light deployment regime for small-area wireless access

FR

Digital

Single

Market

Light Deployment Regime for Small-Area

Wireless Access Points (SAWAPs)

FINAL REPORT

A study prepared for the European Commission

DG Communications Networks, Content & Technology by:

This study was carried out for the European Commission by

Authors: Simon Forge, Robert Horvitz, Colin Blackman and Erik Bohlin

3 December 2019

This report is for use by the European Commission services

Cover image: Small cell installation in Amsterdam, reproduced by permission from

JCDecaux

Internal identification

Contract number: 2016/S 132-237123

SMART number: 2018/0017

DISCLAIMER

By the European Commission, Directorate-General of Communications Networks, Content & Technology.

The information and views set out in this publication are those of the author(s) and do not necessarily reflect the official opinion of the Commission. The Commission does not guarantee the accuracy of the data included in this study. Neither the Commission nor any person acting on the Commission’s behalf may be held responsible for the use which may be made of the information contained therein.

ISBN 978-92-76-13357-5

doi: 10.2759/508915

© European Union, 2019. All rights reserved. Certain parts are licensed under conditions to the EU.

Reproduction is authorised provided the source is acknowledged.

Smart 2018-0017 Light Deployment of SAWAPs

SCF Associates Ltd 1

Contents

Terminology Used in the Report ............................................................................................. 4

Executive Summary .............................................................................................................. 6

Abbreviations ..................................................................................................................... 12

1. Developing a Lightweight Regulatory Regime for Small Cells ............ 16

1.1 The Context for the Study ......................................................................................... 16

1.2 The European Electronic Communications Code .......................................................... 19

1.3 Small Cell Regulation Today ...................................................................................... 25

1.4 The Study Methodology ............................................................................................ 32

2. Current Regulation of SAWAP Deployment in the EU Member States . 34

2.1 Permits and Exemptions ........................................................................................... 34

2.2 Time and Cost ......................................................................................................... 42

2.3 An Alternative to Permits: Notification ....................................................................... 45

3. International and Non-EU Small Cell Initiatives ................................ 47

3.1 International Initiatives ............................................................................................ 47

3.2 Practices in Selected Countries .................................................................................. 50

3.3 Summary ................................................................................................................ 61

4. Lessons from EU and Non-EU Countries ............................................ 62

4.1 Key Country Models ................................................................................................. 62

4.2 Advantages and Disadvantages of Potential Models .................................................... 67

4.3 Elements of a Harmonised “Light Regulation” Model for the EU .................................... 69

5. Shaping a Light Regulatory Regime .................................................. 72

5.1 Practical Recommendations....................................................................................... 72

5.2 An EU-wide exemption procedure .............................................................................. 72

5.3 Satisfying Aesthetic Requirements ............................................................................. 73

5.4 Emission Power Limits .............................................................................................. 78

5.5 Adapting RF EMF Limits to 5G ................................................................................... 90

5.6 SAWAPs under IEC E2 and E10 ................................................................................. 93

5.7 Gaining Planning Authority Exemption ....................................................................... 95

6. Recommendations for the Implementing Act .................................... 97

6.1 A Minimalist Approach .............................................................................................. 97

6.2 Selecting the Level of Emitted Power for Beamforming SAWAPs ................................... 99

6.3 Precedents for Power Levels .................................................................................... 100

6.4 The Possibility of a Higher Power Small Cell ............................................................. 101



6.5 Physical Size for a Standalone Outdoor SAWAP Unit .................................................. 102

6.6 Aesthetics: SAWAP Integration with the Visual Environment ...................................... 103

6.7 Limits on Permit Exemption .................................................................................... 104

7. Additional Recommendations Beyond the Implementing Act .......... 106

7.1 Technical Type-Approval to Accelerate Network Rollout ............................................. 106

7.2 The Need for Notification ........................................................................................ 107

7.3 Location Databases for Planning SAWAP Deployment ................................................ 108

7.4 The Responsibility of Member States for RF EMF limits .............................................. 109

7.5 Automated Monitoring Systems for the RF EMF Environment ..................................... 109

7.6 R&D on RF EMF Exposure and Measurement ............................................................ 110

7.7 Training Programmes to Support Installation ............................................................ 111

7.8 Cybersecurity for SAWAPs ...................................................................................... 112

Bibliography ..................................................................................................................... 114



Figures

Figure 1.1 LTE coverage and mobile broadband penetration in the EU .............................. 16

Figure 1.2. Slowing mobile data growth per SIM, 2017-2018 .......................................... 17

Figure 1.3. Cellular generation and data traffic offloading rates ....................................... 18

Figure 1.4. Two possible configurations for indoor SAWAPs ............................................ 28

Figure 1.5. Unaesthetic small cell installations in South Korea and the USA ...................... 29

Figure 1.6. Finalist designs in Helsinki’s 5G SAWAP design competition (2018) .................. 30

Figure 3.1. Product installation classes from IEC 62232:2017-08 .................................... 48

Figure 3.2. Annual capital investments in 5G in China – two estimates ............................. 52

Figure 3.3. A co-located cluster of different small cell designs in China ............................ 52

Figure 3.4. Resources to deploy a national wholesale 5G network in the USA .................... 60

Figure 5.1. The three phases of EU SAWAP exemption process from approvals .................. 73

Figure 5.2. Decision tree for assessing visual impacts .......................................................... 73

Figure 5.3. European SAWAP design competition with two classes ................................... 74

Figure 5.4. Examples of hiding SAWAPs in plain sight .................................................... 76

Figure 5.5. Limit measurement inconsistencies due to parameter changes at 3-10 GHz ...... 82

Figure 5.6. Adaptive beamforming in 5G ..................................................................... 84

Figure 5.7. Comparing SAR for 4G and 5G handsets ...................................................... 87

Figure 5.8. Uplink and downlink RF exposure levels for LTE, indoors and outdoors ............. 89

Figure 5.9. Exclusion zones and the impact of frequency limits on range .......................... 91

Figure 6.1. Outdoor to indoor via beam connection from external SAWAP ....................... 103

Tables

Table 1.1 Mobile data traffic in Europe (petabytes per month) ........................................ 17

Table 2.1. Local permits needed to deploy base stations (exemptions omitted) ................. 35

Table 2.2. Small cell permit exemptions ...................................................................... 36

Table 2.3. Parameters used to grant exemptions .......................................................... 39

Table 2.4. Permit exemptions based on base station power ............................................ 41

Table 2.5. Time and fees required for local permits ....................................................... 42

Table 2.6. Existing uses of notification as an alternative to permits for small cells.............. 46

Table 3.1. IEC’s simplified safe installation criteria for base station classes ....................... 49

Table 3.2. Human exposure limits (from China’s GB 8702-2014 standard) ........................ 53

Table 5.1. Representative MIMO antenna gains for 5G base stations ................................ 85

Table 6.1. Recommended SAWAP defining parameter set for permit exemption ................. 98



Terminology Used in the Report

The report follows standards from ETSI/3GPP and the ITU. The terms “radio”, “cell”,

“small cell”, cell site”, “base station”, “cellular”, “mobile” and “fixed” are used, but not

interchangeably, as they are not the same. Sources used in the report may sometimes

use “cellular”, “mobile” and even the American term “wireless” interchangeably, despite

the fact that they are not the same, but this not the practice followed in this report. To

clarify further:

“SAWAP” is a new term introduced in the EECC, the name being the acronym for small-

area wireless access point, and is the study’s focus. A SAWAP differs from a “small cell”

(which may imply cellular technology) in being less specific in technology but more

specific in size. As explained below, while a “cell” is a service area, a SAWAP is a new

EECC category of radio transceiver equipment. It may be for a dense cellular network

such as 5G NR, or for a non-cellular technology, such as Wi-Fi. This report recommends

some maximum physical dimensions for SAWAP units but it does not recommend any

maximum coverage area, whether it be for a dense pattern of cells, often termed “small

cells” (see below) or for a non-cellular coverage model.

“Cellular” implies a specific type of radio network based on a repeated overlapping cell

pattern, with standards produced by 3GPP and ETSI. In this report, “cellular” is used

when referring to that specific group of technologies and “radio” when referring to radio

communication in general. Note that there are also many kinds of non-cellular radio

networks: Wi-Fi is the most widely used broadband radio technology today but there are

also Bluetooth, fixed line of sight microwave, satellite television, and industrial IoT

networks, such as ZigBee, as well as SRDs such as RFID, NFC, etc. Furthermore, there

are many “mobile” networks that are not cellular, e.g. aeronautical and maritime

systems such as SSR ATC, TCAS, GPS, MRNSS, and also Citizens Band radio, etc. For

these reasons, in this report, “cellular” is not used interchangeably with either “mobile”

or “radio”.

A “cell” (as used in a “cellular network”) is the service area with signal coverage. It is

repeated contiguously to form the total coverage area of the network.

“Small Cell” is used almost interchangeably with SAWAP in the EECC. But because

“small cell” might suggest use of cellular technology only, and because the distinction

between coverage area and an equipment package is important from a regulatory

perspective, we avoid using SAWAP and “small cell” as exact synonyms. This report

recommends some maximum physical dimensions for SAWAPs but it does not

recommend any maximum “small cell” coverage area. Note that most of the local permit

exemptions now offered by Member States for “small cells” have different functional

requirements compared to the specifications of SAWAPs (see chapter 2). Certain NRAs

provide some indications of small cell size, e.g., from tens to hundreds of metres

(ANFR/ARCEP – see Appendix 1.10).

A “base station” (also termed a “base transceiver station”, BTS, in some standards) is

the set of electronic equipment that sends and receives radio waves. It is usually located

near the middle of a cell, to radiate equally over the surface area of the cell. A SAWAP

unit will incorporate a form of transceiver of lower power, size and energy consumption,

to serve its smaller area of coverage, compared to the majority of today’s macrocell BTS

for UMTS and LTE. The term’s use is thus traditionally associated with large cellular

macrocells but the SAWAP small area of coverage has the same functionality. In the



report, “SAWAP” is generally used in preference to base station where appropriate,

because of this macrocell connotation. Thus, the term base station is used only where it

is justified, for instance when drawing inferences from previous and current use in

national laws and where it is the terminology in relevant standards.

A “cell site” is the physical location of the base station, in the terminology of mobile

cellular networks.

“Fixed” denotes that both the emitting and receiving stations are at a fixed location

permanently, i.e., the subscriber transceiver equipment is not mobile, or is inside a

building. Radio communications may be from one fixed site (e.g., from outside, where

the SAWAP is installed) to another fixed site, e.g., a receiving antenna on a building or

inside it. Many small cells may be used in this configuration, for instance for broadband

entertainment services from the SAWAP into a residential customer’s dwelling. That is

the prevalent use of 5G in cities in the USA today by the two largest operators. Fixed

wireless access (FWA) is the term used in the USA to describe this.

“Radio” usually implies radio communications using electromagnetic transmission of

signals by radio waves over the frequencies of the electromagnetic spectrum between 30

Hz and 300 GHz. The term also implies the equipment that enables radio

communications.

“Wireless” is sometimes used as a colloquial term for “radio” implying absence of

wires or cables, as in “SAWAP”. However, “wireless” has broader connotations than just

communications and location systems in the radio spectrum. The term is currently used

in the relevant industry sectors for other non-wired transmission mediums such as light

waves (especially laser), infrared signals and sonic applications (especially ultrasonic).

Examples of these other “wireless devices” include infrared beams for home appliances

such as TVs, alarms and also for laptops, ultrasonics for signal keys for car and garage

doors and for sonar, and also light wave devices such as lasers for line-of-sight

communications in terrestrial, satellite and space communications as well as Li-Fi and

laser guidance systems and lidar for future autonomous vehicles. For this reason, the

term is used only where appropriate.



Executive Summary

Overview

This report summarises the findings of a study to define a lightweight regulatory regime

for small-area wireless access points (or SAWAPs as they are termed in the European

Electronic Communications Code, the EECC).

A lightweight regulatory approach is prompted by the arrival of 5G, a new generation of

cellular technology for broadband access for fixed and mobile connectivity with very high

bandwidth. The EECC anticipates this with various Articles that respond to the expected

demands for a much higher density of small cells, in contrast with the macrocells of

previous mobile generations. This new technology aims at 100 to 1000 times faster data

speeds for users, but it will rely on a density of base transceiver stations (BTS) that is

100 to 1000 times more than today’s macrocells. For instance, the area of a mobile

macrocell with a three-km radius could host over 900 SAWAP cells of 100 metre radius

without overlaps. Many SAWAPs will have smaller ranges.

This number of SAWAP installations implies significant delays in rollout if each unit has

to proceed through the many planning permissions and other local rules and regulations

for installation. Thus, the objectives of the study are to support the Commission in

preparing to implement the requirements of Article 57 of the European Electronic

Communications Code (EECC, or the “Code”) which calls for simplification of the rollout

procedures. However, there is a complication.

The 28 Member States all have different and highly individual legal criteria on the

specification, permission, approvals procedure, and applicable legislation concerning the

installation of a cellular base station, and on its physical characteristics, including the

levels of RF EMF permitted nationally. Most Member States also have varied local levels

of permission by municipality, administrative region, provinces, state, or devolved

nation. At the same time, many have a 5G strategy aimed at easing the burden on

anticipated 5G rollouts.

Terminology

Often, the terms “cell”, “cell site” and “base station” are used interchangeably, but they are

not the same. A “cell” (as in “cellular network”) is a service area with signal coverage. A

“base station” (or “base transceiver station”) is an equipment package that sends and

receives radio waves. It is usually located near the middle of a cell. A “cell site” is the base

station’s location. These terms are used consistently throughout this report with the

meanings just stated.

“Cellular”, “mobile” and “wireless” are also sometimes used interchangeably, even though

they are not the same. “Wireless” is a colloquial term for “radio”, often used to avoid

confusion with “radio broadcasting” (through-the-air FM, AM or DAB audio programming).

“Cellular” is a specific type of wireless network based on standards produced by 3GPP. But

there are also many kinds of non-cellular wireless networks: Wi-Fi, Bluetooth, fixed

microwave, satellite television, etc. Finally, there are many “mobile” networks that are not

cellular, e.g., aeronautical and maritime systems, Citizens Band, etc. In this report, we are

less strict about using cellular, mobile and wireless than the terms in the paragraph above

(i.e, cell, cell site and base station). However, we use “cellular” when referring to that specific

type of technologies and “wireless” when referring to radio communications generally.



Consequently, the study set out to answer a key question:

How can we define a light-touch regulation regime acceptable to the EU

Member States that will accelerate SAWAP deployment while adequately

protecting the public and the environment?

Summary of Findings

Article 57 of the EECC tasks the European Commission, by means of implementing acts,

to specify the physical and technical characteristics of SAWAPs, such as the maximum

size, emission power, and so on, that would define a complying unit as being exempted

from any individual town planning permit or other prior individual permits, unless there

are environmental or historical conservation conditions, or for public safety reasons.

At a policy level, the purpose of such a SAWAP as defined in the EECC is to reduce the

time, cost and administrative burden currently needed for their deployment, as intended

in Article 57. This would facilitate the intense network densification required for 5G

services. Thus, the study’s overall objective is to specify those technical conditions

under which SAWAPs may not be subject to any individual town planning permit or other

individual prior permit, without prejudice to national requirements on construction health

and safety. Also deployment conditions cannot compromise compliance with the

electromagnetic field limits for the protection of human health, which fall under the

national competence of each Member State (MS).

The key findings for each of the study’s tasks are given below:

Task 1a: Analysis of existing and planned definitions of a small cell, including their

physical and technical characteristics (size, weight, installation height, visual

characteristics, etc):

No common model was found. Instead many different specifications, processes and rules

are applied across the MS. There is a lack of consensus on how to define a small cell

physically and in terms of emitted power across the EU. Few MS have explicit legal or

regulatory definitions of small cells now, although many have implicit definitions based

on their own parameters that define eligibility for permit exemptions in practice. Thus, a

consensus definition of small-area wireless access points has not emerged spontaneously

from the regulatory policies of the individual EU Member States, nor is it likely to if

present trends persist. However, some Member States have recently started aligning

their policies with the EECC in the context of national broadband or 5G action plan.

Task 1b: Verification of whether emission power limits, whose level is set and regulated

under each national administration, are sufficiently covered and enforced through

existing standards (e.g. CENELEC EN 50400, IEC 62232) in compliance with the Radio

Equipment Directive or whether further provisions are needed in the EECC:

About two-thirds of the EU Member States have transposed or approximated

Recommendation 1999/519/EC on the limitation of exposure of the general public to

electromagnetic fields (0 Hz to 300 GHz) that follows the International Commission on

Non-Ionizing Radiation Protection (ICNIRP) limits set by medical criteria for safety.

Although setting and enforcing RF EMF limits on exposure are a national competence,

Member States must justify any divergence from the Recommendation and ICNIRP

limits. A quarter of Member States have stricter limits on human exposure to radio



frequency emissions. A dwindling number have voluntary rather than mandatory limits

while still recommending adherence to the ICNIRP guidelines.

One of the most challenging developments in 5G technology is the use of beam steering

antennae using phased arrays. These are capable of multiple simultaneous beamforming

and reception, or multiple input/multiple output (MIMO). This can be engineered to give

highly focused beams for better transmission range at higher frequencies. Various

mathematical models and measurement protocols to verify the compliance of 5G

equipment with national regulations and ICNIRP’s guidelines on human RF exposure are

still being developed. Further field research and verification by the professional bodies is

essential. Discussions with 3GPP experts on this subject reveal plans for developing field

testing methods, with work on new mathematical tools also under way. The head of the

IEC/CENELEC, TC-106 working group, whose remit is to examine safe RF EMF levels,

notes that fundamental aspects of the measurement problem are now being pursued. In

consequence, the IEC 62232 standard is currently under review and is due for revision in

2019, following ICNIRP’s reviews of its limits, with publication of further expected

revisions in 2020.

Task 2: Analysis of the current regulatory requirements for small-area wireless access

points deployment in each Member State, which permits are required, the criteria for

granting permits (including aesthetics and power limits), and the possibilities and

conditions for exemptions):

The current situation on the regulatory approval process for small cells across the EU is

complex, detailed and varies greatly by Member State. There is no common agreement

and qualifying conditions vary within Member State by region as well as between

Member States. A summary analysis is given in Chapter 2. Although many Member

States lighten the burden of applying for project and site approvals to various extents by

offering exemption, alternatives and simplified or streamlined procedures, not available

to macrocells, few Member States exempt small cells from local planning or building

permits. The diversity of conditions for permit exemption presents a challenge for

designing an EU-wide lightweight regulatory regime. Nevertheless, the diversity does

offer a rich source of information for how to specify exemptions and define eligible small

cells, for instance, the straightforward approach used in Spain. Furthermore, there are

disparities between the current situation in the Member States and EECC Articles 2 and

57. Closing the divergences would require the drafting and adoption of new EU

implementing regulation (followed by changes in regulation at the national and local

levels) for an exemptions process to be established.

Task 3: Analysis of relevant situations in countries outside the EU, as well as

international initiatives regarding the adoption of generic criteria for the exemption of

small cells from approval processes:

Apart from the USA, no country outside the EU uses generic criteria to exempt small

cells from approval processes. In short, no significant lessons emerged from examining

non-EU countries. However, Canada’s transparent, simple, open public approach to base

station deployment could be emulated, and China’s massive training effort for base

station installers is noteworthy. The conclusion is that no model or solution is to be

found for small cell deployment in countries reviewed outside Europe, although others

have lessons in what to avoid (e.g. the FCC regulations issued in the USA in August

2018). Details of the non-EU countries are given in Chapter 3.



One international model is of note, the three-part framework proposed by ITU-T in

Recommendation K.52 (“Guidance on complying with limits for human exposure to

electromagnetic fields”, 2018, particularly Annex IV.1) which offers guidance on power

levels for small cells that also covers line of sight microwave.

Task 4: Propose elements of a light regulatory regime for a SAWAP deployment with a

detailed development of policy options:

The elements necessary for a light regulatory regime fall into two distinct categories –

those that are appropriate for the implementing act and those that are additional

recommendations, for which some different regulatory instrument would be necessary.

Recommendations for the implementing act are given in chapter 6. Additional

recommendations are given in Chapter 7. The context for this is first analysed in Chapter

5 where the major challenges are examined.

An EC public consultation1 and study consultations with industry representatives and

regulators – through a stakeholder workshop and meetings with the RSPG and COCOM

Committee – strongly suggested the need for a minimalist approach to technical and

physical specification of SAWAPs in order to achieve acceptance. Consequently, just

three parameters are proposed – output power and size, as shown in Table 0.1 with

pragmatic aesthetics recommendations. The reasons for this choice are that all

operations, siting and performance of a SAWAP unit will depend on power particularly as

it defines the density of deployment, for a given frequency. Physical size is included as

defining a SAWAP set by industry requests and technological developments for a volume

appropriate to a small cell’s equipment.

The output power, which is the main variable, is set comparatively low because, as

explained in Chapter 5, the necessary research has still to be performed on

measurement techniques, especially for MIMO antennae in mmWave conditions with

interactions between the handset and the SAWAP. Thus, our recommendation is to

proceed on the side of caution for beamforming antenna, at 1 Watt maximum transmit

power outdoors, while it remains to be determined for indoor SAWAPs. The explanation

of the selection of this level of power is examined in chapters 5 and 6. This is our major

final conclusion. However, it is also recommended that a further expert consultation be

pursued on appropriate power levels, especially when the ongoing review of ICNIRP

recommendations become standards under the IEC and CENELEC/CEPT.

The aim is to provide a lighter regime by a simple technical qualification that can be

carried out in its production phase. In line with the concept of a basic small cell, the

specification deliberately does not include heights above the pavement, exclusion zones

or enclosure surface treatment, antenna physical dimensions, weights, brackets or the

many other parameters different Member States have required. However aesthetic

principles must be included in the act as it refers to the “physical characteristics” of

Article 57(1) and so pragmatic principles of aesthetics must be an essential part of the

study recommendations and Table 0.1, with description of the seven principles in

Chapter 6, section 6.6 following guidance from the Spanish planning authorities.

1 European Commission (2019), “Public Consultation on the light deployment regime for small-area wireless

access points,” 16 January - 10 April 2019 - https://ec.europa.eu/digital-single-market/en/news/public-consultation-light-deployment-regime-small-area-wireless-access-points



These parameters are given to define exemption conditions under the EECC but do not

rule out or prejudice other limiting and defining parameters that are within the

competence of the Member States. Note also that enforcement and compliance cannot

be carried out by other than each Member State.

Table 0.1. Definition of parameters for exemption of SAWAPs

Definition of parameter for exemption

Limiting value for exemption

For outdoor SAWAPs emission power (in absence of valid field measurement and monitoring techniques for AAS beamforming with MIMO in any band)

a) For an active antenna system (AAS) with multi-user MIMO beamforming antenna, an upper limit of 1 Watt maximum transmit power. Note that this is a provisional initial estimate. This value should be redefined in terms of a SAR value received by users in W/kg for a MIMO beamformed transmission to meet any subsequent ICNIRP guidelines when new research establishes the appropriate limit. b) For an antenna system not using beamforming with AAS MIMO but instead using conventional 120 degree or 90 degree sectors, the upper limit guidelines are as given in the IEC 62232 (2.0) 2017-08 standard for the categories E2 (2W EIRP) or E10 (10W EIRP) with a minimum 2.2 metre height above ground level.

Physical size of outdoor SAWAP transceiver enclosure if exposed outdoors (and not hidden inside street furniture when it may be larger).

20-30 litres, including power supplies and batteries. Note that this

volume range depends on configuration and technology used.

