHz are less used. Coordination results should have been more favourable in those parts of frequency band where there are fewer stations notified in MIFR. 2. Please clarify whether the antenna directivity was taken into account in calculations? According to our estimations for example RAPLA (EST3410RAPLA, antenna azimuth 180 degrees) or PAIDE (EST3410PAIDE antenna azimuth 200 degrees) antenna direction and beamwidth should not cause interference to the frequency assignments of Russian Federation. For clarification, the antenna parameters are: horizontal beamwidth 65°, vertical beamwidth 13°, front-to-back ratio 25 dB, downtilt -2 degrees. 3. We are of the opinion that since the Agreement between the Telecommunications Administrations of the Russian Federation and the Republic of Estonia concerning the use of the 3400-3600 MHz frequency band by the Broadband Wireless Access systems in the border areas (Moscow, 2010) covers only BWA systems and does not cover mobile systems, than the border conditions specified in ITU RR footnote 5.430A is more adequate for estimation of the impact of mobile systems with respect to FS and FSS stations in neighbouring countries. Therefore, in lack of an agreement that covers coordination of mobile services in the frequency band 3400-3600 MHz, we see the border conditions in footnote 5.430A as the proper ones. Application of the pfd limit specified in FN 5.430A for the protection of FS and FSS stations is also specified in 3.8 of section B6 of ITU Rules of Procedure. Considering the above-mentioned, we see an overestimation of interference probability to frequency assignments of Russian Federation. We kindly ask for your clarifications and re- evaluation of your findings to our coordination request. We also would be grateful for any calculation examples of your findings for comparison purposes. In addition, we agree that the discussions concerning the coordination criteria for stations in radiocommunication services in the frequency band 3400-3600 MHz at the next meeting between Endla 10a / 10122 Tallinn / ESTONIA Phone: +372 667 2000 / Fax: +372 667 2001 / E-mail: [email protected] / http://www.ttja.ee the Telecommunication Administrations of the Russian Federation and the Republic of Estonia are essential for protection of the existing stations and development of new applications in both countries. Yours sincerely, (signed digitally) Erko Kulu Head of Frequency Management Division Endrik Kriisa +372 667 2131 [email protected] 2 (2)