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					    Response to RA consultation on "Disclosure of wireless telegraphy licence
              information on radio frequency and assignment use"

Dear Mr Redwin,

Aegis Systems Ltd is pleased to be able to provide the following comments on the
Radiocommunications Agency's consultation on the "Disclosure of wireless telegraphy licence
information on radio frequency and assignment use".

Our interest in this issue derives from the fact that we provide services relating to spectrum
engineering, frequency management and radio regulatory issues to a wide range of commercial and
government clients around the world. Our activities therefore include a significant amount of work
concerning the coexistence of radio systems, including co-ordination between system operators.

Historically, worst-case assumptions regarding system parameter values have been made in co-
existence analyses. The current demand for spectrum is such that there have been moves away from
this approach to a more real-world approach that takes account of actual systems rather than
hypothetical systems constructed around worst-case assumptions. The real-world approach allows for
a more intensive use of the spectrum but depends entirely on the availability of technical data
associated with operational systems. In general therefore we would support the proposed availability
of system data in the public domain, whether provided over the Internet or on CD-ROM.

If system data is to be made available, it would be useful to provide it in a format that can be directly
processed, such as XML (with associated schema), and to include more detail than is currently
available on "Sitefinder". For example, link characteristics relating to interference analyses should also
be included (e.g. antenna gain patterns). We recognise that on occasion the provision of exact location
information must be withheld. However, we suggest that such instances be kept to a minimum as the
availability of this information is valuable in facilitating a more intensive use of the spectrum, for
example by allowing terrain characteristics to be taken into account during interference analyses. For
the purposes of such analyses the availability of system operator names and contact information is not
entirely necessary if the technical data is complete.

We would be happy to discuss these comments further if required and would be pleased to support the
Radiocommunications Agency in progressing this issue.

Yours sincerely,

Paul Hansell

Managing Director, Aegis Systems Ltd

          Aegis Systems Ltd, 30 Anyards Road, Cobham, Surrey KT11 2LA, UK


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