COAI’S PROPOSAL FOR REVIEW OF DRAFT NFAP –2005

Remarks / Current Provisions / COAI’s Proposal
IND 30 / Induction of wireless access systems (fixed/mobile) telecommunication services may be considered for coordination on case by case basis in the frequency band 450.5- 457.5 MHz paired with 460.5- 467.5 MHz. / As frequency band 450-470 MHz is identified for IMT applications during WRC-07, therefore it should be earmarked for IMT applications.
IND 31 / Requirement of link frequencies for Radio Paging Service will be coordinated in the band 450-470 MHz. /

To be deleted

IND 32 / The frequency spots 461.775, 461.825, 461.875, 461.925, 461.950 MHz are earmarked for Radio Paging Systems for on-site uses only / To be deleted
IND 33 A / Additional Note:
585-698 MHz-be earmarked for Mobile TV.
698–806 MHz – be earmarked for IMT applications (As WRC-07 has identified)
IND 33 B
IND 35 / Frequency band 806-811 MHz paired with 851-856 MHz has been earmarked for mobile trunked radio system to be used predominantly for captive networks. The requirements for public mobile radio trunked systems (PMRTS), which cannot be met in other bands, may also be considered in this band / It is understood that presently these bands are being used by Police/NSG etc. for PMRTS application, predominantly for captive/public networks.

No Comments

IND 36 / Frequency bands 811-814 MHz paired with 856-859 MHz has been earmarked for spectrum efficient digital public mobile radio trunked systems (PMRTS) and captive mobile radio trunked systems
IND 37 / Frequency band 814-819 MHz paired with 859-864 MHz has been earmarked for mobile radio trunked systems to be used predominantly for public mobile radio trunked systems (PMRTS).
IND 38 / Requirement of public mobile radio trunked systems (PMRTS) and captive mobile radio trunked systems may also be considered, as appropriate, in the frequency bands 819-824 MHz paired with 864-869 MHz.
IND 51 / Requirements of IMT-2000 (3G) applications in the frequency bands 1885-2025 MHz paired with 2110-2200 MHz may be coordinated with existing users initially for 1920-1980 MHz paired with 2110-2170 MHz (FDD mode) and 2010-2025 MHz (TDD mode) depending on the market needs and availability, as far as possible. / As decided in WRC-07, IMT-2000 (3G) now be replaced by “IMT” in the draft NFAP.
To be Deleted: depending on the market needs and availability, as far as possible
IND 51 A / Requirement of Deep Space Research operations in the frequency bands 2110-2120 MHz (uplink) and 2290-2300 MHz (downlink) may be considered at Bangalore, Lucknow, Sriharihota and Portblair locations. / It is to be noted that IND 51A proposes to use the frequency band 2110-2120 MHz in the uplink at some locations, which is overlapping with the downlink of IMT-2000 band. Accordingly, vide letter no. TVR/COAI/112 dated 24th June 2005, we had requested that DOS be advised to provide necessary inputs on the interference parameters, output radiated power etc. for coexistence. The required details are still awaited.
It is once again reiterated that in line with our earlier request, that this proposal would prima facie impair the cellular services in the IMT band. It is also recommended that DOS should be advised accordingly.
IND 52 / DELETED / Additional Note: As frequency band 2300-2400 MHz is identified for IMT applications during WRC-07, therefore it should be earmarked for IMT applications
IND 53 A / Additional Note: As frequency band 2500-2690 MHz is identified for IMT applications, therefore the band 2500-2690 MHz should be harmonized and earmarked as an extension band for terrestrial 3G systems.
IND 55 A / Use of low power equipments for Wireless Access Systems including Radio Local Area Networks, in the frequency band 5.150-5.350 GHz and 5.725 – 5.875 GHz using a maximum mean Effective Isotropic Radiated Power of 200 mW and a maximum mean Effective Isotropic Radiated Power density of 10 mW/MHz in any 1 MHz bandwidth, for the indoor applications has been delicensed.
(G.S.R 46(E), Dated 28th January, 2005)
IND 56 / Requirements of microwave multipoint distribution system (MMDS) and local multipoint distribution system (LMDS) may be considered in the frequency band 3.3 – 3.4 GHz on a case-by-case basis / The frequency band 3.3-3.4 MHz is earmarked to Broadband Wireless Access (BWA)
IND 57 /

DELETED

/ Additional Note: As frequency band 3400-3600 MHz is identified for IMT applications during WRC-07, therefore it should be earmarked for IMT applications
IND 64 / Requirement of public protection and disaster relief (PPDR) communications may be considered in the frequency bands 380-400 MHz, 406.1-430 MHz, 440-470 MHz, 746-806 MHz, 806-824/851-869 MHz, 4940-4990 MHz and 5850-5925 MHz on a case by case basis depending on specific need and equipments availability, as far as possible / As 698-806 MHz is earmarked for IMT application, therefore the band 746-806 MHz which is part of 698-806 should be deleted from the PPDR applications
Also the roadmap/ requirement of bandwidth for PPDR communications for all the bands should be made available.

TRD/COAI/020

10 March 2008

Shri P.K Garg,

Wireless Advisor,

Department of Telecommunications,

WPC Wing,

Sanchar Bhawan,

New Delhi- 110001

Dear Sir,

Subject: COAI’s Views/Comments for Review of NFAP-2005

This is with reference to our Letter No. TRD/COAI/018, dated 03rd March, wherein we had submitted our comments for the review of National Frequency Allocation Plan, pursuant to WRC-07 decisions. In continuation of the same, please find below our further comments.

Sir, as you are aware that the band 880-890 MHz paired with 925-935 MHz, commonly known as eGSM band (extended-GSM band), is globally used by Service Providers to offer GSM based mobile services. Even, all the GSM equipments manufactured worldwide operate in this band.

In India, however, a part of this band has been incorrectly and inadvertently earmarked for WLL CDMA applications and is now used /earmarked for CDMA based mobile services.

COAI and GSM operators have been making repeated submissions to the DoT to re-farm this band /spectrum and make it available for GSM based mobile services, as all the equipments that have been imported and are being used by the Indian GSM operators since 1994 are already attuned to offer mobile services in this band.

It is pertinent to note that these submissions have been made by the GSM industry before the High Level Committee set up by DoT in 2003 and also at various NFAP meetings.

It is important to note that despite repeated requests made by COAI and GSM operators, this band has still not been refarmed and is earmarked for CDMA based services.

We would also like to submit that the availability of eGSM band to the current existing GSM operators becomes all the more important, keeping in view the scarcity of the GSM spectrum being currently faced by the existing GSM operators.

In view of the above, we therefore request to kindly earmark the band 880-890 MHz and 925-935 MHz to the existing GSM operators for GSM Cellular services and make suitable amendments in the NFAP-2005 document to be reviewed.

We hope that our submissions would merit your kind consideration.

Thanking You,

Sincerely,

T R Dua,

Senior Director

Cc : Dr. Ashok Chandra, Joint Wireless Advisor (PP)

: Shri R. J. S. Kushvaha, Joint Wireless Advisor (LIC), DoT