For indoor SAWAPs emission power (in absence of valid field measurement and monitoring techniques for AAS beamforming with MIMO in any band)

Less than 0.2 W EIRP for non-AAS. For AAS to be determined.

Physical size of indoor SAWAP transceiver enclosure.

No size limits.

Physical aesthetic considerations Installation principles, as in the seven clauses of section 6.6.

Moreover, there is also the key question of future evolution of the recommendations in

Table 0.1, through delegating acts. Following expert consultation, and when the

difficulties with calculations for beamforming transmission fields are resolved, there is

likely to be a need to revisit the parameters above, to set new specifications that respect

any freshly revised ICNIRP limits for beamforming AAS equipment at that time.

With the restrictions of the powers of implementing acts, certain recommendations

cannot be included. Thus, other provisions that should not be included in the

implementing act but are necessary to support the rapid rollout of SAWAPs under a light

regulatory regime are proposed in Chapter 7. These additional recommendations cover

the following topics:

1 A form of technical type approval of SAWAPs for accelerating rollout

2 Notification of location of a newly installed SAWAP, important for dense

deployments, to help both the industry and local authorities to manage rollout

3 The role of the Member States in monitoring RF limits and their enforcement

4 Automated monitoring systems for constant checking of RF environment

5 Further Research and Development projects urgently required plus an expert

consultation on power limits for beamforming MIMO SAWAPs

6 Geolocation databases for SAWAP deployments, especially in dense urban

settings

7 Training campaigns for installation – and employment opportunities



8 Cybersecurity

The analysis and summary of these additional recommendations above are quite

detailed, with examination in Chapters 4 and 5 for lessons from current country

examples, practical aesthetics barriers and challenges. Two of the measures above are

particularly important:

For rapid rollout, a “standard SAWAP for Europe” would be advantageous and

could use the technical type approval process under the Radio Equipment

Directive for placing equipment on the EU market.

Notification of location of SAWAP installations is necessary to manage the built

environment, in each Member State, with entries in two national databases. The

first database would be for buried services (e.g. power supply ducts, backhaul,

utility runs and wayleaves, etc); the second would be for surface level impacts –

geospatial mapping of power density levels in aggregated conditions with a

surface map of assets such as street furniture.

Task 4b: Identify the administrative barriers which prevent the deployment of SAWAPs

within the scope of EECC Article 57, with an estimate of the workload implications

resulting in costs and delays for both operators and competent authorities:

A detailed review of the barriers forms part of the Member State analysis, summarised in

Chapter 2, and is expanded, by Member State, in Appendix A. This includes a range of

administrative barriers. Principal categories include land use planning, construction

permit requirements and laws regarding wayleaves and access to physical

infrastructures which vary widely, even within single countries and from one city or

region to another. Cities may have control over street furniture and may provide access

individually or group all assets as a single contract.



Abbreviations

2G Second generation mobile communications (GSM)

3G Third generation (mobile communications)

3GPP 3G Partnership Project

4G Fourth generation (mobile communications)

5G Fifth generation radio communications including mobile/fixed

5G NR 5G New Radio (3GPP/ETSI group of standards)

AAS Active Antenna System

AGCOM Autorità per le Garanzie nelle Comunicazioni

(Authority for Competition and Consumer Rights Guarantees in

Communications, NRA, Italy)

AKOS

(formerly

APEK)

Agencija za komunikacijska omrežja in storitve Republike Slovenije

(Agency for Communications Networks and Services of the Republic of

Slovenia)

ARCEP Autorité de régulation des communications électroniques et des postes

(French Regulatory agency for electronic communications and posts)

ANFR Agence National des Fréquences (French Regulatory agency for spectrum

management)

ANSES Agence nationale de sécurité sanitaire de l’alimentation, de

l’environnement et du travail (National Agency for Food, Environmental

and Occupational Health & Safety)

AWS Advanced Wireless Service

BER Bit Error Rate

BEREC Body of European Regulators for Electronic Communications

BEUC European Consumer Organisation

BIAC (European Commission’s) Broadband Internet Access Cost study

BS Base station (ETSI/3GPP nomenclature)

BTS Base Transceiver Station

C-ITS Co-operative and Intelligent Transport System

CAPEX Capital expenditure

CCCE Commission consultative des communications électroniques

CEPT Conférence Européenne des administrations des Postes et des

Télécommunications (European Conference of Postal and

Telecommunications Administrations)

CMA Cellular Market Area; Competition and Markets Authority

COCOM Communications Committee (DG CONNECT) 5G

ComReg Commission for Communications Regulation (Ireland)

CQI Channel Quality Indicator

CPE Customer Premises Equipment

CRC Communications Regulation Commission (Bulgarian NRA); Cyclic

Redundancy Check

D2D Device-to-Device

DAE Digital Agenda for Europe

DAS Distributed Antenna System

dBμV/m Decibel (dB) above 1 microvolt per metre

dBm Decibel referenced to milliwatts

DOCSIS Data Over Cable Service Interface Specification (from Cable Labs)

DMM Distributed Massive MU-MIMO

DSL Digital Subscriber Line (also denoted by xDSL indicating any technology)

DSM Digital Single Market

EEA European Economic Area

EC European Commission



ECC Electronic Communications Committee

EECC European Electronic Communications Code

EIRP Effective Isotropic Radiated Power

EMF Electromagnetic field

ERC European Radiocommunications Committee

ERP Effective radiated power

ETSI European Telecommunications Standards Institute

EU European Union

FCC Federal Communications Commission, USA

FDD Frequency division duplex

FICORA Finnish Communications Regulatory Authority

FMC Fixed-mobile convergence

FMS Fixed-mobile substitution

FTTC/H/B Fibre To The Cabinet; Fibre To The Home; Fibre To The Basement

FWA Fixed Wireless Access

G.mgfast Multi-Gigabit Fast Access to Subscriber Terminals

GDP Gross Domestic Product

GIS Geographic Information System

GPON Gigabit Passive Optical Network (based on ITU-T G.984)

GPS Global Positioning System

GPRS General Packet Radio Service (narrowband data for GSM)

GSM Global System for Mobile Communications, 2G (originally Groupe Spécial

Mobile)

HD High definition (audio or video)

HDTV High definition Television

Hetnet Heterogeneous Network (also HetNet)

HPUE High Power User Equipment

IAS Internet Access Service

IEEE Institute for Electrical and Electronics Engineers

IETF Internet Engineering Task Force

IMT2020 International Mobile Telecommunications for 2020 (from ITU)

IPLR IP Packet Loss Ratio

IP Internet Packet (protocol)

ISD inter-site distance - deployment distance between BTS

ISED Innovation, Science and Economic Development, Canadian NRA

ISP Internet Service Provider

IT Information technology

ITU International Telecommunication Union

KPI Key performance indicator

KPO Key performance objective

KQI Key quality indicator

LAA License Assisted Access (introduced in 3GPP release 13)

LoS Line of sight

LTE Long-Term Evolution (of UMTS)

LTE-A Long-Term Evolution-Advanced

LTE-U LTE-Unlicensed (a variant of LTE for licence exempt spectrum)

M2M Machine-to-machine

MFCN Mobile/fixed communications networks

MIC Ministry of Internal Affairs and Communications (Japan)

MIMO Multiple-Input-Multiple-Output

MU-MIMO Multi-User Multiple Input–Multiple Output (antenna)

MNO Mobile network operator

MS Member State (in the EU context) or also Mobile Station, the ITU term for

a mobile handset or any handheld terminal, also used by other SDOs

MSE Mean squared error

MTBF Mean Time Before Failure



MTTR Mean Time To Repair

N4M Net 4 Mobility

NBP National broadband plans

NFV Network Function Virtualisation

NFV MANO Network Function Virtualisation Management and Orchestration

NP Network performance

NRA National regulatory authority

NGA Next generation access

NGO Non-governmental organisation

NSA National Security Agency (USA)

Ofcom Office of Communications (UK or Switzerland)

OPEX Operating expense

P2P/CWDM Point-to-Point/Coarse Wavelength Division Multiplexing

PoP Point of Presence

PTS Post och TeleStyrelsen (Swedish Post and Telecom Authority)

QoE Quality of experience

QoS Quality of service

RAN Radio Access Network

RAT Radio Access Technology (ITU, 3GPP)

REAG Regional Economic Area Grouping

RED Radio Equipment Directive

RRH Remote Radio Head

RSCP Received Signal Code Power (a parameter for measuring UMTS coverage)

RSPG Radio Spectrum Policy Group

RSRP Reference Signal Received Power

RSRQ Reference Signal Received Quality

RSSI Received Signal Strength Indicator

RSU Road-Side Unit

RTT Round Trip Time (for ping test for latency)

RxLEV Received signal LEVel

RxQUAL Received signal QUALity

SAR Specific Absorption Rate

SAWAP Small-Area Wireless Access Point

SDN Software Defined Network

SDO Standards Development Organisation

SG-12 Study Group 12 (quality, ITU-T)

SFR Société Française du Radiotéléphone

SINR Signal-to-Interference-plus-Noise Ratio

SMP Significant Market Power

SON Self Organising Network; Synchronous Optical Network

SP Service Provider

SSNIP Small but Significant and Non-transitory Increase in Price

ST Sub task

TCP/IP Transmission Control Protocol/ Internet Protocol

TDD Time Division Duplex

TRP Total Radiated Power

UE User equipment (standards documents, ETSI/3GPP, ITU)

UHD Ultra-High Definition (video)

URLLC Ultra-Reliable Low-Latency Communications (a 5G /ITU use case)

UMTS Universal Mobile Telecommunications System

UX User experience

V2I Vehicle-to-(roadway)-infrastructure

V2P Vehicle-to-person/pedestrian

V2V Vehicle-to-vehicle

V2X Vehicle-to-anything



VHC Very High Capacity

VHS Very High Speed

VM Virtual Machine

VNF Virtualised Network Function

VoLTE Voice over LTE

WAN Wide Area Network

WAP Wireless Access Protocol

WDM Wave Division Multiplexing

WHO World Health Organisation (a United Nations agency)

WLAN Wireless Local Area Network

WPT Wireless Power Transfer

WRC-19 ITU World Radio Conference, 2019

WWRF Wireless World Research Forum

xDSL Any Digital Subscriber Line technology



1. Developing a Lightweight Regulatory Regime

for Small Cells

1.1 The Context for the Study

Why is a lightweight regulatory regime for small cells necessary?

Public mobile networks have proven immensely popular over three decades and are now

essential to the European economy and society. Ninety-nine percent of homes in the EU

purportedly have LTE coverage from at least one network operator and so mobile

broadband penetration is approaching 100% as shown in Figure 1.1.

Figure 1.1 LTE coverage and mobile broadband penetration in the EU

Source: EU Digital Economy and Society Index (2019),

https://ec.europa.eu/newsroom/dae/document.cfm?doc_id=60010.



About 15 years ago, when sales of laptops, smartphones, tablets and other portable data

communication devices took off, mobile data traffic growth exploded, increasing by over

50% each year. Some market forecasters predicted that this growth would continue for

a generation or more, and perhaps even increase as processors became more powerful

and new applications emerged to take advantage of bigger memories, new form factors

and new service concepts (telepresence, VR gaming, the Internet of Things (IoT), etc).

It seemed certain that data traffic would soon exceed the capacity of existing networks,

so LTE was developed from UMTS, based on IP packets and greater spectrum efficiency,

while suppliers began work on a successor, 5G, to augment LTE and drive the market.

The mobile supply side encouraged excitement in this new technology, with novel

services, but few noticed when data traffic annual growth rates began to slow (see Table

1.1 and Figure 1.2).

Table 1.1 Mobile data traffic in Europe (petabytes per month)

Region 2015 2016 2017 2018 2019 (est.)

2020 (est.)

2021 (est.)

2022 (est.)

Central & Eastern Europe

546 901 1,355 2,153 3,119 4,317 5,834 7,752

Western Europe 432 724 1,073 1,471 2,062 2,807 3,801 5,120

Totals 978 1,625 2,428 3,624 5,181 7,124 9,635 12,872

Annual rate of increase

-- 66% 49% 49% 43% 37% 35% 34%

Source: Cisco, Visual Networking Index, 2016-2019.

Figure 1.2. Slowing mobile data growth per SIM, 2017-2018

Source: Tefficient (2019), https://twitter.com/tefficient/status/1143176335868776454.

However, this does suggest that the latest LTE version (LTE-A) capacity will be stressed

by the middle of the next decade, so upgrades to mobile networks must be planned,

though perhaps not as urgently as it seemed five years ago. For that reason, Frédéric

Pujol could tell an EC workshop in 2018 that “many players we interviewed for



[IDATE/Plum’s study of 5G demand for mmWave spectrum] do not expect a very

aggressive 5G deployment in Europe”.2

Cellular networks are elastic. With more spectrum, they can support more subscribers. If

frequency reuse is increased by reducing cell size, they can carry more traffic. Thus,

network densification and new allocations of bandwidth are obvious solutions to the

slowing but continuing growth in data traffic, regardless of whether the radio equipment

is LTE, 5G or some other technology such as the new generations of Wi-Fi.

Wi-Fi offloading offers another important adjustment. While cellular networks carry more

data every year, Wi-Fi networks carry even more, so their rate of traffic growth is

slowing less than cellular. Consequently, Cisco predicts that offload from cellular will

increase as a proportion of total mobile data traffic, from 54% in 2017 to 59% in 2022:

Wi-Fi offload is going to be higher on 4G and 5G networks than on lower-speed

networks, according to our projections… As 5G is being introduced, while we

expect plans to be generous with data caps and speeds will be higher than ever,

the new application demands on 5G are also going to move upwards as well

encouraging similar behaviours of offload as 4G. The offload percentage on 5G is

estimated to be 71 percent by 2022.3

Figure 1.3. Cellular generation and data traffic offloading rates

Source: Cisco (2019), Visual Networking Index.

While the Wi-Fi equipment market for in-home and in-office use is nearing saturation,

market analysts predict a continuing proliferation of Wi-Fi public hotspots and local

machine-to-machine (M2M) Wi-Fi networks, as well as a boom in “carrier Wi-Fi” as

network operators invest in small access points incorporating Wi-Fi, taking advantage of

2 F. Pujol (2018), introduction to “EC workshop on using millimetre wave bands for the deployment of the 5G ecosystem in the Union,” 30 May - https://webcast.ec.europa.eu/stakeholders-workshop-study-on-using-millimetre-waves-bands-for-the-deployment

3 Cisco (2019), Visual Networking Index: Global Mobile Data Traffic Forecast Update, 2017–2022 White Paper - https://www.cisco.com/c/en/us/solutions/collateral/service-provider/visual-networking-index-vni/white-paper-c11-738429.html



LTE’s tools for bandwidth aggregation and 5G’s for “load balancing” between licensed

and licence-exempt spectrum.

This is the context for this study: there is a well-established need to densify cellular

networks to absorb the continuing growth in data traffic with a new generation of small

base stations that are likely to be hybrids containing radios for both licensed and licence-

exempt spectrum, supporting both 3GPP and IEEE technologies.

Many of these small base stations may be owned by the incumbent mobile network

operators. But many could be owned by local municipalities, public venues, private

industry, local governments and end users, creating a more diverse and dynamic

radio/economic environment that needs new regulatory concepts and approaches. These

new concepts and approaches will probably combine elements of licence-exempt and

licence-based regulation in novel forms of “light licensing”.4

The site placement rules designed to regulate high-power, tall-tower macrocell base

stations are not appropriate for low-power, short-range base stations, often as small as

a briefcase, particularly when deployed indoors or hidden in street furniture as many

small cells will be. Such rules are unnecessary impediments to a shift in infrastructure

that is clearly needed and advantageous but which comes with new risks and

opportunities.

The Small Cell Forum predicts that global deployment of small cellular base stations will

increase from about 1.7 million/year in 2017 to between 7.1 million (worst case) and

11.4 million/year (best case) in 2025. Annual deployments in Europe are expected to

increase from 175,000 in 2017 to over 1.5 million in 2025.5

1.2 The European Electronic Communications Code

The European Electronic Communications Code6 (EECC or “the Code”) provides a

framework for the new regulatory concepts and approaches mentioned in the previous

section. Published in the Official Journal of the European Union in December 20187,

clause 23 of EECC Article 2 provides a generic definition of “small-area wireless access

points” (SAWAPs) that might serve public, private or sectoral networks. EECC Article 57

adds that the deployment and operation of these SAWAPs should not be unduly

restricted – indeed, they deserve institutional support because of their many and diverse

socioeconomic benefits.

But putting the EECC into practice requires a more precise description of a SAWAP’s

physical dimensions and attributes, as well as an understanding of the minimum

necessary restrictions on their deployment and operation. Thus, the main aim of this

report is to develop recommendations to the European Commission to support the

drafting of implementing acts that satisfy those requirements.

4 CEPT (2009), Light Licensing, Licence-exempt and Commons, ECC Report 132 - https://www.ecodocdb.dk/download/87ccb237-fa9a/ECCREP132.PDF

5 Small Cell forum (2018), Small Cells Market Status Report, document 50-10-03 (December) - http://www.scf.io/en/documents/050_-_Small_cells_market_status_report_December_2018.php

6 Directive (EU) 2018/1972 of the European Parliament and of the Council of 11 December 2018 establishing the European Electronic Communications Code.

7 OJ L 321, 17.12.2018, p. 36



Compliance with the EECC

The logical place to begin is with EECC Article 2’s definition of a SAWAP:

23. ‘small-area wireless access point’ (or “SAWAP” as referred to in this study) means

low-power wireless network access equipment of a small size operating within a small

range, using licensed radio spectrum or licence-exempt radio spectrum or a combination

thereof, which may be used as part of a public electronic communications network, which

may be equipped with one or more low visual impact antennae, and which allows wireless

access by users to electronic communications networks regardless of the underlying

network topology, be it mobile or fixed;

Three aspects of this definition are especially significant:

It stipulates “low-power,” “small size” and “small range” without quantifying

those terms;

It foresees the need for “low visual impact antennae”; and

It embraces different network topologies (“mobile or fixed”) as well as technology

and service neutrality (“licensed radio spectrum or licence-exempt radio spectrum

or a combination thereof, which may be used as part of a public electronic

communications network”). In other words, it anticipates that cellular (mobile)

and WLAN (fixed) radios could be combined in small network access points, as in

today’s “smart” handsets, so the definition of SAWAP is not limited to equipment

provided and controlled by a mobile network operator (MNO).

Complementing Article 2, Article 57 focuses on SAWAP deployment. The second

paragraph explains why implementing acts are needed based on an “examination

procedure”:

Article 57 - Deployment and operation of small-area wireless access points

1. Competent authorities shall not unduly restrict the deployment of small-area wireless

access points. Member States shall seek to ensure that any rules governing the

deployment of small-area wireless access points (or “SAWAPs”) are nationally consistent.

Such rules shall be published in advance of their application. In particular, competent

authorities shall not subject the deployment of small-area wireless access points

complying with the characteristics laid down pursuant to paragraph 2 to any individual

town planning permit or other individual prior permits. By way of derogation from the

second subparagraph of this paragraph, competent authorities may require permits for the

deployment of small-area wireless access points on buildings or sites of architectural,

historical or natural value protected in accordance with national law or where necessary for

public safety reasons. Article 7 of Directive 2014/61/EU shall apply to the granting of those

permits.

2. The Commission shall, by means of implementing acts, specify the physical and

technical characteristics, such as maximum size, weight, and where appropriate emission

power of small-area wireless access points. Those implementing acts shall be adopted in

accordance with the examination procedure referred to in Article 118(4). The first such

implementing act shall be adopted by 30 June 2020.

3. This Article is without prejudice to the essential requirements laid down in Directive

2014/53/EU and to the authorisation regime applicable for the use of the relevant radio

spectrum.

4. Member States shall, by applying, where relevant, the procedures adopted in

accordance with Directive 2014/61/EU, ensure that operators have the right to access any

physical infrastructure controlled by national, regional or local public authorities, which is



technically suitable to host small-area wireless access points or which is necessary to

connect such access points to a backbone network, including street furniture, such as light

poles, street signs, traffic lights, billboards, bus and tramway stops and metro stations.

Public authorities shall meet all reasonable requests for access on fair, reasonable,

transparent and non-discriminatory terms and conditions, which shall be made public at a

single information point.

5.Without prejudice to any commercial agreements, the deployment of small-area wireless

access points shall not be subject to any fees or charges going beyond the administrative

charges…

This Article makes several key points:

SAWAP deployment must not be hindered by unnecessary local authorisation

procedures or arbitrary conditions.

Network operators should have the right to access any physical infrastructure

controlled by public authorities that is suitable to host a SAWAP.

Fees and charges related to SAWAP deployment should be limited to the costs of

administration.

Deployment regulations must be nationally consistent.

Exceptions are allowed for specially protected sites and environments.

The European Commission will specify the physical and technical parameters for

exemption from individual site permits.

There is a deadline for adoption of the first implementing act: 30 June 2020.

Article 57 includes references to other legislation whose content should be taken into

account to fully understand the EECC’s aims and requirements. For example, Article 7 of

Directive 2014/61/EU (mentioned in the fourth paragraph of EECC Article 57) concerns

measures for improving permit procedures:

Directive 2014/61/EU; Article 7 - Permit-granting procedure

1. Member States shall ensure that all relevant information concerning the conditions and

procedures applicable for granting permits for civil works needed with a view to deploying

elements of high-speed electronic communications networks, including any information

concerning exemptions applicable to such elements as regards some or all permits

required under national law, is available via the single information point.

2. Member States may provide for the right of every undertaking providing or authorised

to provide public communications networks to submit, by electronic means via the single

information point, applications for permits required for civil works which are needed with a

view to deploying elements of high-speed electronic communications networks.

3. Member States shall take the necessary measures, in order to ensure that the

competent authorities grant or refuse permits within four months from the date of the

receipt of a complete permit request, without prejudice to other specific deadlines or

obligations laid down for the proper conduct of the procedure which are applicable to the

permit granting procedure in accordance with national or Union law or of appeal

proceedings. Member States may provide that, exceptionally, in duly justified cases, that

deadline may be extended. Any extension shall be the shortest possible in order to grant

or refuse the permit. Any refusal shall be duly justified on the basis of objective,

transparent, non-discriminatory and proportionate criteria.

4. Member States may ensure that every undertaking providing or authorised to provide

public communications networks which has suffered damage as a result of non-compliance



with the deadlines applicable under paragraph 3 has the right to receive compensation for

the damage suffered, in accordance with national law.

Here, too, there are some key points:

Member States must provide a single point of contact for information about,

and electronic applications for, civil works, permits and permit exemptions.

Permit decisions should take no more than four months; if missing that

deadline causes the applicant economic harm, they are entitled to

compensation.

EECC Article 118 (mentioned in Article 57, paragraph 2) states that in developing

implementing acts, the Commission shall be assisted by the Communications Committee

(COCOM) and the Radio Spectrum Committee. Paragraph 4 of Article 118 refers to

Regulation (EU) No 182/2011, which concerns “the Commission’s exercise of

implementing powers”. Specifically cited is Article 4, having regard to Article 8:

Article 4 - Advisory procedure

1. Where the advisory procedure applies, the committee shall deliver its opinion, if

necessary by taking a vote. If the committee takes a vote, the opinion shall be delivered

by a simple majority of its component members.

2. The Commission shall decide on the draft implementing act to be adopted, taking the

utmost account of the conclusions drawn from the discussions within the committee and of

the opinion delivered.

Article 8 - Immediately applicable implementing acts

1. By way of derogation from Articles 4 and 5, a basic act may provide that, on duly

justified imperative grounds of urgency, this Article is to apply.

2. The Commission shall adopt an implementing act which shall apply immediately,

without its prior submission to a committee, and shall remain in force for a period not

exceeding 6 months unless the basic act provides otherwise.

3. At the latest 14 days after its adoption, the chair shall submit the act referred to in

paragraph 2 to the relevant committee in order to obtain its opinion.

4. Where the examination procedure applies, in the event of the committee delivering a

negative opinion, the Commission shall immediately repeal the implementing act adopted

in accordance with paragraph 2.

5. The Commission shall adopt such measures after consulting or, in cases of extreme

urgency, after informing the Member States. In the latter case, consultations shall take

place 10 days at the latest after notification to the Member States of the measures

adopted by the Commission.8

This indicates that the Commission plans to rely on a majority vote by COCOM to

determine the implementing act’s content, but if this process takes too long, and the

Commission considers it a matter of “extreme urgency” – if the deadline for adoption is

8 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32011R0182



imminent, for example – the implementing act may be adopted provisionally with a

committee vote to follow within 10 days.

The final reference to external legislation in EECC Article 57 is to the “essential

requirements” of Directive 2014/53/EU, that is the Radio Equipment Directive (RED),

Article 3 of which enumerates the essential requirements. These are of two types: those

that apply to all radio equipment, and those that apply only to equipment types specified

in delegated acts adopted by the Commission. According to the latest edition of the RED

Guide,9 no delegated acts concerning the essential requirements have yet been adopted

which could be considered relevant to SAWAPs. Thus, the essential requirements in RED

Article 3 that apply to all radio equipment are:

Protecting the health and safety of persons, domestic animals and property

An adequate level of electromagnetic compatibility as defined in Directive

2014/30/EU10

Effectively using and supporting the efficient use of radio spectrum in order to

avoid harmful interference.

Recitals

The EECC also includes several recitals directly relevant to SAWAPs. These prescribe

deployment rights and access to public infrastructures beyond what was available for

UHF macrocells, and they offer clear statements about the Commission’s intentions for

SAWAPs:

(137) Massive growth in radio spectrum demand, and in end-user demand for wireless

broadband capacity, calls for solutions allowing alternative, complementary, spectrally

efficient access solutions, including low-power wireless access systems with a small-area

operating range, such as RLANs and networks of low-power small-size cellular access

points. Such complementary wireless access systems, in particular publicly accessible

RLAN access points, increase access to the internet for end-users and mobile traffic off-

loading for mobile operators… To date, most RLAN access points are used by private users

as local wireless extension of their fixed broadband connection. End-users, within the

limits of their own internet subscription, should not be prevented from sharing access to

their RLAN with others, in order to increase the number of available access points, in

particular, in densely populated areas, maximise wireless data capacity through radio

spectrum re-use and create a cost-effective complementary wireless broadband

infrastructure accessible to other end-users. Therefore, unnecessary restrictions to the

deployment and interlinkage of RLAN access points should also be removed.

(139) Since low power small-area wireless access points, such as femtocells, picocells,

metrocells or microcells, can be very small and make use of unobtrusive equipment similar

to that of domestic RLAN routers, which do not require any permits beyond those

necessary for the use of radio spectrum, …any restriction to their deployment should be

limited to the greatest extent possible… Member States should not subject to any

individual permits the deployment of such devices on buildings which are not officially

protected as part of a designated environment or because of their special architectural or

historical merit, except for reasons of public safety… characteristics, such as maximum

9 European Commission (2018), Guide to the Radio Equipment Directive 2014/53/EU, version of 19 December 2018 - https://ec.europa.eu/docsroom/documents/33162/attachments/1/translations/en/renditions/native

10 Directive 2014/30/EU of the European Parliament and of the Council of 26 February 2014 on the harmonisation of the laws of the Member States relating to electromagnetic compatibility (recast) - https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32014L0030.



size, weight and emission … should be specified at Union level in a proportionate way for

local deployment and to ensure a high level of protection of public health, as laid down in

Recommendation 1999/519/EC. For the operation of small-area wireless access points,

Article 7 of Directive 2014/53/EU should apply … without prejudice to private property

rights set out in Union or national law. The procedure for considering permit applications

should be streamlined and without prejudice to any commercial agreements and any

administrative charge involved should be limited to the administrative costs relating to the

processing of the application. The process of assessing a request for a permit should take

as little time as possible, and in principle no longer than four months.

(140) Public buildings and other public infrastructure … such as street lamps, traffic lights,

offer… sites for deploying small cells… Without prejudice to the possibility for competent

authorities to subject the deployment of small-area wireless access points to individual

prior permits, operators should have the right to access to those public sites for the

purpose of adequately serving demand. Member States should therefore ensure that such

public buildings and other public infrastructure are made available on reasonable

conditions for the deployment of small-cells with a view to complementing Directive

2014/61/EU …which follows a functional approach and imposes obligations of access to

physical infrastructure only when it is part of a network and only if it is owned or used by a

network operator… a specific obligation is not necessary for physical infrastructure, such as

ducts or poles, used for intelligent transport systems, which are owned by network

operators …

Significant points in these three clauses include:

Support for the meshing of RLANs to form neighbourhood or community networks

as an alternative to reliance on national commercial networks.

Except for reasons of public safety, restrictions on SAWAP deployment should be

limited to the greatest extent possible; no individual site permits except on

legally protected structures.

Mandated access to public infrastructures for small cell deployment (note that

this access right is not limited to MNOs).

Three additional legislative documents are referenced in the above passages:

Recommendation 1999/519/EC (limiting public exposure to electromagnetic

fields). This is cited above as an indicative standard but EECC Article 58 obliges

any Member State that introduces a measure applying electromagnetic field (EMF)

exposure limits to SAWAPs that differs from Recommendation 1999/519/EC to

justify their proposal before a standing committee for technical regulations of

Information Society services, delay their adoption of the proposal, and take the

committee’s comments on the proposal into account “as far as possible”. This

procedure is described in Directive (EU) 2015/1535,11 which Article 58 cites.

Article 7 of Directive 2014/53/EU (the Radio Equipment Directive) says, inter alia,

that “Member States may only introduce additional requirements for the putting

into service and/or use of radio equipment for reasons related to the effective and

efficient use of the radio spectrum, to the avoidance of harmful interference, to

the avoidance of electromagnetic disturbances or to public health”.

11 Directive (EU) 2015/1535 of the European Parliament and of the Council of 9 September 2015 laying down a procedure for the provision of information in the field of technical regulations and of rules on Information Society services - https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015L1535



Directive 2014/61/EU – measures to reduce the cost of deploying high-speed

electronic communication networks by making available information about existing

infrastructures and by facilitating the coordination of civil works. A study by

Stratix for the Dutch Ministry of Economic Affairs and Climate Policy found that

“around 84% of the costs [of 5G rollout] are small cell civil works, with the actual

small cells being only approximately 16% of the cost”.12 It is thus very significant

that the EECC extends rights of access to physical infrastructure and civil works

coordination beyond the facilities “owned or used by a network operator” to other

developers of small cell sites.

1.3 Small Cell Regulation Today

Small cell deployment is subject to at least four types of regulation that vary from place

to place: land use planning rules, construction safety rules, protection of the visual

environment and radio frequency authorisations. Thus, a major cause of the diversity

seen among the Member States in their regulation of small base station deployment

results from the four-dimensional rule space.

In addition, the Member States have delegated authority to local administrative entities

to approve the installation of base stations. This has led to significant differences among

them because of varying degrees of autonomy and structures of governance. In some

states, regional bodies are important (eg Austria and Germany). In other states,

environmental protection agencies and ministries of health have major roles (e.g.

Belgium, Finland and Lithuania) while mayors and city councils are dominant in others

(e.g. France and Luxembourg).

This situation is consistent with – possibly even the result of – recommendations of the

Congress of Local and Regional Authorities of Europe “that the governments of the

member states:

a. adopt the strictest national limits currently in use, or at least the

ICNIRP/European Union recommended guideline limits for exposure to

electromagnetic fields as a precautionary measure;…

i. reinforce the authority of regional and local governments over decisions

regarding the placement, construction, and modifications of telecommunications

facilities in their area;

j. introduce a planning procedure to give local and regional authorities greater

control over the siting of telecommunications masts and associated equipment,

enabling them to develop their own telecommunications policies within the

national framework;

k. make sure that local democracy is integral to the planning process via public

consultation, neighbour notification and communication between

telecommunications operators and local authorities…

n. require telecommunications developers and operators to seek to avoid locating

telecommunications developments in environmentally sensitive areas, and where

12 Stratix (2018), Cost elements in the rollout of 5G networks in the Netherlands – https://www.rijksoverheid.nl/binaries/rijksoverheid/documenten/rapporten/2018/04/05/onderzoek-naar-de-kosten-van-5g-uitrol-english/Onderzoek+naar+de+kosten+van+5G-uitrol+(English).pdf



this is the only option, to minimise the environmental impact through the careful

siting, design and application of technological solutions…”13

Adopting rules that are “nationally consistent” will be challenging for federal states such

as Belgium and political unions of devolved nations as in the UK. But some Member

States have already adopted rules that reduce administrative obstacles for the

deployment of base stations meeting certain size, height, volume or power restrictions,

with many more announcing plans for such changes. In Denmark, France, the UK and

elsewhere, this process is driven by national 5G action plans. Chapter 2 examines the

evolving situations in the Member States.

Our research found that, to date, legal definitions analogous to SAWAP have only been

adopted in Austria (“Kleinantennen”), Greece (“οι εγκαταστάσεις κατασκευών κεραιών

χαμηλής ηλεκτρομαγνητικής περιβαλλοντικής όχλησης” – low power, low interference

potential antenna installations), Ireland (“Small cell antenna”) and the UK (“Small cell

system”). Many more Member States have tacit definitions based on physical parameters

that provide exemptions from permits without establishing a special category for these

access points (see Table 2.2).

The current diversity of both parameters and the limits used to qualify sites for

exemptions is striking. The most common parameters are antenna height, power, size of

the equipment enclosure and where the station is located. The next chapter gives a

more complete accounting of the Member States’ policies, but here we cite just a few

examples to illustrate the diversity:

Austria: if the base station has a form factor of less than 30 litres, no site permit

is needed.

Cyprus: if the base station is “outside the boundary of urban development” then

site permits are not needed when the antenna mast is less than 25 m tall.

Hungary: no site permit is needed for radio equipment mounted on an electric

power plant, a conveyor belt or a pipeline transporting crude oil, natural gas,

sewage or district heating.

Sweden: antennas are exempted from building permits if they do not “materially

change” the appearance of the building.

Harmonisation of the exemption criteria may be aided by the fact that most EU Members

now conform to ICNIRP’s guidelines limiting human exposure to radio frequency

radiation, as advocated by Council Recommendation 1999/519/EC. Countries with

significantly lower exposure limits are Belgium, Bulgaria, Croatia, Greece, Italy,

Lithuania, Luxembourg, Poland and Slovenia.14 The extent to which these lower

“precautionary” limits might impede network densification and 5G rollout is a subject of

ongoing debate. But since typical ambient exposures to mobile network emissions in

most parts of Europe today are a small fraction of the existing safety standards15 and

13 Council of Europe (2001). “Recommendation 95 (2001) on mobile telephone base stations and local/regional authorities,” adopted by the Congress of Local and Regional Authorities of Europe, 31 May, in CLRAE Texts Adopted, 8th Session - https://books.google.com/books?id=eeYuizFtbYwC

14 In October 2018, Brussels’ Environment Minister announced a plan to raise the exposure limit in the capital area by 2020 from 6 V/m to 14.5 V/m (9 V/m indoors) but changed her mind when informed that compliance could not be verified for 5G. Lithuania announced it would be “expedient” to implement the EC's exposure limit recommendations when all the Member States adopt a common position.

15 D. Urbinello et al. (2014). “Radio-frequency electromagnetic field (RF-EMF) exposure levels in different European outdoor urban environments in comparison with regulatory limits,” Environment International, Vol. 68 - https://www.academia.edu/31383502/Radio-frequency_electromagnetic_field_RF-



many in the mobile industry argue that small cells and 5G will actually reduce average

RF exposure (by shortening link paths from handset to base station and reducing

emissions in unwanted directions)16 the impact of below-ICNIRP limits may be significant

only in “hotspots” of especially dense deployment. In Switzerland, for example, where

public RF exposure limits are about one-tenth of the ICNIRP recommendations and

although the Swiss Business Federation had said that this would “prevent any

forthcoming implementation of 5th-generation mobile networks”,17 commercial 5G

service is now available in all major cities and tourist areas and coverage of over 90% of

the population is expected by the end of 2019.18 On the other hand, limits on aggregate

field strengths have been reached at more than 6,000 out of a total of 15,000 cell sites

in Switzerland, so in many places installing 5G requires decommissioning older base

stations.19

Looking at the situation more broadly, the EC’s recent public consultation on SAWAP

rules makes it clear that the main policy issues going forward with regard to small cells

are public safety and aesthetics.20

Small Cell Aesthetics

Network densification and migration to 5G will require many more base stations than

exist today – possibly a hundred times more.21 The Small Cell Forum claims that “by

2020, the average densification project will involve 100-350 cells per km2”.22 In the

terms of reference for this project, the Commission noted that the Internet of Things

“could involve 1000 small cells [per km2] in some scenarios”.23 That might sound

ominous or implausible but it is similar to the density of Wi-Fi nodes in many European

EMF_exposure_levels_in_different_European_outdoor_urban_environments_in_comparison_with_regulatory_limits; L. E. Birks et al. (2018), “Spatial and temporal variability of personal environmental exposure to radio frequency electromagnetic fields in children in Europe,” Environment International, Vol. 117 (August) - https://www.sciencedirect.com/science/article/pii/S0160412017320597; etc.

16 M. J. van Wyk et al. (2018), “Measurement of EMF Exposure around small cell base station sites,” Radiation Protection Dosimetry, ncy201 - https://doi.org/10.1093/rpd/ncy201

17 Economiesuisse (2018), “Pas de numérisation sans infrastructure moderne de téléphonie mobile,” press release, 15 January - https://www.economiesuisse.ch/fr/articles/keine-digitalisierung-ohne-modernes-mobilfunknetz

18 J. Horowitz (2019), “5G is live in 3 countries, but we still need answers on health risks,” VentureBeat, 19 April - https://venturebeat.com/2019/04/19/5g-is-live-in-3-countries-but-we-still-need-answers-on-health-risks/

19 BAKOM (2015), Zukunftstaugliche Mobilfunknetze - Bericht des Bundesrates in Erfüllung der Postulate No-

ser (12.3580) und FDP-Liberale Fraktion (14.3149) [Future-proof Mobile Networks - Report of the Federal

Council in fulfillment of the postulates No-ser (12.3580) and FDP-Liberal Group (14.3149)] -

https://www.bakom.admin.ch/dam/bakom/de/dokumente/zukunftstauglichemobilfunknetze.pdf.download.pdf/

zukunftstauglichemobilfunknetze.pdf

20 EC (2019), “Public Consultation on the light deployment regime for small-area wireless access points,” 16 January - 10 April 2019 - https://ec.europa.eu/digital-single-market/en/news/public-consultation-light-deployment-regime-small-area-wireless-access-points

21 “The 4G radio access network (RAN) is roughly 10x denser than the 3G network, and that densification is predicted to continue through 2022 before new 5G equipment takes over the growth trend… It is predicted that 5G networks will need to be 10x denser than 4G networks, a 100x increase over 3G.” L. Getto (2019), “The Challenges of 5G Network Densification,” Microwave Journal, 14 May - https://www.microwavejournal.com/articles/32235-the-challenges-of-5g-network-densification.

22 Small Cell Forum (2018), Small cell siting challenges and recommendations, Document SCF195.10.01 – http://scf.io/en/get_email.php?doc=195.

23 “SMART 2018/0017 - Terms of Reference: Light deployment regime for small-area wireless access points,” page 2.



cities today – and the analogy between SAWAPs and Wi-Fi is not a stretch of the

imagination.

Fortunately, like Wi-Fi, most small cells (about 80%, according to the Small Cell

Forum24) are likely to be indoors, out of public view, since that is where most Internet

use occurs. This makes the challenge of absorbing so many new access points into our

milieu more tractable. However, if there were 1000 small cells per km2 and 80% were

indoors, there still could be 200 per km2 outdoors.

Because the mmWave frequencies that 5G networks are expected to use can be blocked

by window glass or walls, there will also be many situations where an antenna panel is

mounted on the outside of a building with a cable connection to the electronics package

and a retransmitter inside. Low visibility solutions will often be easier to implement if

antenna and equipment cabinet are separated. Two possible two indoor configurations

are shown in Figure 1.4.

Figure 1.4. Two possible configurations for indoor SAWAPs

Wall transceiver

BTS unit with

DC power supply

Through

wall

cabling

External

facing

MIMO

antenna

array

Wi-Fi

or 5G

Air interface

Wi-Fi hub

or 5G SAWAP

BTS unit

Fixed line

Broadband FO N/w

Wall transceiver

BTS unit with

DC power supply

Through

wall

cabling

External

facing

MIMO

antenna

array

Wall transceiver

BTS unit with

DC power supply

Through

wall

cabling

External

facing

MIMO

antenna

array

Wi-Fi

or 5G

Air interface

Wi-Fi hub

or 5G SAWAP

BTS unit

Fixed line

Broadband FO N/w

Wi-Fi

or 5G

Air interface

Wi-Fi hub

or 5G SAWAP

BTS unit

Fixed line

Broadband FO N/w

But when the antenna and equipment cabinet are separated, or the electronics are split

into several units, electric cables are needed to connect the parts. As the photograph in

the right half of Figure 1.5 shows, exposed wiring is often the most objectionable visual

feature of an installation (slotted metal angle brackets are also a problem). If the wiring

cannot be hidden inside a hollow support or conduit, it will be visible. Even though there

is wide agreement that exposed wiring is a major visual irritant, current regulations in

most Member States do not address that problem. So far as we have been able to

discover, only Spain and the Netherlands censure exposed wiring in base stations, and in

both cases it is via industry agreements on best practices rather than by regulation.

24 Small Cell Forum and Rethink (2017), “Small cells market status report - December 2017”, Document 050.10.01 - http://scf.io/en/documents/050_-_Small_cells_market_status_report_ December_2017.php.



Figure 1.5. Unaesthetic small cell installations in South Korea and the USA

Sources: SOLiD (South Korea) and Marcus Spectrum Solutions (USA)

Best practices

Developing designs for outdoor SAWAPs that are visually unobjectionable must be on

Europe’s agenda if network densification is to succeed. A carefully thought-out strategy

was developed more than a decade ago by Spain’s Sectoral Commission for the

Deployment of Radiocommunication Infrastructure.25 It provides an analytical framework

and best practice recommendations for harmonising base station design with urban,

suburban and natural environments. An English-language adaptation of one of their

texts accompanies this report as Appendix D. The Sectoral Commission is said to be

updating the text now, adding a section on SAWAP, and this new version may be a

useful model for Europe as a whole.

Design competition

A design competition organised by the city of Helsinki to develop a 5G SAWAP is another

interesting approach (see Figure 1.6). Announced at the same time as Finland’s 3.6 GHz

licence auction, the contest was co-sponsored by the city government, Nokia, Elisa, and

Ornamo Art & Design. Proposals were invited for a "standard model” that “smoothly fits

in a variety of environments” and is “unique and easily scalable” for mass production. A

jury chose five designs as finalists, then the public voted through the competition

website26 to rank the finalists for the €20,000 first prize, a €10,000 second prize and a

€5,000 third prize. The contestants retain the rights to their design, but a recent

interview with the winning team did not indicate that their design is going into

production. Nevertheless, this competition suggests the possibility of an EU-wide

version.

25 Comisión Sectorial para el Despliegue de Infraestructuras de Radiocomunicación (2005) Código de Buenas Prácticas para la Instalación de Infraestructuras de Telefonía Móvil [Code of Best Practices for the Installation of Mobile Telephone Infrastructures] - http://www.lineaverdeestepona.com/documentacion/antenas/Codigo_Buenas_Practicas.pdf.

26 https://www.open-ecosystem.org/challenges/helsinki-5g-base-station-design.



Figure 1.6. Finalist designs in Helsinki’s 5G SAWAP design competition (2018)

Source: https://www.open-ecosystem.org/challenges/helsinki-5g-base-station-design.

Street furniture

The advertising firm JCDecaux has emerged as a leading innovator in embedding

SAWAPs in street furniture. Their European project manager, spoke at our stakeholder

workshop offering insights from his broad experience. One of JCDecaux’s first

installations (in Amsterdam) is illustrated on the cover of this report. Since that

photograph was taken, the company has reduced the size of its LTE equipment package

by 80%. It is no longer necessary to mount it on the roof of a bus shelter: it can be

hidden behind the advertising placard. This may be useful as many cities want SAWAPs

to be completely invisible, though this is not always the case. There is considerable

variety in municipal preferences. It is usually necessary to present decision makers with

several designs and see which they prefer. That makes standardisation difficult across

one country, let alone multiple countries.

Bus shelters are excellent platforms for SAWAPs but because the SAWAP is so close to

people, the RF output must be small for safety reasons (typically 0.1 – 1.0 V/m). That

means the signal range is also limited – just enough to provide good connectivity around

the bus stop.

However, there is a large inventory of usable street furniture of other types, with very

different form factors: traffic lights, billboards, lamp posts, etc. Consequently, a new

business is emerging: integrating SAWAPs with street furniture. The challenge is doing it

well: no one wants bad-looking or unsafe equipment drawing attention to itself. While

street lamps are often suggested as an alternative to the antenna mast, they are not

always strong enough to support the added weight of a SAWAP. Even fewer can support

two, making the sharing of street lamps difficult (notwithstanding the photo at the start

of this section showing a dozen SAWAPs on one lamp post in Korea). At least the first

wave of 5G equipment with MIMO antenna arrays will probably be larger and heavier

than LTE equipment. That might slow the evolution from LTE to 5G if 5G SAWAPs cannot

be simply “drop in” replacements for LTE.

Bulky SAWAPs are harder to hide but still possible to integrate with existing street

furniture. And as suggested above, hiding is not always the right solution. When a Dutch



newspaper27 reported that cellular transmitters had been installed in hundreds of bus

shelters in Amsterdam and 5G will require thousands more, city officials were flooded

with complaints about covert exposure of the population and growing opposition to the

goal of blanketing the city with small cells. To reassure the public, the Ministry of

Economic Affairs agreed to make Holland’s voluntary limits on RF exposure mandatory.

This was endorsed by the Dutch Cabinet.28

Does that mean in Amsterdam the “low visibility” approach backfired? There is an

inherent conflict between camouflage/concealment and transparency. When the public

senses that mobile networks are trying to hide something, paranoia grows. On the other

hand, as pointed out in the workshop, the lack of vandalism directed against -the bus

shelter deployments offers proof of public acceptance.

Thus, the conclusion seems to be not that the “low visibility” strategy backfired, but that

hiding small cell equipment is not enough. Sceptics may think operators are hiding some

greater mischief when claiming that the purpose of “low visibility” designs is to protect

the city’s visual environment. That is why this study recommends additional measures:

engaging the public in activities like a SAWAP design competition, an EU commitment to

funding more research into the bioeffects of radio waves and an integrated multilevel

information/promotion campaign. Publicising 5G tests and small cell rollouts in advance

must be done sensitively, emphasising that the environment is being protected and

always within EU and national RF safety limits.29 As an ITU expert meeting on EMF levels

and 5G rollout concluded:

Actions of national regulators and network operators must be accompanied to the

greatest possible extent by transparency and communication with citizens… A

core role accords to politicians and authorities in order to lower the concerns of

the public. Public awareness campaigns coming from operators do not have the

same credibility in the eyes of the public… [However] the criteria defining when a

campaign is successful or not is challenging to characterize.30

Our stakeholder workshop highlighted the need for diverse design solutions. Not only

does street furniture offer many different form factors, but not all urban environments

look alike. What blends with the surroundings in one place might not work everywhere.

For that reason, the European Commission has suggested creating a catalogue of SAWAP

designs approved somewhere in Europe which other places can select from as a menu of

already approved options. In addition, type approvals for SAWAPs would assure

conformance to safety and technical standards and facilitate deployment, just as

standardised electrical sockets simplify the planning of building wiring.

27 P. Winterman (2018), “Straling antennes aan banden: onduidelijkheid over gevaar volksgezondheid” [Mobile antenna radiation: uncertainty about public health risks], Algemeen Dagblad, 27 March - https://www.ad.nl/politiek/straling-antennes-aan-banden-onduidelijkheid-over-gevaar-volksgezondheid~a388a34d/.

28 Government of the Netherlands (2018), “Voor alle Nederlanders in 2023 snel vast internet” [Fast fixed internet for all Dutch people in 2023], news release dated 11 October - https://www.rijksoverheid.nl/actueel/nieuws/2018/07/03/voor-alle-nederlanders-in-2023-vast-snel-internet.

29 GSMA and the Mobile & Wireless Forum (2017), Risk Communication Guide for Mobile Phones and Base Stations: Practical guidance and support on good risk communications practice for the mobile industry - http://emfhealth.info/docs/eng/2017_MWF_GSMA_RiskCommunicationsGuide.pdf

30 ITU (2017), “Report of the Expert Meeting on Electromagnetic Field Level and 5G Rollout,” 2-3 November, Rome - https://www.itu.int/en/ITU-D/Regional-Presence/Europe/Documents/Events/2017/EMF/2017-12-04%20Expert%20Meeting%20ReportFinal.pdf



We may soon have a chance to see what happens when small cells are deployed on a

large scale without aesthetic considerations. The US Federal Communications

Commission (FCC) adopted rules31 in September 2018 stating that local authorities

cannot impose aesthetic requirements on “small wireless facilities” that are “more

burdensome than those applied to other types of infrastructure deployments”. Since

there are generally no aesthetic requirements imposed on electricity pylons, natural gas

pipelines, water pipes, cable TV distribution cabinets, etc., they cannot be imposed on

small wireless base stations either. More than 80 cities in America have gone to court to

block these new rules so it remains to be seen if they will be implemented.32 It is also

significant that the FCC’s own Technological Advisory Council has come out against the

policy. At its meeting in March 2019, the Council adopted this resolution:

The roll out of 5G is likely to be slowed appreciably by public resistance to

installation of small cells in their communities and neighbourhoods. Small cell

installations can be designed to better blend in with the surroundings, potentially

lessening resistance to their presence. We recommend that the FCC use its

influence with the cellular industry to strongly recommend the development and

maintenance of guidelines/industry standards to improve the appearance of small

cell installations. We recommend that the FCC:

Issue a Public Notice to gather input from providers, citizens and communities

Facilitate a multi-stakeholder group to create such guidelines.33

The FCC has not yet responded to these recommendations.

1.4 The Study Methodology

At the start of this project, the study team drafted questionnaires for national regulators,

standards organisations, mobile network operators, associations of local planning

officials, construction permitting agencies, current base station installers and other

stakeholders. Questions put to regulators, for example, included:

What are the physical and technical characteristics used to define a “small cell”

and to distinguish it from wireless cells subject to stricter authorisation

requirements in your country?

Under what conditions are exemptions or releases given from requirements for an

individual site permit?

Did you negotiate privately with stakeholders to reach agreement on the

technical characteristics qualifying small cells for a “light deployment regime”?

31 FCC (2018), “Declaratory Ruling and Third Report and Order in the Matter of Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment,” WT Docket No. 17-79; WC Docket No. 17-84, adopted 26 September - https://docs.fcc.gov/public/attachments/FCC-18-133A1.pdf

32 US Court of Appeals for the District of Columbia (2019), Case No. 18-1129: “On Petitions for Review of on Order of the Federal Communications Commission” - https://www.cadc.uscourts.gov/internet/opinions.nsf/4001BED4E8A6A29685258451005085C7/$file/18-1129-1801375.pdf

33 FCC (2019), Technological Advisory Council – Antenna Technology Working Group meeting presentations, 26 March - https://transition.fcc.gov/oet/tac/tacdocs/meeting32619/TAC-Presentations-3-26-19.pdf



Information extracted from the questionnaires permeates this report and informs the

detailed country profiles in Appendix A.

In addition to the dozens of written responses received, a range of telephone interviews

were conducted with specialists and experts, sometimes as a follow-up to questionnaires

(to expand upon or clarify written answers), but more often to expand the variety and

range of information sources consulted. Information from these interviews also

permeates this report and was an especially important source for news about national

legislation and the state of development. Research on the state of play into 5G

technology was also examined, especially with the leading European standards fora – the

3GPP/ETSI and CENELEC-IEC initiatives, whose leading technical experts provided useful

inputs.

On 22 November 2018, the European Commission hosted an all-day stakeholder

workshop in Brussels attended by over 100 people.34 After some initial findings were

presented, panel discussions in the morning and discussion groups in the afternoon

looked more deeply at possible parameters and physical dimensions for defining SAWAPs

as well as alternatives to permits and elements of a practical “light regulation regime”.

An open public consultation on a light deployment regime for SAWAPs was conducted by

the Commission from 16 January to 10 April 2019.35 Twelve individuals and 21 industry

groups responded. Differences between the responses from individuals and from

industry were significant. While no questions were asked about the possible impact on

public health of large numbers of new small cells, many individuals emphasised that as

their main concern. Also, frequently expressed was concern about visual clutter (75% of

the responses from individuals). As one government official from Austria put it, “We as

regional administration know how difficult rapid network expansion can be if there are

fears in the population. Dealing with citizens' concerns sensitively must be taken into

account.”

Some industry groups, on the other hand, expressed impatience with the amount of

technical information sought by local officials and what they perceived as a lack of

understanding about how cellular technology works. This gap in perspective between

industry and the public is an unfortunate but crucial feature of the policymaking

environment.

The study’s interim results were also presented to two interested communities:

The European spectrum regulators’ forum, the RSPG, who gave immediate and

strong feedback on the core findings, which have been taken into account in this

report.

The Communications Committee (COCOM), consisting of representatives from the

Member States with agendas for the development of 5G networks. For COCOM,

the presentation was an information input, which also yielded several interesting

later responses.

34 A report about the Stakeholder Workshop accompanies this report as Appendix E. In addition, the workshop agenda, background notes, the opening presentation and discussion group reports are online at https://ec.europa.eu/digital-single-market/en/news/workshop-light-deployment-regime-small-cells-across-eu

35 https://ec.europa.eu/digital-single-market/en/news/public-consultation-light-deployment-regime-small-area-wireless-access-points



2. Current Regulation of SAWAP Deployment in

the EU Member States

This chapter analyses current regulatory requirements for deploying small-area wireless

access points in the EU Member States as well as current exemptions from local building

permits and other prior authorisations. Appendix A provides more documentation,

background and explanation of these matters.

The following topics were assigned as Task 2 by the terms of reference for this study:

Analysis of the current regulatory requirements for small-area wireless access

points deployment in each Member State. The study should detail what permits

are required, what are the criteria for granting the permits (including aesthetics

and emission power limits) and their costs and timelines for operators at both

national and, where relevant, regional or local level, as well as the possibility and

conditions for exemptions. In this regard, administrative barriers which prevent

the deployment of small-area wireless access points within the scope of draft

Article 56 [now Article 57] of the EECC should be identified. An estimate of the

workload implications resulting in costs and delays for both operators and

competent authorities should also be provided. Furthermore, the contractor

should address the problem of setting-up a large number of small-area wireless

access points in the same place and present ways to deal with that issue.

That last subtopic – dealing with large numbers of co-located SAWAPs – is addressed in

Chapter 5 in the context of network densification.

Since the EECC’s definition of a SAWAP does not yet include physical parameters,

requirements for “small cell” permits and exemptions are considered here however the

countries define them in practice. Often the definition is tacit, based simply on the

requirements for permit exemption, rather than on a formally defined classification. To

date we have found legal definitions analogous to SAWAPs only in Austria, Greece,

Ireland and the UK. These SAWAP-like definitions are included in Table 2.2.

Most local authorities understand that their citizens want good wireless network services

even if they dislike antenna masts. But for macrocells, the experience of the network

operators, installers and site developers has been that the process of getting permits is

complex, arduous and slow. However, the Member States are quite aware of the

Commission’s interest in streamlining approvals for small cells and making the

procedures and requirements consistent throughout the region. Thus, many of them are

already preparing legislation to achieve these purposes.

2.1 Permits and Exemptions

Without knowing what permits are currently required, one cannot identify exemptions

that could or should be implemented. Table 2.1 presents an overview of the permits

normally required to deploy base stations in each Member State. Note, however, that

exemptions are often already available, without being harmonised across the EU. This

table indicates what the permissions landscape would look like without the existing

exemptions:



Table 2.1. Local permits needed to deploy base stations (exemptions omitted)

Country Permits needed

Austria Building permit

Belgium Brussels capital: “urban development permit” and an environmental permit

Flanders: “certificate of conformity”

Wallonia: a building permit and an environmental declaration

Bulgaria Building permit

Croatia Location permit, construction permit, certificate of compliance with RF regulations and (for base stations mounted on occupied buildings) a use permit.

Cyprus Building permit. A planning permit may also be required under certain conditions.

Czech Rep. “Territorial decision” or “territorial consent” (the latter requires an environmental impact assessment).

Denmark Zoning and land use permits

Estonia Building permit and maybe a “use and occupancy” permit

Finland Activity permit [toimenpidelupa] or if no mast is involved, an “attachment to building” permit [Liitteet rakennuslupaan]

France Building permit

Germany “Site certificate” [standortbescheinigung]

Greece Antenna Construction License. Before a site can begin transmitting, EETT must issue a Certificate of Completion.

Hungary Until a 2017 decree exempted 4G and 5G base stations from local permits, “principle building permits,” construction permits and “retention permits”

[fennmaradási engedély] had been required.

Ireland Planning permission

Italy Permits from the municipality and regional health and safety agencies. Permits may also be needed from the Department of National Heritage and Cultural Activities.

Latvia Building permit

Lithuania Building permit [Statybą leidžiantis dokumentas]

Luxembourg Environmental permit and zoning permit

Malta Development planning permit

Netherlands Environmental permit

Poland Construction permit

Portugal Municipal authorisation (building permission)

Romania An “urbanism certificate” [certificatului de urbanism] and a construction permit

[autorizației de construire contractul]

Slovakia A land use or zoning decision and possibly a building permit

Slovenia Building permit

Spain “Municipal license for the installation, commissioning or operation of telecom infrastructures” [Licencia municipal para la instalación, puesta en servicio o funcionamiento de infraestructuras de telecomunicación]

Sweden Building permit

United Kingdom

Electronic communications development permit

Source: National laws of the Member States.



Most Member States do not have different permit requirements for base stations with

different dimensions until the low end of the scale is reached, whether that low end is

defined by transmitter power, antenna height or some other metric. Table 2.2

summarises what has been learned about existing exemptions for small cells, however

that term is defined.

Table 2.2. Small cell permit exemptions

Member State

Definition

Austria “Kleinantennen” (small antennas): radio equipment which does not exceed the form factor of 0.03 m3 [30 litres].36 Even before passage of the new telecom law, some Länder had special rules exempting small base stations from building

permits: in Salzburg, rooftop stations with masts less than 2 m tall; in Upper Austria and some cities in Bergenland, rooftop and greenfield deployments less than 3 m tall; in Lower Austria, base stations without masts; etc.

Belgium Brussels: radio links, radiating waveguides, remote antenna systems and stations

with EIRP less than 2 W do not need environmental permits.

Flanders: no environmental permit is needed for transmitters with ERP of 2 W or

less. No building permit is needed for antennas added to existing structures if the antenna does not increase the structure’s overall height.

Wallonia: fixed installations of transmitting antennas with EIRP under 4 W need

not be declared.

Bulgaria No small cell definition

Croatia No small cell definition

Cyprus “It is not necessary to submit an application and obtain an urban planning permit for a radio station covered by a valid General or Special Development Ordinance…”.37 Planning permits are also not required for radio stations built on

the ground outside the boundary of urban development when the antenna mast is less than 25 m tall; built on a building roof when the antenna mast is less than 9

m above the main roof level; when the antenna mast height is less than 6 m on an unoccupied two-story building; or when the equipment cabin is less than 3 m tall and the ground area is under 6m2.

Czech Republic

Antenna masts up to 8 m in height (including their support structures) do not require building permits or location approvals.

Denmark Local planning and zoning permits are not needed for: “Panel antennae for mobile communication with associated radio modules and transmission links in neutral

colours, set on existing masts used for public mobile communications, silos or high chimneys, when the height of the building is not increased [or for radio technology cabinets] with a maximum floor plan of 2 m2 and a maximum height of 2.5 m for use with the antennas mentioned and mounted on or immediately at the mast, silo or chimney”.38 (These exemptions apply only to cellular mobile network antennas on already approved and deployed masts. Masts at new sites need municipal approval.)

Estonia According to GSMA, no permits required for base stations with ERP less than or

36 “Kleinantennen: Funkanlagen, die den Formfaktor von 0,03 m3 nicht überschreiten” – added to the Telecommunications Act in 2018 by Federal Law No. 138/2017, Article 1 § 5 Z 36, Bundesgesetzblatt für die

Republik Österreich, 30 November 2018, https://www.ris.bka.gv.at/Dokumente/BgblAuth/BGBLA_2018_I_78/BGBLA_2018_I_78.pdfsig.

37 Article 22 of the Urban and Spatial Planning Law [Πολεοδομίας και Χωροταξίας Νόμο] - http://www.moi.gov.cy/moi/tph/tph.nsf/All/2809495D14AEA64EC22581B5001AF2DC/$file/ΚΔΠ 309_99 (παρεκκλιση)_& Τροπ ΚΔΠ 120_2005.pdf.

38 https://www.retsinformation.dk/Forms/R0710.aspx?id=200614.



equal to 100 W.

Finland Local building ordinances can exempt minor projects (like small antenna masts)

from “action permits” or replace permit requirements with prior notification.

France No declaration or ANFR authorisation is needed for stations radiating less than 1 W EIRP. Any station operating on an assigned frequency at 1-5 W EIRP must notify ANFR and the local governing authority about the station’s technical characteristics. ANFR/ARCEP’s joint response to our questionnaire indicates that

the 1-5 W power category is their de facto definition of small cells.

Germany Radio stations with EIRP of 100 mW or less do not need site certificates. BNetzA must be notified two weeks in advance about the commissioning of new or substantially modified stations whose EIRP is greater than 100 mW but less than

10 W and civic authorities must be informed at the same time.

Greece “Low power, low electromagnetic interference potential antenna installations” (οι εγκαταστάσεις κατασκευών κεραιών χαμηλής ηλεκτρομαγνητικής περιβαλλοντικής

όχλησης - ΕΚΚΧΟ). These are exempt from Antenna Construction Licenses so

they do not need planning or environmental approvals. Like SAWAP, both licensed and licence exempt radios are included, but there are many distinct sub-types, each defined by specific physical parameters. Generally they are less than 4 m in height with “total radiant power” less than 100 W (164 W EIRP).

Hungary No construction permit or notification to the NRA is required to deploy a licensed

radio station which is: less than 3 m above the ground and less than 15 m2 in area; on a building if it can be deployed without reinforcing the building’s structure; mounted on an electric power plant, a conveyor belt, plumbing or a pipeline transporting crude oil, natural gas, sewage or district heating. Deployment of antenna masts requires no NMHH notification or construction permit when: the largest physical dimension of the support is less than 6 m with lightning protection; the antenna itself does not measure more than 4 m in any

dimension and does not require structural reinforcement; the purpose of the installation is to establish a link up to 100 m in length connecting the site to an existing, legally registered electronic communication network.

Ireland “Small cell antenna” is defined as: “(a) Operates on a point to multi-point or area

basis in connection with an electronic communications service, (b) Including any power supply unit or casing but excluding any mounting, fixing, bracket or other support structure: (i) Does not, in any two-dimensional measurement, have a surface area exceeding 0.5m2, and (ii) does not have a volume exceeding 0.05 cubic metres, and (c) Subject to paragraphs (a) and (b), includes a femtocell antenna, a picocell antenna, a metrocell antenna, a microcell antenna, and any similar type antenna.”39

Italy In certain parts of the country, for base stations <10 W and surface area <0.5 m2 the local planning authority requires notification but does not have to decide on a permit. In other regions, exemption for stations with <5 W into the antenna. In still other regions, <5 W means less paperwork but no exemption.

Latvia A municipal building permit is needed only for telecom projects that require ground breaking or for projects that reduce the bearing strength or stability of an

existing construction. Base stations installed on the street side of a building facade or in public outdoor areas must be coordinated with the building authority. Coordination is said to be simpler and faster than getting a permit and can be

considered a permit exemption.

Lithuania Exemptions were found only for repeaters and for transmitters inside buildings.

39 Planning and Development (Amendment) (No. 3) Regulations 2018 (Statutory Instrument S.I. No. 31 of 2018) came into effect on 8 February 2018 and added the definition for “small cell antenna” to Article 5 of the Planning and Development Regulations, http://www.irishstatutebook.ie/eli/2018/si/31/made/en/print.



Luxembourg Before April 2016, individual site authorisations were not needed for base stations

delivering less than 100 W to their antennae. But then the limit was lowered to 50 W to expand protections for the public against radio exposure.

Malta According to GSMA, base stations on “non-sensitive” sites in the Development Zone are exempt from development permits.

Netherlands Environmental permits are not required for mobile communication antennas mounted above 3 m on existing cell towers, high-voltage pylons, road portals,

advertising columns, light poles, windmills, siren masts or freestanding chimneys. Environmental permits are also not required of antennas (including the mast) less than 5 m tall or small cells less than 0.5 m tall on street furniture.

Poland No small cell definition.

Portugal No small cell definition

Romania No building permit is needed for equipment operating under general authorisation

(WLANs) which does not require a foundation or platform.

Slovakia For communications equipment and “engineering structures” less than 6 m tall and less than 2.5 m wide, notification of the local building office is sufficient, in lieu of a permit.

Slovenia “Simple communication facilities” are said to not need a building permit, but no regulation defining that term has yet been found.

Spain Radio stations emitting less than 1 W need no permits – a simple signed notice to

the municipality is enough. Radio stations on private property no longer require a “licencia municipal.” However, the installer must still pay the municipal site tax, submit a notice of work completion and a statement of responsibility for compliance with the Building Code.

Sweden Antennas are exempted from building permits if they do not “materially change” the appearance of the building. (The meaning of “materially change” is subject to interpretation, and for buildings in protected areas or of historical interest, a

building permit is always needed regardless of the base station’s size.)

United

Kingdom

“’Small antenna’ means an antenna which (a) is for use in connection with a

telephone system operating on a point to fixed multi-point basis; (b) does not exceed 0.5 metres in any linear measurement; and (c) does not, in two-dimensional profile, have an area exceeding 1,591 square centimetres, and any calculation for the purposes of paragraph (b) or (c) excludes any feed element, reinforcing rim mountings and brackets; ’small cell system’ means an antenna which may be variously referred to as a femtocell, picocell, metrocell or microcell

antenna, together with any ancillary apparatus, which (a) operates on a point to multi-point or area basis in connection with an electronic communications service (as defined in section 32 of the Communications Act 2003(a)); (b) does not, in any two-dimensional measurement, have a surface area exceeding 5,000 square centimetres; and (c) does not have a volume exceeding 50,000 cubic centimetres, and any calculation for the purposes of paragraph (b) or (c) includes any power supply unit or casing, but excludes any mounting, fixing, bracket or

other support structure…”40

Source: SCF Associates Ltd, survey of NRAs, relevant administrations and ministries,

installers/mobile cell site operators, Sept 2018-July 2019.

The EU Member States have thus made different choices in the parameters used to

define eligibility for exemption from local permits. However, the parameters seem to

form clusters sorted into logical groups, as shown in Table 2.3:

40 Section A.4 of the Town and Country Planning (General Permitted Development) (England) (Amendment) (No. 2) Order 2016 - http://www.legislation.gov.uk/uksi/2016/1040/pdfs/uksi_20161040_en.pdf



Table 2.3. Parameters used to grant exemptions

Groups Sub-groups Details Number of MS

Location

Outside built-up area

Cyprus: on ground outside boundary of urban development when antenna mast is <25 m tall

3

Indoors Lithuania: “transmitters inside buildings”

Spain: in privately owned buildings

Mounting

Rooftop Cyprus: mast is <9 m above main roof level or

<6 m on unoccupied two-story building

5

Building facade Sweden: does not “materially change” building appearance

Building

without reinforcement

Hungary: can be deployed without reinforcing

building structure

Latvia: does not reduce “bearing strength or stability” of an existing construction

Street furniture Netherlands: <0.5 m tall on street furniture

Total size Form factor

Austria: form factor <0.03 m3 [30 litres]

Hungary: <15 in area and <3 m above the ground; largest physical dimension of the support is <6 m with lightning protection; the antenna itself no more than 4 m in any dimension

Ireland: in any 2D measurement surface area

<0.5 m2 and volume <0.05 m3

UK: in any 2D measurement surface area <5,000 cm2 and volume <50,000cm3

4

Power

ERP

Belgium: Flanders: ≤2W

Estonia: Health Board approval not needed ≤100W

8 EIRP

Belgium: Brussels: <2W; Wallonia: <4W

France: no authorisation needed for stations <1W, notification for stations operating 1-5 W

Germany: “BNetzA must be notified two weeks in advance about… stations whose EIRP is

greater than 100 mW but less than 10W”

Greece: “Submission of a technical study is not required for stations whose total active radiant power… does not exceed 100 W (164 W EIRP)

Antenna input

Italy: radiating surface < 0.5m² and power <7 W at the antenna input

Luxembourg: <50 W

Antenna Mast height Belgium: Flanders – no height increase when added to existing structure

Czech Republic: Antenna masts <8 m in height

7



including support

Hungary: <3 m above ground and <15 m2 in area

Netherlands: antennas (including mast) <5 m tall or mounted above 3 m on existing mast

UK: 8-25 m (depending on location and type of mount)

Panel type

Denmark: “Panel antennae for mobile

communication with associated radio modules and transmission links in neutral colours, set on existing masts used for public mobile communications, silos or high chimneys, when the height of the building is not increased”

Radiating area Italy (some regions): radiating surface

<0.5m² and power <7 W at the antenna input

Appearance

Denmark: “Panel antennae for mobile communication with associated radio modules and transmission links in neutral colours”

Poland: “low impact on the landscape”

Sweden: does not “materially change” building appearance

3

Equipment cabinet

Cyprus: <3 m tall and ground area <6 m2

Denmark: floor plan <2 m2 and height <2.5 m, used with panel antenna in neutral colour and mounted on mast, chimney, etc.

2


installers/mobile cell site operators, Sept 2018-July 2019.

Table 2.3 shows that the most widely used parameters to qualify small base stations for

exemption from local permits are antenna mast height and transmitter power. But

interestingly, these two parameters are not combined, as one would expect if coverage

area or signal range were of primary interest. The type of antenna mount is also a

consideration (façade, rooftop, street furniture, etc.).

The following table summarises the power outputs which Member States currently use to

exempt small cells that would qualify as SAWAPs from local permits, in relation to their

human exposure limits:



Table 2.4. Permit exemptions based on base station power

Country BTS Power output (how defined) RF exposure limits for

the general public

Austria No power-based exemptions found ICNIRP

Belgium Brussels: no permits required for base stations with

EIRP <2 W

Flanders: no environmental permit needed for

transmitters with ERP ≤2W

Wallonia: base stations with EIRP <4W are exempt

from “environmental declaration” (building permit

still needed)

Precautionary

Bulgaria No power-based exemptions found Precautionary

Croatia No power-based exemptions found Precautionary

Cyprus Base stations emitting <63 W exempt from planning

permits

ICNIRP

Czech Rep. No power-based exemptions found ICNIRP

Denmark No power-based exemptions found ICNIRP recommended but

not mandatory

Estonia No permits or Health Board approval needed for base

stations with ERP ≤100W

ICNIRP

Finland No power-based exemptions found ICNIRP

France No declaration or ANFR authorisation needed for

stations <1 W EIRP. For stations emitting 1-5 W

EIRP, only notification to ANFR and the local

governing authority about the station’s existence and

technical characteristics needed

ICNIRP (except in Paris)

Germany BNetzA and civic authorities must be notified about

the deployment of stations emitting more than

100mW but less than 10W EIRP. Stations emitting

<100mW EIRP do not need a site certificate

ICNIRP

Greece “Low power, low interference potential antenna

structures” are exempt from Antenna Construction

Licenses so they do not need planning or

environmental approvals. These are similar to

SAWAP but with many defined subtypes. In general

they are <100 W (164 W EIRP).

Precautionary

Hungary No power-based exemptions found ICNIRP

Ireland No power-based exemptions found ICNIRP recommended but

not mandatory

Italy In some areas, complete or partial exemption if <5

W; in other areas, if <10 W just notify local planning

authorities

Precautionary

Latvia No power-based exemptions found ICNIRP recommended but

not mandatory

Lithuania Base stations emitting <25 W ERP do not need public

health authority certification

Precautionary

Luxembourg Stations <50 W do not need individual site

authorisations

Precautionary



Malta No power-based exemptions found ICNIRP

Netherlands No power-based exemptions found ICNIRP recommended but

not mandatory

Poland No power-based exemptions found Precautionary

Portugal No power-based exemptions found ICNIRP

Romania Exemption only for stations operating under “general

authorisation” (e.g. Wi-Fi)

ICNIRP

Slovakia No power-based exemptions found ICNIRP

Slovenia No power-based exemptions found Precautionary

Spain Stations <1 W exempt from permits ICNIRP

Sweden No power-based exemptions found ICNIRP

United

Kingdom

No power-based exemptions found ICNIRP recommended but

not mandatory


installers/mobile cell site operators, Sept 2018-July 2019

Table 2.4 reveals that a majority of Member States which have relatively high power

limits exempting small cells from permits (Greece, Lithuania and Luxembourg) also have

precautionary human exposure limits. Thus, leniency for permit exemptions is often

“ring fenced” by emission limits stricter than the ICNIRP guidelines, so it would be

misleading to cite those high-power limits as a guide for countries with less severe limits

on human exposure.

2.2 Time and Cost

Meaningful data about the workload imposed on network operators and local

administrators by the existing permit requirements proved impossible to collect. All the

MNOs we surveyed left this question blank or indicated that they consider this

information confidential. Local authorities, on the other hand, generally do not track the

time allotted to processing specific projects.

Even discovering how long it takes to get a permit issued proved challenging. Fees are

usually set by law but legally mandated time limits on decision making do not always

reflect the actual wait times. There are indications that the time needed to prepare an

application or reach a permit decision varies according to the project’s simplicity or

complexity, how much controversy it provokes and especially whether land-use rules

must be modified or waived.

Table 2.5 summarises what we were able to learn about the time and fees needed to

obtain local permits for base station deployment:

Table 2.5. Time and fees required for local permits

Member State

Time required Permit costs

Austria Varies by region, from an average of 10 weeks up to 6 months

Wide variation by region

Belgium Varies by region, from 60 days in Wide variation by region



Wallonia up to 700 days in Brussels

Bulgaria Varies from 7 days to a year Varies from city to city, but outside the capital typical fees are 400-1000 leva (€200-€500) for a roof-top to 600-1000 leva (€300-€1000) for construction on the ground

Croatia 15 days for Certificate of Compliance but no time limit on local planning permits

More research needed

Cyprus 6 weeks is the legal limit but 6 months is more typical

Varies from one municipality to another but could be thousands of

Euros

Czech Rep. 30-90 days €39.30 for a territorial decision or

€19.65 for territorial consent

Denmark No more than 6 months, much faster if no environmental protection issues

Depends on which services requested from which municipalities

Estonia 20 days (10 + 10) separated by actual construction

€85

Finland More research needed €500 - €800

France 3-6 months, 9 months in difficult cases €160.70 (annual site tax for small cells)

Germany Up to 8 weeks Varies from place to place and by project complexity

Greece ~4 months €340

Hungary 8 days €21.40 for county environmental permit, €76.30 to use municipal property, up to €2,290/m2 to license

antenna and mast.

Ireland Legal maximum is 4 months, after which permit is “deemed granted.”

Fee exemptions for mobile broadband infrastructure were approved nationally in 2013 but it is uncertain if all local

planning authorities have implemented this policy yet. Some may still charge €240-€600 per site, or more for site renewals.

Italy Evidence from installer organisations is that delays for permits may be avoided

for BTS below 10 W emitted power under certain conditions. For larger base station sites delays may be several months but are highly variable.

If a deployment permit is needed it generally costs less than €100 (one-

time payment), but there may also be site survey costs.

Latvia Permits issued or denied within 1 month Cost for VAS ES to consider a request to approve a new public land mobile base station is €35.57. An additional €7.11 is charged for VAS ES to examine the submitted request. An

additional €113.55 must paid upon approval of the project, or €170.32 for



accelerated processing (within 3

business days). If the request is to share an existing installation, approval costs €24.33 per antenna, or for

accelerated processing €36.50 per antenna (within 3 business days).

Lithuania Decisions by national public health authority about the radio technical part of the project (compliance with EMF

limits, approval of the EMF monitoring plan) must be made within 20 working days. In case of a repeat request regarding the same installation, decision made within 15 working days. Decisions on the building permit should take no

more than 20 business days for “special

purpose” projects, 10 business days for all other projects. After site launch, the owner of the installation has up to 20 working days to make the EMF monitoring measurements. Results of the measurements are due at the

national public health authority within 15 working days after they are available or within 24 hours they show that EMF limit values are exceeded.

€29 fee for agreement that the radio technical part of the project complies with EMF public health requirements,

plus €29 fee for agreement on the EMF monitoring plan.

Luxembourg Typically 2 months Every urban area sets their own fees.

Malta Applications for planning permits are decided in 15 days plus 15 more days for public comment. Hearings are held within 2 weeks and then the decision is

due within 2 months. So the whole process takes 8-12 weeks (or 42 days for “summary applications”) and applicants can ask for a partial refund of the processing fee if the time limits are exceeded.

A “full development permit” costs €19,695 plus €450 to process the Notice of Completion. But such permits are rarely required, certainly not for

small base stations.

Netherlands Permits for base stations mostly not needed but environmental permits often needed for buried backhaul links. Time varies from one municipality to another.

€258 if one is needed at all.

Poland Permit regulations under review – past practices may no longer be relevant

Permit regulations under review – past practices may no longer be relevant

Portugal Less than 30 days Locally determined (eg €35-€525 for

authorisation to install a new base station, then €1400-€4377 per antenna per year if installation is on city property.)

Romania Property owner must apply for an “urbanism certificate” to verify that supporting a base station is an allowed use of the property – this will be decided within 30 days. Then issuing a building permit is to be decided within 30 days. But actual processing

The “urbanism certificate” seems to be free of charge, but the cost of a building permit is 0.9% of the construction project’s cost.



apparently takes months.

Slovakia Depends on project complexity and local site restrictions, generally 30-90 days.

€30 - €200 per site, depending on location and project complexity.

Slovenia Time allowed by law is 60 days, which is often but not always achieved.

If full vetting required, the cost can be up to €789.

Spain From one to several months, depending on jurisdiction. But permits mostly not needed anymore.

Permits have mostly been replaced by installers’ statements of responsibility and notices of work completion.

Sweden Generally 10-20 weeks, but “worst cases” can take up to a year.

Differs from one municipality to another.

United Kingdom

8 weeks for “prior approvals” and “full development planning permits”

In England, £462 for full planning applications or prior approval. In

Scotland, £401 for full planning

applications, £300 for prior approval. In Northern Ireland £357. If an operator wants a pre-application consultation with a planning authority, there will often be a charge for this, with costs varying widely.

Source: SCF Associates Ltd, survey of installers/mobile cell site operators, with inputs from

relevant administrations and NRAs, Sept 2018- July 2019.

Administrative Barriers

Two types of administrative barriers to the deployment of SAWAPs have been identified:

Some result from the need to protect property rights and values, e.g. not

allowing base stations on roofs that might cause a building’s structure to become

unsafe, or denying permits to projects that building owners, tenants or

neighbours oppose.

Other barriers are justified by consistency with past practice, when larger, more

powerful and visually intrusive base stations were the norm. Providing a clear

physical definition of cells entitled to more lenient regulation so they can be

distinguished from those where existing limitations are still justified is the

primary purpose of this investigation and it is hoped that the removal of

inappropriate limits on future deployments will result from this study.

2.3 An Alternative to Permits: Notification

About one third of the EU Member States currently offer developers of base station sites

the opportunity to use notification (of the regulator, of the city council, of the planning

authority, etc.) as an easier alternative to obtaining building/planning/environmental

permits. The examples in Table 2.6 illustrate how the concept works in practice. Such

alternatives could be implemented by additional countries as part of the harmonisation

and “regulatory lightening” process. Because inspections and mapping may be advisable

for sites at the high end of the SAWAP power spectrum, we recommend that notification

be used in the future as an alternative to permits for SAWAPs rated between 2 and 10

watts:



Table 2.6. Existing uses of notification as an alternative to permits for small cells

Country Example

Czech Rep. Antenna masts <8m tall do not need permits but building authority must

be notified when construction is finished.

Finland Local building ordinances can exempt minor projects from “action

permits” - or may require prior notification instead.

France No approval needed for 1-5 watts EIRP stations but operators must notify

ANFR & local authorities about the station & report its characteristics.

Germany BNetzA must be notified 2 weeks in advance about commissioning of new

or substantially modified stations with EIRP >100mW but <10 W.

Ireland ComReg has a definition of “small cell antenna” that exempts them from

permits, but local planning authority must be notified about proposed

antenna location at least 4 weeks before attachment.

Italy In some regions, local planning authority must be notified about base

stations with <10 watts into the antenna connector and antenna area

<0.5 m2.

Spain Statement of work completion and payment of site tax accepted in lieu of

“licencia municipal.”

Sweden Notices for minor changes in existing sites, permits for substantial

changes.

United

Kingdom England: neither prior approval nor full planning permission needed for

“small antenna systems” if local authority notified at least 28 days after

completion of installation or 56 days before start.



3. International and Non-EU Small Cell Initiatives

The terms of reference for this study define Task 3 as:

Analysis of any relevant situation in non-EU countries, as well as any

international initiatives regarding the adoption of generic criteria for the

exemption of small-area wireless access points [SAWAPs] from the approval

process, i.e. regarding the maximum antenna height, size, weight, emission

power, power supply unit, etc.

Thus, this chapter briefly examines international efforts to define “small cells” and the

solutions of selected countries outside the EU, to see what can be learned from them,

positive or negative. More information about the countries is found in Appendix B to this

report.

3.1 International Initiatives

As far as we can determine, there are few definitions from outside the EU that match the

SAWAP definition in the European Electronic Communications Code. ETSI offers an

approximation with just a hint of physical dimensions:

Small cells are generally understood as low-powered radio access nodes

operating in licensed and unlicensed spectrum, with a range of 10 to several

hundred meters in urban applications, up to few kms outside….

However, ETSI describes that kind of node as “operator-controlled” and the application

in unlicensed spectrum as “carrier-grade Wi-Fi”41 – a reminder that the small cell’s roots

are in “femtocells”. Femtocells are complete, easy to set up cellular base stations about

the size of a Wi-Fi router serving a limited number of users in an area with poor

macrocell coverage. What is today called the Small Cell Forum began as the Femto

Forum. When femtocells were introduced about ten years ago, the telecommunications

industry predicted they would be wildly popular, displacing Wi-Fi and revolutionising

communications.42 That did not happen.

ETSI and 3GPP have adopted physically specific definitions of power classes for LTE base

stations:

“Wide Area Base Stations” derive from “macrocell” scenarios and have power

output greater than 38 dBm (6.3 W)

“Medium Range Base Stations” derive from “microcell” scenarios and have

power output between 24 dBm (250 mW) and 38 dBm (6.3 W)

41 ETSI (2018), “TR 103 230 V1.1.1: Fixed Radio Systems; Small cells microwave backhauling” - https://www.etsi.org/deliver/etsi_tr/103200_103299/103230/01.01.01_60/tr_103230v010101p.pdf.

42 “This fast-rising technology could revolutionize cellular service, even as it lowers network costs for carriers while delivering flawless service... One source believes the market could be as high as $8 billion worldwide by 2012…” M. Singh (2008), “The need for femtocells,” EETimes, 2 June, https://www.eetimes.com/document.asp?doc_id=1271633 Global sales of femtocells in 2012 were actually just $425 million. T. Parker (2013), “Infonetics: Femtocell sales set to blast off in 2013,” FierceWireless, 9 March, https://www.fiercewireless.com/tech/infonetics-femtocell-sales-set-to-blast-off-2013.



“Local Area Base Stations” derive from “picocell” scenarios and have power

output between 20 dBm (100 mW) and 24 dBm (250 mW)

“Home Base Stations” derive from “femtocell” scenarios and have power

output less than 20 dBm (100 mW)43

The ETSI/3GPP cut-off thus seems to be either 6.3 W or 250 mW for a small LTE cell.

A categorisation scheme for base stations developed by the International

Electrotechnical Commission in standard IEC 62232:2017 is supported by mobile

industry groups like the Small Cell Forum and by other standards bodies like the ITU and

IEEE. Figure 3.1 summarises the “E” classes.

Figure 3.1. Product installation classes from IEC 62232:2017-08

Source: Small cell Forum based on information from IEC 62232 Ed 2.10, 2017

The power and installation categories in the IEC’s scheme are further defined in Table

3.1.

43 3GPP TS 36.104 version 16.2.0 (Release 16), “Evolved Universal Terrestrial Radio Access (E-UTRA); Base Station (BS) radio transmission and reception” - http://www.3gpp.org/ftp//Specs/archive/36_series/36.104/36104-g20.zip



Table 3.1. IEC’s simplified safe installation criteria for base station classes

Class EIRP

(W)

EIRP

(dBm) Product installation criteria

E0 n/a n/a

The product complies with IEC 62479 or the product compliance

boundary dimensions are zero. No specific requirement for product

installation.

E2 ≤2 ≤33

The product is installed according to instructions from the

manufacturer and/or entity putting into service. Compliance with the

exposure limits is generally obtained at zero distance or within a few

centimetres.

E10 ≤10 ≤40


manufacturer and/or entity putting into service and the lowest

radiating part of the antenna(s) is at a minimum height of 2.2 metres

above the general public walkway.

E100 ≤100 ≤50


manufacturer and/or entity putting into service and: (a) the lowest

radiating part of the antenna(s) is at a minimum height of 2.5 metres

above the general public walkway. (b) the minimum distance to areas

accessible to the general public in the main lobe direction is Dm and

(c) there are no pre-existing RF sources with EIRP above 10 W

installed within a distance of 5Dm metres in the main lobe direction

(as determined by considering the half power beam width) and within

Dm metres in other directions. If Dm is not available, a value of 2

metres can be used or 1 metre if all product transmit frequencies are

equal to or above 1500 MHz.

E+ >100 >50


manufacturer and/or entity putting into service and (a) the lowest

radiating part of the antenna(s) is at a minimum height of Hm metres

above the general public walkway, (b) the minimum distance to areas

accessible to the general public in the main lobe direction is Dm

metres, and (c) there are no pre-existing RF sources with EIRP above

100 W installed within a distance of 5Dm metres in the main lobe

direction and within Dm metres in other directions. Hm is given by

equations (6.1), (6.2) or (6.3) of IEC 62232.

But how can the above categories be linked to the EECC’s definition of a SAWAP? Is

category E10 a SAWAP? The Small Cell Forum is in favour of that. But there first needs

to be a clarification of how the assumptions of IEC 62232:2017 are affected by the

technologies implemented in 4G and 5G networks. Because of beamforming, the power

density of a 10 W station could easily exceed what are today considered safe limits for

human exposure, since the focused beam is boosted by more than 20 dB (to the

equivalent of 1000 watts EIRP - see Table 1.2) and aimed at the communicator. For

that reason we would include E10 within the scope of the SAWAP definition only if beam-

forming is not used.

The IEC categories also ignore the relationship between the base station and its

surroundings – in contrast to 3GPP’s definitions of “Small Cells” and “Large Cells.” For

3GPP, a base station whose “antenna is installed above the maximum height of the

surrounding roof tops” is a Large Cell. The same base station is a Small Cell when “the

antenna is sited above the median but below the maximum height of the surrounding



roof tops.”44 Thus, antenna height relative to the surrounding rooftops is a defining

characteristic, apart from EIRP, because of the impact of height and line-of-sight

blockage on signal range. And yet a Small Cell is still much bigger than a Micro Cell,

which is the 3GPP category that most closely approximates the EECC’s definition of a

SAWAP:

A cell in which the base station antenna is mounted generally below roof top

level. Wave propagation is determined by diffraction and scattering around

buildings, i.e. the main rays propagate in street canyons… Micro cells have a

radius in the region of 200 to 300 metres and therefore exhibit different usage

patterns from large and small cells.45

However, the analysis of base station installations in ITU-T Recommendation K.5246

seems most relevant to the question of which small cells could be exempted from local

permits and site approvals with minimal risk to public safety and the environment. That

ITU Recommendation recognises three installation categories:

• Inherently compliant: RF emissions comply with human exposure limits

even close to the antenna so no particular precautions or installation instructions

are required. When EIRP is less than 2 W, the station is considered an “inherently

compliant source for ICNIRP limits.”

• Normally compliant: the radio field strength around the station can exceed

safe exposure limits but “normal” installation makes the “exceedance zone”

inaccessible to the public. Such a station thus requires instructions for

installation, perhaps even some training or vetting for installers. This category

describes base stations with EIRP greater than 2 W.

• Provisionally compliant: such stations require on-site measurements or

calculations to determine the exceedance zones. Barriers, warning signs or some

other form of mitigation may be needed to prevent excessive exposure. This

category requires site-specific compliance verification.

The ITU framework suggests the possibility of a light regulation regime that includes

notification or reporting, deployment instructions and inspections without depending on

pre-deployment permits. What is needed is agreement on a clear threshold between

“normally” and “provisionally” compliant power levels.

3.2 Practices in Selected Countries

People’s Republic of China

China’s government is the largest shareholder in all three national cellular companies,

but the regulatory agencies of the provinces, autonomous regions and municipalities

44 3GPP TS 45.022 V15.0.0 [2018-06], “GSM/EDGE Radio link management in hierarchical networks,” paragraphs 5.2.1 – 5.2.3, - http://www.3gpp.org/ftp//Specs/archive/45_series/45.022/45022-f00.zip

45 Ibid.

46 ITU-T (2018), Recommendation K.52: Guidance on complying with limits for human exposure to electromagnetic fields - https://www.itu.int/rec/T-REC-K.52

https://www.itu.int/rec/T-REC-K.52



approve the siting and construction of base stations.47 Since 2014, most of China’s

cellular infrastructure has been owned and operated by a single company, China Tower.

With 1.9 million transmitter sites, China Tower is the world’s largest telecom tower

holding company.48 In 2017 it added an average of 460 new sites every day: 40,000

each quarter. Mobile base station installers in the USA added fewer sites in the last three

years than China Tower added in the last three months.49

This demonstrates the faster pace of deployment needed for wide-area network

densification. It also confirms that a large increase in the number of installers is needed,

along with training programs to prepare them. If 5G is a race, in China it will be a

marathon. And from their perspective it is not about winning but about catching up: M-

Lab reported in June 2018 that the mean download speed in China is still just 2.48 Mbps

– slower than Uganda or Haiti.50 Moreover, the latency imposed by the “Great Wall”

content filtering system means 5G in China may never achieve the near-real-time

delivery speeds promised elsewhere.51

China’s contributions to standards development in 3GPP began to focus increasingly on

small cells in 2012, when they started promoting TDD (time division duplex) while the

US and Europe focused on FDD (frequency division duplex). TDD is better for dense

deployments because it produces less interference between neighbouring base stations.

This early commitment to TDD led to their emergence as the dominant player in small

cell standards, with Huawei and the Chinese Institute of Telecommunications Research

jointly leading the 3GPP project on core physical layer enhancements for LTE.52 Since 5G

networks also rely on TDD, Chinese expertise is now central to cellular standards

development. It is not clear what impact – if any - the US/China trade conflict and

efforts to isolate Huawei will have on their contributions to 3GPP.

Mobile network planners in China distinguish between ground based stations, roof based

stations and small scale stations. But these categories are informal and pragmatic, not

defined by regulatory parameters. According to China Securities Research, migrating to

5G will entail deploying between 65.75 million and 164.375 million small base stations in

47 Ministry of Industry and Information Technology (2016), 中华人民共和国电信条例 [People's Republic of China

Telecom Regulation] - http://www.miit.gov.cn/n1146295/n1146557/n1146619/c4860613/content.html

48 Articles about China Tower in the Western trade press often claim even an larger site inventory – 2.5 million

was recently cited by RCR Wireless – but the figure we cite was compiled for potential investors in the Initial

Public Offering (IPO). In August 2018, 25% ownership of China Tower was offered to the public in the form of

tradable shares. The IPO raised USD 6.9 billion so the implied valuation of the company is about USD 28

billion. F. Lau and J. Zhu (2018), “China Tower raises $6.9 billion in world’s largest IPO in two years: sources,”

Reuters News, 1 August - https://www.reuters.com/article/us-china-tower-ipo/china-tower-raises-69-billion-in-

worlds-largest-ipo-in-two-years-sources-idUSKBN1KM3L1

49 Deloitte (2018), 5G: The Chance to Lead for a Decade - https://www2.deloitte.com/content/dam/Deloitte/us/Documents/technology-media-telecommunications/us-tmt-5g-deployment-imperative.pdf

50 M-Lab (2018), “Worldwide Broadband Speed League” -

https://www.cable.co.uk/broadband/speed/worldwide-speed-league/

51 Xinheng Wang, Chuan Xu, et al. (2018), “A First Look at Cellular Network Latency in China,” International Conference on Communications and Networking in China, Chengdu, 23-25 October -https://www.researchgate.net/publication/320129599_A_First_Look_at_Cellular_Network_Latency_in_China

52 Liu Xiaofeng (2014), “Small Cell 技术发展趋势、亮点及挑战”[Small Cell technology trends, highlights and

challenges], Ministry of Industry and Information Technology - http://miit.gov.cn/n1146312/n1146909/n1146991/n1648534/c3489146/content.html



the country,53 which the ICT Academy (research arm of the Ministry of Industry & IT)

estimates will cost 2.8 trillion yuan (US$411 billion) between 2020 and 2030.54

Figure 3.2. Annual capital investments in 5G in China – two estimates

Source: B. Perez (2017).

We found no special rules or exemptions from rules to encourage small cell deployments

in China. However, the training materials for installers suggest that most small cells will

be indoors, so to the extent that site approvals are needed, they are not for individual

transmitter units but for whole buildings or neighbourhoods.

Little effort is put into “beautifying” base stations in China, as Figure 3.3 shows. But

individual cities are experimenting with ways to disguise or hide rooftop installations as

particularly large and ugly ones are prone to vandalism by local residents.

Figure 3.3. A co-located cluster of different small cell designs in China

Figure 1: A co-located cluster of

different SAWAP designs in China

53 Wu Chao Zhe and Yu Hai Ning (2017),从4G+到5G [In-depth Industry Securities Research Report – From 4+G

to 5G: Small Base Station, Big Future], China Security Research, http://pg.jrj.com.cn/acc/Res/CN_RES/INDUS/2017/2/13/d53b9d72-8417-420e-a9df-57443a0fbf14.pdf

54 B. Perez (2017), “Why China is set to spend US$411 billion on 5G mobile networks,” South China Morning Post, 19 June - https://www.scmp.com/tech/china-tech/article/2098948/china-plans-28-trillion-yuan-capital-expenditure-create-worlds



China’s standards limiting human exposure to RF emissions vary from industry to

industry and from ministry to ministry. The standard to which cellular networks must

adhere is GB 8702-2014, issued by the Ministry of Environmental Protection.55 More

lenient than the standard it replaced, it is still much stricter than the ICNIRP guidelines,

see Table 3.2.

Table 3.2. Human exposure limits (from China’s GB 8702-2014 standard)

Frequency range Electric Field Strength E (V/m)

Equivalent radiation power Seq (W/m2)

30 MHz – 3000 MHz 12 0.4

3 GHz – 15 GHz 0.22 f½ f / 7500

15 GHz – 300 GHz 27 2

Japan

Like China, Japan does not have special rules to facilitate small cell deployment. But

businesses with licenses for wide-area public radio services must submit a “Base Station

Establishment Plan” to the Telecommunications Bureau of the Ministry of Internal Affairs

and Communications (MIC) as a condition of their licence. This reduces the paperwork

subsequently needed to deploy individual base stations. If approved, and if the applicant

agrees to publication, the deployment plan appears in the official gazette, making it

legally binding (although modifications can be negotiated).56

Improvements in MIC’s tracking of installations (and a desire to reform and simplify

procedures) has led the regulator to eliminate paper forms and reduce the

documentation requirements for many types of radio stations, including cellular. Since

March 2018, free electronic apps enable networks to notify MIC’s Licensing Office when

base stations are established, modified, inspected or terminated.57 A new ordinance,

effective since the start of 2019, cut the processing time for updates from three months

to one month.58

Since 1991 MIC has used state aid to encourage MNOs to establish base stations and

backhaul links in areas that are “geographically disadvantageous” from a business

perspective. Since 2005 even relatively profitable areas have been subsidised to

promote network development (railway lines and highways, for example).

55 Chinese Ministry of Environmental Protection (2014), GB 8702: Controlling limits for the Electromagnetic Environment, http://bz.mep.gov.cn/bzwb/hxxhj/dcfsbz/201410/W020141022352826534956.pdf.

56 MIC (2018), 第４世代移動通信システムの普及のための特定基地局の開設計画の認定申請マニュアル [Manual for

applications for certification of establishment plans for specific base stations for spreading 4th Generation mobile communication systems] - https://www.tele.soumu.go.jp/resource/j/system/ml/mobile/4g/manual2.pdf.

57 MIC (n.d.), 特定無線局開設届（携帯電話基地局等）申請 [Application for notification of establishment of specific

radio stations (mobile phone base stations etc.)] - https://www.denpa.soumu.go.jp/public/prog/detail/denpa_kt.html.

58 MIC (2017), 免許手続の簡素化に係る制度整備の概要 [Summary of system maintenance to affect simplification of

licence procedure] – http://www.soumu.go.jp/main_content/000521919.pdf.



There has been some discussion of making cellular coverage a universal service

obligation, but that remains undecided.59 Cellular has already achieved 99.97%

population coverage in Japan. But because the Internet of Things is seen as benefitting

greatly from 5G and the government wants to be able to deliver emergency warning

messages and support disaster recovery in rural and mountainous areas (earthquakes

being all too common in Japan), covering populated areas is not enough. A March 2019

presentation titled “MIC’s approach to 5G deployment”60 estimates that complete

national coverage will be “several dozens of times” more expensive than previous

cellular upgrades.

The latest measure to stimulate 5G build-out is the award of new frequency bands

(3600–4000 MHz, 4000-4100/4500–4600 MHz and 27–29.5 GHz) to four network

operators without auctions or license fees: NTT DoCoMo, KDDI, SoftBank and Rakuten

won a total of 2100 MHz when their Base Station Establishment Plans were approved by

MIC’s Radio Frequency Control Council. The four companies committed to spending a

total of US$14.5 billion to fulfil the conditions of their licenses (the amounts they

proposed to spend was one reason for their selection). The money will be spent on

launching 5G services in all of Japan’s 47 prefectures within 2 years, then covering more

than 50% of the nation within 5 years. In addition to these public networks, MIC

reserved 4.6-4.8 GHz and 28.2-29.1 GHz for private industries to deploy their own 5G

networks under a new assignment system called “Local 5G.”61 The physical parameters

for these “Local” stations have not yet been agreed.62

Singapore

Advanced communication technologies are strongly supported as key investment and

export sectors for Singapore. Their industrial policy focuses now on business use of 5G

small cells because their MNOs are “not keen to provide 5G to consumers due to

perceived lack of willingness to pay for incremental benefits.”63 Nor are they rushing into

5G: “As significant investments have been sunk into the 4G networks, MNOs are likely to

continue to ‘milk’ the network in the next few years”64 to be able to pay for 5G’s higher

infrastructure cost. As Small Cell Forum’s CEO Sue Monahan wrote about the evolution

of 5G in Asia:

Mobile operators need to lay strong foundations now, so they can migrate to 5G

with minimal disruption, at a time that suits their business case. Even 5G

59 MIC (2014), 携帯電話の基地局整備の在り方に関する研究会報告書（案）[Study Group on Methods of Mobile Phone

Base Station Maintenance (Draft Report)] - http://www.soumu.go.jp/menu_news/s-news/01kiban14_02000185.html.

60 Included with MIC’s response to our questionnaire.

61 M. R. Marti (2019), “Regulators look at next priority: vertical industries,” PolicyTracker, 14 February - https://www.policytracker.com/regulators-look-at-next-priority-vertical-industries/.

62 MIC’s answer to our written questionnaire. The parameters that are being considered are summarised in MIC Information and Communications Technology Subcommittee (2019), 新世代モバイル通信システム委員会報告（案）[New Generation Mobile Communication System Committee Report

(Draft), 14 March - http://www.soumu.go.jp/main_content/000607544.pdf.

63 H. Foo (2018), “5G Development in Singapore,” presented at the ITU-APT Foundation of India Workshop on 26-28 GHz Spectrum for 5G, New Delhi, 27-28 September, http://itu-apt.org/28-GHz-Indiay-5G-Spectrum-Workshop/docs/henry.pdf.

64 Ibid.



trailblazers like SoftBank are clear that LTE will also have a long life, and the two

networks will coexist to a greater extent than in previous generations.65

Large scale deployment of small cells has already begun in Singapore, using LTE.

Hundreds of small cells are now found in the subway system, malls and other crowded

public spaces, including some MIMO experiments to reduce interference. At the same

time, Singtel’s blanket of 2000+ public Wi-Fi hot spots is progressively expanding.

To encourage 5G pilot tests, no permits are needed if the technology is experimental and

the trials are conducted by infrastructure firms based in Singapore. The Infocomm Media

Development Authority (IMDA) has waived experimental spectrum license fees to the

end of 2019 as the aim of such trials is to assist industry in learning how 5G functions in

different real environments and how it might benefit different economic sectors.66

5G trials utilise IMDA’s existing Technical Trial (TT) or Market Trial (MT) frameworks. TTs

are generally for testing equipment and R&D while MTs are for testing the commercial

potential of new technologies, services or products. As such, TTs must be on a non-

commercial basis. Any proposed trial must be in one of the three categories defined by

ITU-R for 5G technology:

enhanced Mobile Broadband (eMBB);

Ultra-Reliable Low-Latency Communications (URLLC), which includes industrial

applications and autonomous vehicles; or

Massive Machine Type Communications (MMTC) or sensors.

To enable this, IMDA offers access to 15 frequency bands from 1427 MHz to 80 GHz

(included are all the bands above 6 GHz which may be internationally harmonised for

5G). The aim of current experiments in the mmWave bands is to understand the

propagation characteristics and performance of the higher frequency ranges.

Switzerland

Switzerland has a state government and parliament, but it is also a confederation.

Article 92 of the federal constitution says the confederation is responsible for

telecommunications.67 However, many competences have been devolved to the

communes and cantons, including responsibility for managing the planning, permitting

and verification of base stations for mobile telephony. More precisely, the 26 Swiss

cantons enact laws regulating construction within their territory which the communes

have roles in enforcing.

Planning and Building Permits

Most construction projects in Switzerland – and modifications of existing structures –

require a building permit, usually from the local communal building office. Part of the

building permit is an RF exposure assessment usually from the cantonal Non-Ionizing

65 S. Monahan (2017), “5G Asia: Small cells will support 4G continuity as well as 5G innovation,” Small Cell Forum blog, 26 September, https://www.smallcellforum.org/blog/5g-asia-small-cells-will-support-4g-continuity-well-5g-innovation/.

66 IMDA (2017), “Factsheet: Facilitating 5G Deployments in Singapore”, https://www.imda.gov.sg/-/media/imda/files/about/media-releases/2017/facilitating-5g-deployments-in-singapore-factsheet.pdf.

67 Federal Constitution of the Swiss Confederation (1999) – English translation -

https://www.admin.ch/opc/en/classified-compilation/19995395/201801010000/101.pdf.



Radiation (NIR) protection service. Fees are generally of two types: a percentage of the

construction cost and, for special permits and expertise, cost based on the time spent on

the project.

Swiss land-use laws distinguish between built-up zones and non-built-up zones (farm

land, pastures, wilderness areas, etc.). Base station deployments in a built-up zone

usually require the local commune’s approval – or for low-power stations, simple

notification. Deployments in non-built-up zones usually require approval from the

canton.

The use of existing structures as antenna mounts is strongly preferred. For deployments

in non-built-up zones, it is necessary to show that the deployment is needed to satisfy

existing demand and how considerations like aesthetics, quality of service, etc., are

factored into the proposal. Network coverage maps are often used to demonstrate the

need for the deployment. Such maps also indicate existing base stations and the local

“radio environment”, including areas where adding a proposed transmitter would bring

total emissions close to the field strength limit or where Installation Limit Values apply

(see next section). All cantons and some cities have a NIR protection service that,

depending on the applicable law, can verify claimed RF levels and their conformance to

the limits set by the federal law on the environment with on-site measurements before

the permit decision is made.

In many cantons, “micro cells” with ERP less than 6 W may still need a construction

permit (depending on their appearance) but not an NIR assessment. NIR-wise they only

need to be reported to the commune using a simple form.

Emission Limits Dominate the Small Cell Discussion

The key issue affecting small cell and 5G rollout is Switzerland’s strict limits on radio

frequency emissions. The fundamental regulation is the Ordinance on Protection from

Non-Ionising Radiation (ONIR)68 which limits EMF exposure from stationary installations,

including mobile communication masts. ONIR requires the modelling of human exposure

as part of the planning process and stipulates exposure verification after installation, by

mapping measurements of the actual field for compliance. Thus, ONIR is more exacting

and exercises more influence than the equivalent in other countries. ONIR sets two types

of exposure limits:

ELV (Exposure Limit Values) - for protection - must be respected in all locations

accessible to the general public. ELV applies to the aggregate field strength of

installations with overlapping signals

ILV (Installation Limit Values) - for precaution “due to incomplete knowledge

about long term health effects.” This applies to the radiation emitted by a single

installation which must be respected in any space where humans may have

prolonged exposures (indoor residential, schools, work places, etc).

The limit values for mobile phone base stations are:

4.0 V/m for installations emitting radio frequencies around 900 MHz or lower;

6.0 V/m for installations emitting radio frequencies around 1800 MHz or higher;

5.0 V/m for installations emitting in both frequency ranges or between them.

68 RS 814.710: “Ordonnance sur la protection contre le rayonnement non ionisant du 23 décembre 1999” -

https://www.admin.ch/ch/f/rs/8/814.710.fr.pdf



Note that these limits do not apply to micro cells with ERP less than 6 W as such stations

are considered physically incapable of exceeding the SAR values at the foreseeable

usage distance. (That may not in fact be true for active antenna arrays.) As Switzerland

has precautionary limits about 10 times lower than the ICNIRP recommendations, the

quota for aggregate field strengths has already been reached at more than 6,000 out of

a total of 15,000 locations, where network capacity can no longer be expanded by

authorising additional spectrum and it may not be possible to install 5G at heavily used

sites without decommissioning 2G and 3G69. However, the cantons cannot change the

limit values set by federal ordinance ONIR for human exposure to EMFs. According to

Light Reading, “Swiss authorities have recently voted against relaxing those limits”.70

The Swiss Medical Association (FMH) recommended waiting for the World Health

Organization (WHO) to publish studies on 5G’s safety before promoting the new

technology.71 In March 2019, the canton of Vaud announced a freeze on permits for 5G

deployment at least until the Federal Office for the Environment (BAFU) declared the

technology safe.72 The canton of Geneva did the same in April,73 followed by the canton

of Jura.74 Just as it looked like this could become a nationwide movement75 BAFU and

the Federal Office of Communication (BAKOM) issued a joint declaration that “there is no

room for cantonal or municipal regulations to protect humans from the radiation of

mobile radio systems."76

The Swiss Business Federation went farther, asserting that ONIR would “prevent any

forthcoming implementation of 5th-generation mobile networks.”77 But in fact 5G

deployment is racing ahead in Switzerland, faster than in most other parts of Europe.

69 BAKOM (2015), Zukunftstaugliche Mobilfunknetze - Bericht des Bundesrates in Erfüllung der Postulate No-

ser (12.3580) und FDP-Liberale Fraktion (14.3149) [Future-proof Mobile Networks - Report of the Federal

Council in fulfillment of the postulates No-ser (12.3580) and FDP-Liberal Group (14.3149)],

https://www.bakom.admin.ch/dam/bakom/de/dokumente/zukunftstauglichemobilfunknetze.pdf.download.pdf/

zukunftstauglichemobilfunknetze.pdf.

70 I. Morris (2019), “Swiss 5G auction bags $380M amid radiation law gripes,” Light Reading, 8 February - https://www.lightreading.com/mobile/5g/swiss-5g-auction-bags-$380m-amid-radiation-law-gripes/d/d-id/749354.

71 L. Monnat (2017), “La 5G risque d’arriver en retard en Suisse,” 24 Heures, 6 December -

https://www.24heures.ch/suisse/5g-risque-arriver-retard-suisse/story/25809787

72 Grand Conseil, Canton de Vaud (2019), Resolution 19-RES-026: “Moratoire sur l’installation d’antennes 5G.” 26 March - https://www.vd.ch/fileadmin/user_upload/organisation/gc/fichiers_pdf/2017-2022/19_RES_026_depot.pdf

73 “Kanton Genf verbietet Bau von 5G-Antennen – vorerst,” SRF.ch, 11 April 2019 - https://www.srf.ch/news/schweiz/gesundheitsschaedliche-wellen-kanton-genf-verbietet-bau-von-5g-antennen-vorerst

74 “Jura legt 5G-Antennenbau wegen Gesundheitsbedenken auf Eis,” Blick, 17 April 2019 - https://www.blick.ch/news/wirtschaft/telekommunikation-jura-legt-5g-antennenbau-wegen-gesundheitsbedenken-auf-eis-id15277418.html

75 https://www.5g-moratorium.ch/

76 “Gemeinsame Stellungnahme BAFU/BAKOM: Kantonale Moratorien zu MobilfunkAntennen 5G und Bundesrecht,” 3 May 2019 - https://www.bafu.admin.ch/dam/bafu/de/dokumente/elektrosmog/dossier/Gemeinsame_Stellungnahme_BAFU_BAKOM_Kantonale_Moratorien_zu_Mobilfunk-Antennen_5G_und_Bundesrecht.pdf.download.pdf/Gemeinsame_Stellungnahme_BAFU_BAKOM_Kantonale_Moratorien_zu_Mobilfunk-Antennen_5G_und_Bundesrecht.pdf

77 Economiesuisse (2018), “Pas de numérisation sans infrastructure moderne de téléphonie mobile,” press

release, 15 January - https://www.economiesuisse.ch/fr/articles/keine-digitalisierung-ohne-modernes-

mobilfunknetz



Despite industry complaints about the country’s strict limits on RF emissions, Swisscom

plans to achieve 5G coverage for more than 90% of the population by the end of 2019.78

“Right now, the network is live across all of Switzerland’s major cities and tourist areas,

making it the third country [in the world] with standards-compliant commercial 5G

service.”79

Meanwhile, to assuage public concerns, the Swiss cabinet agreed to fund a nationwide

monitoring system for BAFU to measure RF exposure levels and report its findings

regularly.80

USA

In September 2018 the Federal Communication Commission (FCC) adopted new rules81

to accelerate network densification by standardising or pre-empting local site

authorisation requirements, defining “small wireless facilities” (similar to SAWAPs),

limiting the use of aesthetic criteria and setting time limits on the processing of permit

applications.82 They also capped the fees that local jurisdictions can charge for permits83

and site use.84 Most large cities in the USA quickly went to court to block these new

rules.85 Fee caps will cost them over $2 billion per year and they object to the fact that

no coverage obligations or build-out deadlines were imposed on the wireless broadband

networks in exchange for these benefits.

Here is the definition of “Small Wireless Facilities” adopted by the FCC as the American

version of SAWAP:

78 E, Hüsler (2019), “Swisscom flips the switch: Switzerland’s first 5G network is live,” Swisscom press release, 17 April - https://www.swisscom.ch/en/about/news/2019/04/17-erstes-5g-netz-live.html

79 J. Horowitz (2019), “5G is live in 3 countries, but we still need answers on health risks,” VentureBeat, 19 April - https://venturebeat.com/2019/04/19/5g-is-live-in-3-countries-but-we-still-need-answers-on-health-risks/

80 M. Shields (2019), “Switzerland to monitor potential health risks posed by 5G networks,” Reuters News Agency, 17 April - https://www.reuters.com/article/us-swiss-5g/switzerland-to-monitor-potential-health-risks-posed-by-5g-networks-idUSKCN1RT159

81 US Federal Communications Commission (2018), “Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment: Declaratory Ruling and Third Report and Order,” WT Docket No. 17-79 and WC Docket No. 17-84, adopted 26 September, https://docs.fcc.gov/public/attachments/FCC-18-133A1.pdf.

82 90 days for new sites, 60 days for “colocation” at existing sites.

83 A maximum of $500 for up to 5 sites in a single application, $100 for each additional site.

84 A maximum of $270 per site per year.

85 C. Sbeglia (2019), "Opposition to 5G small cell deployment spreads across US", RCR Wireless Report, 26 August - https://www.rcrwireless.com/20190826/5g/opposition-to-5g-small-cell-deployment-spreads-across-us.



One of the most striking aspects of the FCC’s new rules is their attempt to supress local

use of aesthetic criteria – and equally striking is the opposition to that policy by their

own Technological Advisory Council (noted in Section 1.3 above). The TAC recommended

that the FCC convene “a multi-stakeholder group” to create “guidelines/industry

standards to improve the appearance of small cell installations”86 but the FCC has not

reacted to this proposal yet.

More recently, the FCC proposed to broaden the so-called “OTARD rule” – a change that

could have big implications for small cells. OTARD stands for “over-the-air receiving

devices.” The FCC created the “OTARD rule” to ensure that state and local governments,

neighbourhood associations, zoning authorities, landlords, etc., could not stop people

from installing satellite dishes and TV antennas on their property. Now they want to add

“hub and relay antennas” to the list of what cannot be locally restricted. The questions

they ask in their public consultation show their motivation:

We seek comment on the extent to which extending the OTARD rule to fixed

wireless hub and relay antennas would spur infrastructure deployment, including

the deployment of mesh networks in urban, suburban, and rural areas. To what

extent would extending the rule create more siting opportunities for fixed wireless

service providers? What effect would adoption of the proposed rule have on

infrastructure deployment in rural, Tribal, and other underserved areas? What

effect would it have on infrastructure deployment by small providers?87

86 FCC (2019), “Technological Advisory Council – Antenna Technology Working Group,” meeting presentations, 26 March - https://transition.fcc.gov/oet/tac/tacdocs/meeting32619/TAC-Presentations-3-26-19.pdf

87 FCC (2019), “In the Matter of Updating the Commission’s Rule for Over-the-Air Reception Devices,” WT Docket No. 19-71, adopted 12 April - https://docs.fcc.gov/public/attachments/FCC-19-36A1.doc.

FCC Definition of “Small Wireless Facilities”

“a facility that meets each of the following conditions:

“(1) The structure on which antenna facilities are mounted –

“(i) is 50 feet or less in height, or

“(ii) is no more than 10 percent taller than other adjacent structures, or

“(iii) is not extended to a height of more than 50 feet or by more than 10 percent

above its pre-existing height as a result of the collocation of new antenna facilities;

and

“(2) Each antenna (excluding the associated equipment) is no more than three cubic feet in

volume; and

“(3) All antenna equipment associated with the facility (excluding antennas) are cumulatively no

more than 28 cubic feet in volume; and

“(4) The facility does not require antenna structure registration under part 17 of this chapter

[which states that “An antenna structure must be registered if the antenna structure is taller

than 200 feet above ground level or may interfere with the flight path of a nearby airport”]; and

“(5) The facility is not located on Tribal lands…; and

“(6) The facility does not result in human exposure to radiofrequency radiation in excess of the

applicable safety standards specified in Rule 1.1307(b).”



In effect, this would create an additional subcategory of small cells – with antennas less

than one meter in the longest dimension – with even fewer restrictions than the “Small

Wireless Facilities” described above. It is still just a proposal, but as all five FCC

Commissioners support it, adoption seems likely.

A national wholesale 5G network for the USA?

A National Security Council presentation at the White House in January 2018

unexpectedly proposed a government-backed nationwide wholesale network for 5G to

accelerate deployment and reduce the cost of coverage. That seemed a radical departure

from existing US policies but the presenter cited the Interstate Highway System as a

precedent.

A leaked copy of the presentation was posted online.88 It emphasised the dire

consequences of “losing the 5G race” to China and included a more detailed version of

Figure 3.4 estimating the resources needed to build the network:

Figure 3.4. Resources to deploy a national wholesale 5G network in the USA

Source: Adapted from R. Spalding (2018), Appendix 7.

Translating this picture into numbers, the total investment appears to be about $585

billion, with additional funding needed for maintenance, upgrades and operation after

2020. The biggest cost is “build crew resources” (labour), constituting 73% of the total.

However, no coverage map was included nor any estimate of the number of small cells.

The wholesale network would operate between 3.7 and 4.2 GHz. MNOs could build their

own retail networks in lower and higher frequency bands.

The FCC, the mobile industry and Members of Congress from both political parties

reacted swiftly and negatively to this idea.89 The proposal’s author was fired within

days90 but it took President Trump four months to finally quash the plan:

88 R. Spalding (2018), Secure 5G: The Eisenhower National Highway System for the Information Age, US National Security Council memorandum and presentation - https://assets.documentcloud.org/documents/4361020/Secure-5g.pdf

89 D. McCabe (2018), “Federal 5G proposal hits major resistance,” Axios, 30 January - https://www.axios.com/washington-kills-5g-nationalization-1517263614-deb56123-4da3-4c6f-8cb1-26f00011da95.html



“In the United States, our approach is private sector-driven and private sector-

led… As you probably heard, we had another alternative of doing it that would be

through government investment and leading through the government… We do

not want to do that because it won't be nearly as good, nearly as fast."91

3.3 Summary

China’s market structure is quite different from Europe’s and the relationship between

cellular networks and municipalities there is also quite different. Nevertheless, China

sees the scale of the effort needed to deploy small cells very clearly and has embarked

on an ambitious training program to produce tens of thousands of new installers. The

scale of their domestic market gives a formidable economic advantage to equipment

producers like Huawei, not to mention the company’s leadership role in small cell

standards development within 3GPP. It is not clear yet what impact US efforts to isolate

and discredit Huawei might have on their standards work.

Like China, Japan does not auction spectrum. Money that would have been spent

acquiring frequency licenses instead goes directly into network development. Because

earthquakes can happen anywhere, creating a need for early warning sensor networks

and disaster recovery communications, Japan wants 100% territorial coverage for 5G

and the government is willing to subsidise build-out to make that happen. There has

been discussion of making cellular coverage a universal service obligation but Like

Sweden and Germany, Japan is also encouraging the emergence of private 5G networks

by setting aside spectrum bands exclusively for industrial applications on a “first come,

first served” basis.

Taking a different approach, Singapore has decided to focus on industrial applications for

5G because of the perceived unwillingness of consumers to pay premium prices for

faster data. Like China, they view their own market with few illusions. That may be

instructive, as is Switzerland’s early achievement of wide area 5G coverage, despite the

Swiss Business Federation’s warning that the country’s strict laws limiting public

exposure to RF would make 5G deployment impossible.

The USA is even more instructive as large cities and even representatives of the telecom

industry fight the FCC’s new rules promoting small cells as too extreme. It remains to be

seen what the courts will say and do about federal pre-emption of local authority. A plan

for the federal government to build a nationwide wholesale 5G network (as Mexico did

for LTE at 700 MHz) drew attention to the idea before it was firmly rejected.

90 J. Rogin (2018), “National Security Council official behind 5G memo leaves White House,” Washington Post, 2 February - https://www.washingtonpost.com/news/josh-rogin/wp/2018/02/02/national-security-council-official-behind-5g-memo-leaves-white-house/

91 M. H. McGill (2019), “Trump rejects government intervention in 5G wireless networks,” Politico, 12 April - https://www.politico.com/story/2019/04/12/trump-government-intervention-5g-wireless-networks-1352763



4. Lessons from EU and Non-EU Countries

4.1 Key Country Models

This chapter reviews the deployment of small cells in key countries, both in the EU and

outside, highlighting the lessons learned in regulating the rollout of small cells, to

identify potential models for a light regulatory regime for EU. Further details are

provided in Appendixes A and B. At the outset, we note that the majority of countries

have yet to address the challenges of 5G technology, especially in the centimetric and

millimetric bands.

The Leading Countries in Small Cell Deployment

China: although the concentration on dense network rollout is the largest in the world,

the market and governance situation is quite different to the EU, being under a centrally

planned economy, with a single monopoly mobile base station installer/owner, China

Tower. In this model of a command economy, permits are granted almost automatically

but there is still a problem of vandalism against sites on rooftops and close to dwellings

that have been deployed without consulting local residents. Throughout 2017, China

Tower installed some 460 sites every day on average, some 40,000 sites every quarter –

basically LTE UHF macrocells. In comparison, the mobile base station installers in the

USA (i.e. the MNOs and tower owner/operators) added fewer sites in the last three years

than China Tower added in three months.92 The lesson to be learnt is that a rapid rate

of installation emphasises the degree of preparation needed for dense concentrations of

small cells – specifically in terms of the numbers of installers necessary and the training

they require. Apart from this latter point, China has little to offer in terms of a model for

the EU.

USA: while there is strong commercial interest in 5G, which is raising the challenge of

dense small cell rollout, the USA is held back by the very different planning laws and

fees across the country. While the FCC mandated a light touch regulatory regime in

2018, this has provoked local opposition in a country renowned for its legal conflicts over

municipal, state and federal rights. Mandates have not so far worked. Perhaps a way

forward may be to balance motivating small cell approvals at a local level, while

maintaining state, rural and municipal authority, especially over any fees for a permit-

free installation. This model is not likely to lead to constructive cooperation in the short

term between states, rural councils and MNOs for efficient deployment of a 5G

infrastructure. For these reasons, it does not offer a useful model for the EU to follow.

Countries Offering Potential Models for the EU

The Netherlands perhaps offers the most appropriate model for the EU to follow. No

environmental permit is needed to deploy a mobile network antenna less than 5 m high

(including the mast and equipment cabinet) or mounted at least 3 m above the ground

on an existing cell tower, high-voltage pylon, advertising column, lamppost, etc. The

Netherlands is one of the EU MS which did not transpose EU Recommendation

1999/519/EC into national law. However, telecommunication companies have signed up

to a voluntary code to respect the limits in the EU Recommendation at locations

accessible to the public. Now government support for Recommendation 1999/519/EC is

92 Deloitte, 2018, 5G: The Chance to Lead for a Decade.



stated in the National Antenna Policy93 and the Antenna Covenant.94 Its 380

municipalities pay attention to RF EMF levels, via a covenant with the telecoms providers

managed by a Foundation for Mobile Services Codes of Conduct (Stichting Gedragscodes

Mobiele Diensten).95 A new Covenant with the operators is expected96 to add a section

on 5G in 2020. It may abandon the voluntary limits on RF exposure as the Cabinet

decided to include the EU recommendation on EMF limits in Dutch legislation.97

A key trigger for progress in the Netherlands was the adoption in 2016 of a low-visibility

design for small cells for street furniture, using Amsterdam’s bus shelters. The rollout

programme showed how it was possible to create 200 small cell sites within 12 months

(compared to 18-24 months for one macrocell in the same area). It demonstrated multi-

operator site sharing with up to four base stations on one bus stop with RF exposure

always limited to 2 V/m, for proximity to the travelling public.

Except for establishing an obligation for mobile networks to share transmitter locations,

the Netherlands Law on Telecommunications says nothing about the siting of base

stations. That is regulated at the local level under the General Provisions of

Environmental Law Act [‘WABO’]. WABO replaces numerous approval procedures and

sets of requirements with one integrated assessment leading to an “environmental

permit” – but still implemented by diverse local laws and ordinances. Thus, further

revision of WABO is in hand, to replace 15 existing laws (e.g. Water Act, Crisis &

Recovery Act and Spatial Planning Act plus 8 other laws) with an augmented

Environment and Planning Act, approved by both Chambers of Parliament, to take effect

in 2021. Further work is still needed to streamline permits for new ducts and for cabling

for backhaul and power. A more detailed description is given in Appendix A.

Essentially, the advances in the Netherlands which could contribute to best practice are:

The working relationship between the operators and the local authorities - and

the fruits of this in faster and multiple permissions processes

The effects of simplicity for defining a small cell with a lighter touch regulation

Attempts to simplify numerous approvals procedures into one (WABO) shows how

a Member State can progress in an environment with many local laws.

Finland has addressed the design problem for outdoor SAWAPs with its competition for

acceptable plans for enclosure shapes, as described in Chapter 1. This could be repeated

at an EU level.

Switzerland has a highly detailed set of processes for planning permission and the

approvals for new base stations down to local level (reviewed in detail in Appendix B).

However, it is emission limits that dominate the discussion about deployment of small

93 Ministerie van Verkeer en Waterstaat (2000), Nationaal Antennebeleid, https://www.antennebureau.nl/binaries/antennebureau/documenten/beleidsnotas/2018/januari/26/nationaal-antennebeleid-2000/Nota_nationaal_antennebeleid_2000.pdf 94 Antennebureau, Antenneconvenant 2010 - https://www.antennebureau.nl/binaries/antennebureau/documenten/convenanten/2018/januari/26/antenneconvenant-2010/Antenneconvenant_2010.pdf 95 Administratie Instemmingen Antenneconvenant, http://administratieinstemmingenantenneconvenant.nl/

96 Antennebureau (2018), “Inbreng gemeenten voor nieuw antenneconvenant” [Municipalities’ input for new antenna covenant], 11 October, https://www.antennebureau.nl/plaatsing-antennes/nieuws/2018/oktober/11/inbreng-gemeenten-voor-nieuw-antenneconvenant

97 Government of the Netherlands (2018), “Voor alle Nederlanders in 2023 snel vast internet” [Fast fixed internet for all Dutch people in 2023], news release dated 11 October, https://www.rijksoverheid.nl/actueel/nieuws/2018/07/03/voor-alle-nederlanders-in-2023-vast-snel-internet

http://administratieinstemmingenantenneconvenant.nl/

https://www.antennebureau.nl/plaatsing-antennes/nieuws/2018/oktober/11/inbreng-gemeenten-voor-nieuw-antenneconvenant

https://www.antennebureau.nl/plaatsing-antennes/nieuws/2018/oktober/11/inbreng-gemeenten-voor-nieuw-antenneconvenant



cells. The key issue affecting small cell and 5G rollout is Switzerland’s strict limits on RF

EMF emissions. These are set by a fundamental regulation, the Ordinance on Protection

from Non-Ionising Radiation (ONIR)98 which limits EMF exposure from mobile base

stations.

Importantly, ONIR requires the modelling of human exposure as part of the planning

process and stipulates exposure verification after installation, by mapping measurements

of the actual field for compliance. Thus, ONIR is more exacting and exercises more

influence than the equivalent legislation in many other countries. Mobile network

operators see it as a burdensome procedure but the public in Switzerland see it as

necessary (and the Swiss use of referendums is a feature of the political opposition that

must be considered). ONIR sets out two types of exposure limits:

ELV (Exposure Limit Values) – for protection – must be respected in all locations

accessible to the general public. ELV applies to the aggregate field strength of

installations with overlapping signals

ILV (Installation Limit Values) – for precaution “due to incomplete knowledge

about long term health effects”. This applies to the radiation emitted by a single

installation which must be respected in any space where humans may have

prolonged exposures (indoor residential, schools, work places, etc.).

Compliance verification requires manual sweeping of the whole volume to be measured

while varying the preferential direction and the direction of polarisation of the antenna

with a set of selective measurements. The process explores all mobile frequencies and

protocols (GSM, UMTS, LTE, etc.) to extrapolate the maximum allowed power. The

current limiting values for mobile cellular transceivers of all kinds are:

4.0 V/m for installations emitting radio frequencies around 900 MHz or lower;

6.0 V/m for installations emitting radio frequencies around 1800 MHz or higher;

5.0 V/m for installations emitting in both frequency ranges or between them.

Note that these limits do not apply to micro cells with ERP less than 6 W as such stations

are considered physically incapable of exceeding the SAR values at the foreseeable

usage distance. That may not in fact be true for MIMO antenna arrays.

Switzerland’s approach thus has some noteworthy features, specifically:

Despite having strong local authority control of small cell deployment, a single

process model is followed nationally, which includes all technical factors such as

power emitted.

A sophisticated model of RF fields and their measurement has been developed.

Specification of a category of very low power microcells.

Poland is one of the EU MS with much lower human RF exposure limits than ICNIRP

recommends. Since 1998 there has been just one exposure zone recognised, with a 0.1

W/m² (7 V/m) limit. That is dwarfed by the EU accepted ICNIRP reference levels, which

vary from 2 W/m² [27.45 V/m] to 10 W/m² [61.4 V/m] above 10 MHz. Thus, Polish

MNOs have argued that this lower limit impedes network development, as low power

98 RS 814.710: “Ordonnance sur la protection contre le rayonnement non ionisant du 23 décembre 1999”,

https://www.admin.ch/ch/f/rs/8/814.710.fr.pdf



reduces signal range. That forces rollout of extra base stations, raising the cost of

coverage and discouraging site sharing as it also increases the net output power density.

However, all is now changing.

In June 2017 the government formed an alliance with the mobile industry to invest in a

5G Strategy for Poland. Draft amendments to the Act Supporting the Development of

Telecommunications Services and Networks and Other Laws were published in December

2018, on the government information portal. These amendments are intended to

promote network densification and facilitate the introduction of 5G, by changes to law,

policy and procedures. Poland would replace its low limits on RF exposure levels. But the

determination of new safe exposure levels is left for the future.

A broadband fund is also proposed to support internet access services, based on

expected funds from telecoms operators of some €35-47 million per annum. Note that

local governments may now offer targeted subsidies to finance connectivity from the

edge of a plot of land to a building on the land. These recent developments illustrate

various positive directions:

Modification of the previous law for a streamlined approvals process for small

cells, with a single-approvals point, replacing many such applications to different

authorities

Targeted funding for backhaul connectivity by local authorities

Other Relevant Country Models

Sweden: For building permissions, antennas (and their small cells) are exempted from

building permits if they do not materially change the appearance of the building. What

“materially change” means is not defined and so in principle this should be checked with

the local building committee.

Thus, even if small cells would normally be exempted, there is no clear definition to

confirm this. But for buildings in protected areas or for installation on buildings of

historical interest, building permits will be needed regardless of the size of the

antenna/small cell.

Note that small cells thus fall into a lighter regime for planning permission. This is not at

all the case for normal macrocell sites as cellular base station deployments in Sweden

are subject to various different public bodies for environmental protection laws, land use

plans, building codes and contracts agreed with property owners. While building permits

are a municipal competence, environmental protection is mainly the concern of county

administrative boards.

For spectrum use, in Sweden each MNO can obtain a national blanket spectrum licence

permit when its receives its national block licence to operate and to use that spectrum.

The operator is then free to plan and install as many base stations as required in order

to comply with license award criteria. No additional spectrum applications and/or

licences for each base station are required. From a radio licensing perspective, all base

stations operating in frequency bands with block licences are exempted from individual

site permits, (usually for macrocells on standalone sites). So a national cluster of small

cells could be covered by one national spectrum licence.

Overall, Sweden’s model shows some useful features:



The use of blanket permissions for the spectrum licence for all base stations

The separation of small cells from macrocells

Building permit exemptions – antennae (and thus small cells) are exempted from

building permits, if they do not materially change the appearance of the building,

(unless in a protected area or for a protected building).

Bulgaria: While the country has coverage by the three major MNOs, it also has a set of

small cell networks based on Wi-Fi and built as an independent infrastructure. Mobile

broadband take-up is fairly low. The large number of commercial Internet service

providers whose access networks are based on Wi-Fi is a distinctive feature of

broadband in Bulgaria. As the European Commission99 has noted, the fixed broadband

market remains highly fragmented with some 600 players in a country of seven million

people. The number of DOCSIS 3.0 and FTTH/B subscribers is also unusually high.

Alternative operators continue to rely mainly on the deployment of their own

infrastructure. Operators appear to have little commercial interest in using the

incumbent’s DSL-based wholesale infrastructure and services. Thus compared to the

rest of the EU, Bulgaria stands out as a useful example of having a mix of innovative

business models and network infrastructures.

Essentially this model is a useful illustration of the possibility of having a small cell

infrastructure for broadband, with independent operators, as well as mobile macrocell

coverage

Singapore: Singapore has a highly developed sense of the business use of small cells

for 5G under its industrial policy which guides the rollout of specific centres of

competence between suppliers and operators.

In its economic and industrial policy model, advanced communications technology is

strongly supported as a boost to the key export sectors – electronics and avionics

manufacturing, high technology services such as aircraft servicing, financial services and

logistics through the shipping trade.

It appears to be practising small cell rollout first using LTE technology, with MIMO

experiments for the current infrastructure with hundreds of small cells in crowded

environments such as its metro system and city state’s malls and public spaces. While

small cell technology is being tested on LTE, a progressive expansion of the incumbent

Singtel’s Wi-Fi hot spots is also being pursued, with chosen suppliers.

Singapore's first 5G pilot was tested at the end of 2018 in an initiative driven by Singtel

and Ericsson at the Singtel Comcentre, i.e. in a lab operation with use cases. To

encourage pilots in 5G, no permits are needed, if the infrastructure pilot is facilitating

experimental 5G technology and service trials by industry in Singapore. The

orchestrating government body, the IMDA (Info-Communications Media Development

Authority) is waiving spectrum licence fees in 2019 as the aim of such trials is to assist

the industry to better understand how 5G will work in a real-world environment and the

potential benefits for different sectors.

5G trials may utilise the existing Info-Communications Media Development Authority

IMDA Technical Trial (“TT”) and Market Trial (“MT”) frameworks. Generally, TTs may be

99 EC Staff Working Document, SWD(2014) 249.



conducted for the purpose of equipment testing and R&D for any telecommunication

service, while MTs may be conducted to assess the commercial potential of a new

technology, service or product that is not commercially deployed or offered in Singapore.

As such, TTs must be on a non-commercial basis. Application for a TT or an MT licence

can be found on the IMDA website. Interested companies are invited to submit an

application with the necessary supporting documents. This is a highly focused approach

based on the ITU use cases. Any proposed trial may be in one of the three categories

defined by ITU-R for 5G technology. IMDA will adopt the 5G technical performance

parameters as a guide when reviewing applications from investing enterprises for both

technical and market projects. To enable this, IMDA has made available some 15

spectrum bands from 1427 MHz up to 80 GHz specifically for 5G (the 800MHz band is

excluded). The aim of current experiments in the mmWave bands is to understand the

propagation characteristics and performance of higher frequency ranges for 5G

deployment. To facilitate trials, all of the bands in the frequency range above 6 GHz that

will be potentially harmonised internationally for 5G are to be made available by IMDA.

Canada: Compared to its nearest neighbour, the USA, Canada has a very different

model in that it has a single, coherent approval process for small cells that is standard

across its large territory. Its national authorities publish clear guidelines for citizens,

municipalities and the installing and operating companies, with a five-step decision

process, designed originally for macrocell base stations. This planning permit process

involves all stakeholders. It is public, easy to understand and transparent.

But in addition, there are limited exclusion conditions from land-use authority and public

consultation requirements, which may be useful. They apply to Non-Tower Structures be

they antennas on buildings, water towers, lamp posts, etc. which may be excluded from

consultation provided that the height above ground of the non-tower structure, exclusive

of appurtenances, is not increased by more than 25%.

Canada’s government body responsible for 5G development, Innovation, Science and

Economic Development Canada (ISED) is considering a national framework of best

practice to facilitate future 5G small cell deployment that reduces the administrative

burden on the operators and installers for large scale densification in the major cities. RF

health and safety is managed by Health Canada. It has established safety guidelines for

exposure to RF fields, in its Safety Code 6 document. Canada’s five step decision process

is aimed at macrocell base stations on large sites that have a major physical presence.

Its principles however, of transparency and clarity, should be applied to a permit-free

process, and hopefully the new ISED initiative for light touch regulation will apply the

same simplicity and lucidity to its operation.

In summary, Canada offers lessons in clarity of legislative principles, standard processes

and overall organisation that need to be applied for a rapid rollout regime. It also

encourages small cell installations on existing street furniture, etc, with advantages of

exclusion from the permits process.

4.2 Advantages and Disadvantages of Potential Models

In examining the nine models above, it is immediately apparent that those of the USA

and China cannot be examples for the EU to follow, but they do emphasise specific

lessons:



The USA emphasises the need for finding a suitable common model for local

working with planning authorities and collective aesthetic standards across the

country.

China emphasises the need for large-scale preparation and planning to create

the rollout skills, with enormous training programmes for the high volume of

competent personnel that will be essential for dense small cell installation across

all cities.

Europe: Appendix A to this report has profiles of all the EU Member States. Much can

be learned from the strategies and solutions that they implement. The EU mobile

industry tends to treat the diversity of European practices as a nuisance or impediment

to efficient continental roll-out. But from a more neutral perspective, this diversity can

offer a rich useful library of experience. Most promising are the models from EU Member

States and other countries in Europe which offer pointers to a process for all of Europe:

The Netherlands provides perhaps the most comprehensive model in its set of

agreements between local authorities, operators and the public. The country has

extensive experience with the integration of small cells into street furniture

thanks to JCDecaux’s innovative work with bus shelters in Amsterdam. That early

installation of small cells for LTE in street furniture is possibly a useful model. It is

successful in terms of aesthetics, assurance of respect for health and safety limits

and its handling of public relations by maintaining transparency without raising

undue public concern, for the currently deployed technologies. But other,

important aspects of the Dutch experience are the Foundation for Mobile Services

Codes of Conduct (Stichting Gedragscodes Mobiele Diensten),100 the National

Antenna Policy with the Antenna Covenant. Together these embody a spirit of

cooperation between city officials, mobile networks and the public that one hopes

to see blossoming everywhere. Further revisions of its permit streamlining WABO

processes could replace numerous approval procedures and sets of requirements

with one integrated assessment leading to streamlined permits for new ducts and

for cabling for backhaul and power. With a standard SAWAP unit that meets

technical and physical size threshold limits, a permit-free process could emerge.

Spain: For consideration of best practices used in current rules, a translated

major excerpt from a guide from the Spanish authorities on integrating small cells

into the environment appears as Appendix D to the study report. It is an

excellent model for any MS, and for the EU as a whole. A future version of the

guide may be updated to include SAWAPs.

Sweden. For building permission, antennas (and their small cells) are exempted

from building permits if they do not materially change the appearance of the

building. What “materially change” means is not defined and so in principle this

should be checked with the local building committee. However, if a SAWAP that

conforms to the EU norms for permit-free status is put forward - and that wins

national approval - then it is possible that a permit free regulatory status could

result.

Bulgaria brings the model of many small cell players sharing networks and

interworking (based currently on Wi-Fi) with a highly varied set of backhaul

access networks. That is enabled by freedom of access and flexibility at a legal

level, in this key area of connectivity for small cells, including power supplies. It

100 Administratie Instemmingen Antenneconvenant, http://administratieinstemmingenantenneconvenant.nl/



also underlines the need for interworking between existing Wi-Fi RLAN

infrastructures and 5G (cellular) small cells that may share sites as well as their

connectivity assets. That could include sharing physical access –wayleaves, ducts,

power supplies, as well as possible multiplexing of fibre optic cable even. It might

also include sharing a complete mobile Core Network, if it has the bandwidth for

extra 5G traffic, whether it be an LTE or 5G NR core. The ETSI non-standalone 5G

NR specification enables an LTE core. This model emphasises that small cells

densification may start off with Wi-Fi in the EU as a current model, which has also

been emphasised in Switzerland, at St Galen.

Countries outside the EU also have notable contributions for a model:

Canada offers perhaps the most transparent and balanced public interface for

small cell rollout that takes all stakeholders into account and so provides

confidence for all the population in the rollout process. This is an example that

the EU should follow to avoid problems later. Transparency was emphasised by a

major EU installer of small cells at the Stakeholder Meeting - not being

transparent can raise severe subsequent problems. That could be a determining

factor for many EU MS where public confidence is a paramount issue.

Switzerland, while having quite limiting thresholds for RF EMF levels, still offers

useful principles for handling health and safety aspects. Importantly, its ONIR

legislation requires both the modelling of human exposure as part of the planning

process and stipulates exposure verification after installation, by mapping

measurements of the actual field for compliance. That could form part of standard

EU-type factory test. ONIR is also is clear on the zones in which constant

exposure and limited exposure can occur, with stricter limits for residential and

working environments.

Singapore also exploits use of existing technologies (LTE and Wi-Fi) to first test

dense installation of small cells for 5G rollout on a large scale, which is an

interesting approach.

4.3 Elements of a Harmonised “Light Regulation” Model for the EU

Combining key features from the models described above and in the Appendixes (see

especially Appendixes A and B) the following elements could form a basic

implementation and legislation model for the EU. They may be included within the EU’s

competence resulting from EECC Article 57 and Article 2:

Transposing the whole SAWAP definition (Article 2) and attendant operational

elements into national legislation (relevant under Article 57 including visual

impact).

An EU-wide standard SAWAP definition that has passed technical and physical

size criteria tests, including health and safety conforming with ICNIRP

recommendations. (relevant to Articles 2, and 57), and using the examination

procedure referred to in Article 118(4) of the EECC.

National RF EMF planning models could perhaps use insights from the

Netherlands concertation approach, with operators agreeing levels that are within

accepted limits. This may not be directly relevant to Article 57, yet the EMF

aspect is relevant as some Member States have much lower levels. Concertation

with the operators might give the confidence to ensure national EMF limits at

those of Council Recommendation 1999/519/EC.



Revision of national laws concerning planning, building and environmental

permits to enable a consistent set of streamlined approval processes and/or

exemptions for small cells fitting a standard definition of SAWAPs. Simple

notification and reporting obligations, deployment instructions and inspections

can replace permits to a large extent. Basing that on the Netherlands models for

5G rollout would provide a useful example for implementing Article 57, providing

a comprehensive model of what will be acceptable in terms of aesthetics,

assurance of respect for health and safety limits and handling of public relations

by balancing transparency without raising undue public concern over the

technologies deployed. Streamlining the Netherlands’ permit WABO processes

could replace numerous approval procedures and sets of requirements with one

integrated assessment, including efficient permits processes if new ducts and

cabling for backhaul and power are necessary.

Access to street furniture, with rights to use ducts and power supplies with

charges at the levels of the utilities. This may not be directly relevant to Article

57, but could supplement support for SAWAPs falling under the exemption

regime.

To gain public confidence, it may be useful to emulate Canada’s model with its

openness, clarity and relatively simple processes and involvement of all

stakeholders, which may be relevant under Article 57. The model’s transparency

and clear explanations engenders trust in the populace, with straightforward

announcements and dialogue where needed. This approach was used in the 2016

small cell rollout in Amsterdam. To increase public understanding and acceptance

of SAWAPs, a dedicated public relations team may be necessary implement this.

The tasks would include producing an integrated set of media (web, publications,

manuals for design and technical installation, etc) for the different audiences

describing SAWAPs, their benefits and advantages, with instructions for low-

visibility deployment, etc.

There are additional recommendations for an extended EU approach, going beyond

Article 57 and perhaps the EECC into more general issues:

An agreed method is needed for the calculation of EMF exposure levels, including

their accumulated effects inherent in 5G small cell deployment, to respect the

mandated EMF thresholds. This is not strictly relevant under Article 57 but is

directly relevant to a coherent approach to setting EMF limits and to their

measurement, for verifying them across the EU MS.

Several levels of exclusion zones for residential and working exposure with

testing practices for commissioning and subsequent long term verification, as in

the Swiss ONIR model. Although not directly relevant under Article 57, it provides

a coherent approach to EMF setting/measurement.

Encourage expectation of an operating environment of multiple types of operator,

asset owners and technologies with diverse business models (as in the Bulgarian,

Estonian and Singapore models) in which multiple technologies are mixed and

used as small cell test preparations for 5G SAWAPs. These small cell networks

offer useful community infrastructure, like Guifi.net in Spain and Freifunk in

Germany, living examples of “bottom-up broadband”. The Commission hopes to

encourage such programs like WiFi4EU. Thus policies such as the EECC’s Recital



137 and Article 57 will give positive regulatory recognition for SAWAPs; official

support will encourage further rollout of such community networks.

The above examples should be taken into account in developing the EU’s deployment

policy and light regulatory regime, combining various elements in legislation, promotion

and support for EU-wide common technical standards and type approvals with

harmonised planning and aesthetic conditions for permit-free installation.

The next chapter examines the technical and aesthetic challenges and their

recommended potential solution, combining certain lessons from the above models.



5. Shaping a Light Regulatory Regime

5.1 Practical Recommendations

The purpose of this chapter is to discuss all of the factors that will shape the regulatory

environment for SAWAPs, consistent with EECC Articles 2 and 57, across the EU Member

States. The aim is to support the introduction of planning exemptions that will be crucial

for large-scale rollout of SAWAPs and 5G across the EU Member States by reducing the

time, cost and administrative effort currently constricting deployment. While the overall

objective is to provide input to the Commission’s implementing act for SAWAP

deployment, the discussion recognises the need for measures beyond the implementing

act. Following this discussion, Chapter 6 proposes the policy elements specifically needed

for the implementing act, considering a range of options. The process for that follows the

better regulation guidelines (see Appendix F where this is outlined). Chapter 7 then

outlines the measures beyond the implementing act that will support the proposed

lightweight regulatory environment.

To shape a lightweight regime, responses to the following major challenges in a dense

rollout need to be considered:

A consistent approach to an EU-wide approvals process that is lightweight yet

acceptable to all Member States as an alternative to 28 different approaches

The challenge of affordable aesthetic integration into Europe’s diverse

environments

Moving toward regionally consistent RF exposure limits that protect public health

(such as those contained in European standard EN 62232:2017) while

accommodating the technical innovations of 5G

Measuring the RF emissions from 5G equipment to verify compliance with license

conditions and safety standards

Deriving acceptable parameters for exemption from planning authority permits

(examined in Chapter 6) which will be based on the IEC 62232 guidelines

updated with the latest ICNIRP revisions. Note that the current version of IEC

62232 does not cover AAS beamforming MIMO antenna, also reflected in its

CEPT/CENELEC form, EN 62232.

A regional approach to protecting visual environments might form part of a future

mandate for a lightweight approvals regime but that is outside the scope of the 2020

implementing act. To safely relax regulatory controls over SAWAP siting, these small

cells should be physically unable to exceed the ICNIRP guidelines when properly

installed. A well-managed rollout would ensure that the distribution of SAWAPs respects

the safe EMF exposure limits. Article 45.2(h) of the EECC calls on Member States to take

into account the Council Recommendation on authorising use of the radio spectrum so as

to protect public health to provide consistency and predictability across the EU.

5.2 An EU-wide exemption procedure

To streamline the rollout of SAWAPs across the EU, a specific harmonised exemption

process is necessary as shown in Figure 5.1.



Figure 5.1. The three phases of EU SAWAP exemption process from approvals

Aesthetics

Approvalconditions

Cultural Acceptance

for aesthetics parameters

Emissions Parameters

Measurement Process

RF/EMF

conditions

Aesthetics

conditions


Measurement Process

Emissions ParametersEmissions Parameters

Measurement ProcessMeasurement Process

Phase 3 Exemption from

planning permission

Phase 1 Phase 2

Verified compliance

with exemption parameters

Verified compliance


Aesthetics

Approvalconditions

Aesthetics

Approvalconditions

Cultural Acceptance

for aesthetics parameters


Measurement Process



RF/EMF

conditions

Aesthetics

conditions





Phase 3 Exemption from

planning permission

Phase 1 Phase 2

Verified compliance


Verified compliance


In the first phase, the major hurdles of aesthetics and cultural acceptance would be

addressed. The process must include qualifying conditions of aesthetics and health and

safety in a way that satisfies national requirements as well as local planning

responsibilities.

The exemption parameters thus take in two sets of preconditions – aesthetics and health

and safety – each of which has significant measurement problems. The process

addresses both challenges simultaneously to replace planning permission while

eliminating unique local approval procedures.

5.3 Satisfying Aesthetic Requirements

Approvals Process for Visual Impact Acceptance for Protected Areas

Public concern over adverse visual and material impacts of small cells can be a major

source of opposition to such projects. Although this is acknowledged as an issue for

historic sections of cities and villages, as well as scenic areas, there is no common

European approach to address this. Even without a permission procedure, there needs to

be some prior assessment of visual impact and the effectiveness of mitigation measures.

Mitigation measures might include the choice of colour for the equipment enclosure,

reduced visibility to the public and/or minimising the amount of exposed cabling. Unless

it is hidden inside a building or inside street furniture, the SAWAP enclosure must always

be aesthetically approved, perhaps by being selected from among pre-approved options

in a Europe-wide catalogue. The decision on whether to take further steps for legally

protected sites of special interest depends on an assessment of visual and material

impact, following the decision tree shown in Figure 5.2

Figure 5.2. Decision tree for assessing visual impacts

SAWAP

rollout:

- initial site

triage

analysis

Visual impact

assessment

NOT

required

Visual impact

assessment

NOT

required

Visual

impact

assessment

required

Determine

visual

impact

level

Special Case

(never before

seen)

Minimal

case

Standard

assessment

Expanded

assessment

Protected

area/ site

NOT in

protected

area/ site

Meets

standards

for SAWAPs

approval

Meets

standards

for SAWAPs

approval

Source: based on Guidelines for the visual impact assessment of highway projects, US

Department of Transportation, FHWA-HEP-15-029 (2015), with extensions for SAWAPs.



Cultural Acceptance in a World of Aesthetic Divergence

Aesthetic issues need to be taken seriously. This subject is not included under Article 57

but is relevant to the EECC definition of SAWAPs (Article 2 stipulates “low visual impact

antennae”). Thus, the mitigation of visual impact is an essential part of best practice and

an appropriate subject for recommendations or guidelines. Input from Europe’s national

and local planning authorities, industrial design experts and perhaps telecommunications

industry representatives (e.g. the Small Cell Forum) is recommended for both outdoor

and indoor models. The acceptability of standalone outdoor SAWAPs is particularly

important, but recommendations are also appropriate for indoor designs (which may

constitute a majority of SAWAP deployments) and SAWAPs that can be hidden in street

furniture.

A European design competition could offer a way forward, with two design classes, as

shown in Figure 5.3

Figure 5.3. European SAWAP design competition with two classes

Three issues need to be resolved initially:

Should such a competition be organised country by country or regionally, i.e. for

the EU as a whole?

Who may enter designs in the competition? Anyone? Or just professionals who

design for the built environment or who know what has to go inside the

enclosures and how enclosure production fits into the SAWAP supply chain?

How would winners be selected – by the public or by stakeholders (i.e. local

planning authorities and those who will deploy)?

It might be possible to organise an EU-wide competition open to different categories of

entrants - registered professionals, be they architects, industrial designers, or from the

fine arts – with another section for art schools and design students, sources that have

produced successful and innovative solutions in the past. The chosen design solutions

need buy-in from local authorities, NRAs and the mobile industry, so these should

constitute a majority of the selection jury. Like Helsinki’s 5G SAWAP design contest, the

selection could proceed through different rounds – an initial selection by the public via

online voting, then ranking and short-listing by stakeholders – local authorities, telecom

industry associations, MNOs and NRAs. The whole exercise could and should be part of a

wider public relations effort (“SAWAPs for Europe”).

A Europe-wide campaign would explain and promote the winning designs as pre-

approved solutions suitable for diverse environments, leaving flexibility for the

manufacturers to adapt to technical needs and local tastes. The contest would be

accompanied by – and draw attention to – a series of support documents:

• An EU-wide competition on solutions – high

promotion (“a small cell for Europe” contest –

with public exposure) in 2 classes, either:-

1 Visible but

acceptable

appearance

2 Hide in plain sight

eg in bus stop/

display panel



Deployment Guides published in all Member State languages for the public, local

authorities and the industry as an introduction to small cell technologies and their

public benefits.101

SAWAP reference guide for NRAs and governments, giving an overview of the

SAWAP concept, the relevant EU regulations, the defining parameters and the

exemption conditions.

Small cells information pack for local planning and environmental protection

authorities: the what/why/when/where/how/who that highlights the conditions

attached to permit-free deployment and the content required in notifications.

A catalogue of approved SAWAP designs from all over the EU for local decision-

makers, including designs for both protected and unprotected sites and

environments.

Guiding principles for planning authorities and the public on integrating SAWAPs

and environments.

Installation guides for cellular industry professionals.

A manual on SAWAP technical specifications for manufacturers, MNOs, NRAs, and

major third party installers, including tower operators, incorporating the relevant

SDO references, testing methods, functional descriptions, physical dimensions

and the limit-values of key parameters, backhaul and earthing requirements,

antenna positioning, plus templates for ducting and cabling.

Historic site/protected environment guide for stakeholder bodies and local

authorities written by experts on designing and installing SAWAPs in culturally

sensitive areas.

Site preparation, including Hiding in Plain Sight and when in evidence for

installers, planning bodies and local authorities, with details of backhaul, street

furniture use, duct sharing, etc.

Publicity Campaigns Should be Carefully Planned and Executed

The experience of early adopters of small cells, like France and the Netherlands,

demonstrates the importance of preparatory public communication offering accurate and

reassuring explanations about roll-out that ordinary people can understand. In addition,

the Small Cell Forum conducted a three-year study on deployment and aesthetics in and

on street furniture. Their conclusions were that communications must be at both local

and national levels.102 The campaign must be handled with sensitivity, clarity and

common sense without pressure, recognising that public apprehension about

proliferating exposure to non-ionising radiation is reasonable even if not factual.

There is also a need, especially for regulators, to distinguish between the technical

definition of SAWAPs and the legal basis for implementing a light deployment regime. As

a commenter at our Stakeholder Workshop noted:

101 Some Member States have already produced excellent guides promoting consistency in local decision making and deployment, e.g. the German Alliance of Cities’ Mobilfunk: Gestern-Heute-Morgen [Mobile Radio: Yesterday-Today-Tomorrow], https://www.dstgb.de/dstgb/Homepage/Publikationen/Dokumentationen/Nr.%20148%20-%20Mobilfunk%20-%20Gestern%20-%20Heute%20-%20Morgen/,and the Netherlands Antenna Bureau’s Example Note on Municipal Antenna Policy [Voorbeeldnota Gemeentelijk] https://www.antennebureau.nl/documenten/beleidsnotas/2018/januari/26/voorbeeldnota-gemeentelijk-antennebeleid. See also our translation of the Spanish guide in Appendix D.

102 Small Cell Forum (2018), Small Cells Market Status Report, 1 December 2018, document 050.10.03 - https://scf.io/en/documents/050_-_Small_cells_market_status_report_December_2018.php



In general, regulators should have all information on what small cells are

contemplated in their Member State, where they are and all information on their

design. There is some confusion between design and deployment requirements. A

light deployment regime (as in Article 57) and the definition of what a small cell

is (Articles 2 and 58) are not the same thing. Working closely on the clarifications

of definitions in the future with RSPG representing the regulators may help here.

Site Preparation – Hiding in Plain Sight

Amsterdam’s rollout of 200 small cells in 2016 is one example of an urban “out of sight”

placement solution. It highlights the use of bus stop roofs and advertising side panels for

the equipment volume as discreet “low visibility” enclosures that do not disrupt the

urban landscape (see Figure 5.4). Antennae placed inside advertising panels completely

hides them. That provides a positive counterexample to the installations on wooden

poles with exposed cabling seen in other parts of the world.

Figure 5.4. Examples of hiding SAWAPs in plain sight

Source: JC Decaux

Inside Street furniture

- Bus Stop

Under the street inside

manhole covers -deep or

just below street surface

No visual clutter:-

Sources Ericsson, Nokia

Sources: JCDecaux, Ericsson, Nokia.

But as noted in Chapter 1, a policy favouring hidden deployments can be

counterproductive, such is the public’s concern about radio being both invisible and

potentially harmful. JCDecaux learned from this experience that low visibility

installations and transparency about their deployment is a better combination than

invisible installations and low-visibility plans. As soon as the public senses that mobile

networks are hiding something, concerns grow. That the strategy of acknowledging and

addressing public concerns was successful was demonstrated by the lack of vandalism

directed against the cell sites.

Street furniture – lamp posts, bus shelters, utility cabinets, etc. – provide many

opportunities to integrate small cells with the urban environment. But there are

advantages and disadvantages. The advantages:



Lampposts are a normal, universally accepted part of the urban environment,

sited at regular intervals in densely populated areas of streets and public spaces,

often spaced at 2-3 times the lamp height.103

The local authority is responsible for the lampposts and can consign them as a

bulk asset with a single contract for access to all units. That could imply a single

tenant network, or if the contract allows, it may permit a shared network, so the

contractor might be a hosting company for multiple operators.

Lamppost construction in Europe is usually a hollow vertical tube, which may be

able to support extra weight, carry cables out of sight and be internally

reinforced. Visually the presence of a SAWAP may be reduced to a thicker

section.

As street lights are usually 4-12 m above the pavement level, their height above

the street gives a useful distance for a separation or vertical exclusion zone. Of

course, the height of nearby buildings is a consideration, in terms of RF exposure

on the higher floors.

A power supply with fairly high capacity is already present - or the unit has

cableways for a potential upgrade.

The power supply cabling may run in a sub-street duct shareable for fibre optic

backhaul and may have a simple right of way within the local authority domain

for a single contract.

Earthing is fairly straightforward and so EMF shielding can be simple, if needed.

Possible disadvantages include:

Constraints on electrical supply capacity and physical dimensions (e.g. height).

Siting tends to only follow streets, offering little to no coverage of areas away

from streets.

Local authorities may wish to have a single contract for all street lamps, as

mentioned above, so infrastructure sharing might be compromised, particularly if

the contractor is a national incumbent.

A more important disadvantage is that “fibre to the lamp post” is a rarity,

implying either xDSL, coax or microwave backhaul.

Our stakeholder workshop revealed that city contracts with electrical utilities to

power street lamps may not allow the city to share access to the electricity with

any non-governmental user because of the special price discounts agreed for the

contract.

Another aesthetically acceptable option is to put SAWAPs below ground and transmit

upwards through an opaque non-metallic covering, or to put the SAWAP unit at ground

level. This implies lower power output as passers-by will be close to the antenna – the

exclusion distance would be short. Manhole covers on pavement and road surfaces are

now being widely exploited as discrete SAWAP sites (see Figure 5.4). Ericsson, Nokia

and others are offering units that may either be sited in the surface cover or within the

tunnel leading down. These units offer rapid rollout, possibly with bulk applications for

permits, or in some countries freedom from planning permission (as in the UK). The

attenuation of high frequencies in heavy rain with ground water runoff is a potential

problem, however.

103 Global Designing Cities Initiative (n.d.) “Lighting Design Guidance” - https://globaldesigningcities.org/publication/global-street-design-guide/utilities-and-infrastructure/lighting-and-technology/lighting-design-guidance



5.4 Emission Power Limits

This section responds to the Terms of Reference (ToR) questions of emission power

limits being sufficiently covered and enforced through existing standards, to comply with

the Radio Equipment Directive (RED). The ToR asks the Study to consider ways to deal

with the problem of large numbers of SAWAPs deployed in close proximity. Specifically,

it asks for answers to these questions:

Are emission power limits sufficiently covered and enforced through existing

standards (e.g. EN 50400, IEC 62232, etc.) to comply with the Radio Equipment

Directive?

Are additional provisions needed as part of the implementation of EECC Article

57?

These issues are examined in the sections below.

SAWAPs and network densification

SAWAPs operating in close proximity can interfere with one another, causing service

degradation. The superimposition of energy fields from multiple sources can also exceed

safety limits for human exposure. If individual site approvals are eliminated for SAWAPs,

there is a concern that authorities would not be able to prevent such situations, or even

know when they occur. Is there a solution?

The EECC’s definition of SAWAP does not require installation at a fixed location. Indeed,

SAWAPs that are small enough to be portable or mobile, installed in cars, buses or

trucks for vehicle-to-vehicle, vehicle-to-Internet and mobile mesh relay communications,

are obvious implementations of the concept. Even smartphones fit the SAWAP definition.

When people pack into a train or subway or attend a standing-room-only musical event

with a mobile phone in almost every pocket, device density can easily – if only

temporarily – reach 100,000/km2 or more, interspersed with large numbers of people.

Mobile phones are low power devices – 250 mW typically. Such common crowded

situations illustrate why the power output of SAWAPs must be limited and aggregate

field strengths considered: to mitigate health risks when hyperdense deployments are

necessary.

A radio licence confers not just the right to use frequencies, but also a right to access

spectrum without interference. Thus, the presence of a module using licensed spectrum

would seem to impose at least theoretical constraints on SAWAP densification104 – or

alternatively, on the strength of nearby transmitters, the robustness of receivers and the

equipment’s RF emissions space sharing capabilities. Licences for cellular networks that

do not specify the location of every SAWAP implicitly shift responsibility for rational site

selection to network operators and initial responsibility for operators to cooperate in

resolving interference problems (although regulators can assist if called upon). This is

the case when broadcasters share a transmission tower and cellular networks share a

rooftop.

104 3GPP specifications assume a separation distance of at least 25 cm between co-located 5G base stations utilizing the same frequency band to limit mutual interference. See 3GPP (2019), TR 37.843 V15.4.0 – “Technical Report: Radio Frequency (RF) requirement background for Active Antenna System (AAS) Base Station (BS) radiated requirements” - http://www.3gpp.org/ftp//Specs/archive/37_series/37.843/37843-f40.zip.



National regulators must also anticipate situations where adding one more SAWAPs to a

shared site will exceed the local maximum permitted exposure limit. In such cases, who

is responsible for returning the site to safe levels: the most recent deploying entity? – or

the site owner? – or the owner of the unit contributing the most energy?

The ITU offers a limited consideration of these topics: “Authorities and operators should

discuss and agree on the framework for ensuring compliance of a shared site, both for

the case of a new site that is to be shared and the case of new equipment additions to

an existing site105”. This is a matter for the MS NRAs to decide as it is clearly within their

competence. However, there are also overlapping legal responsibilities which differ

among the Members States and may make the situation more complex. In most EU MS,

the owner of a site accessible to the general public is held responsible for maintaining

safe conditions at the site even if others rent or use places on the property to install

their own facilities. The site owner may have to make reasonable efforts to inspect,

discover and eliminate hazards within their property. But within that framework, the

owners of licensed SAWAPs are also responsible for maintaining safe RF emission levels.

Due diligence requires calculation before deployment to forecast the impact of an

equipment change on local aggregate field strength. This is a prerequisite for site permit

applications in many EU Member States and could be retained as a spectrum licence

condition even without local permitting processes.

In Canada (and perhaps elsewhere) the licensed operator making the most recent

change in emission levels at a site has to certify that the aggregate RF level is below the

maximum permitted.106 In the USA, new deploying entities (MNOs, installers, site

operators) at shared sites are responsible for evaluating the local RF environment prior

to deployment – but they are not primarily responsible for resolving any subsequent

noncompliance. Responsibility is collective, as exceeding the safety limits can lead to

penalties being imposed on “all site occupants that contribute significantly to exposure,

not just the newest occupant or the occupant which contributes the most...”

(“Significant” contributors are defined as “licensees whose transmitters produce, at the

area in question, power density levels that exceed 5% of the power density exposure

limit.”) However, the USA rules do not explain how to bring a site with multiple

transmitters back into compliance cooperatively - when no one in particular is

responsible for compliance.107

BEREC’s “Common Position on Mobile Infrastructure Sharing”108 offers additional insights

from a European perspective, if densification is understood as a progressive form of co-

location. The salient point is that densification involving separate networks in a shared

space can reduce the networks’ ability to act independently, thus reducing competition

at that location. Densification may in fact oblige the networks to coordinate frequency

use, transmitter siting, antenna aiming, etc. to minimise interference, and this implies a

risk of collusion displacing competition.

105 ITU-T (2018), “Recommendation K.91: K.Sup4 – Electromagnetic field considerations in smart sustainable cities” - https://www.itu.int/rec/T-REC-K.Sup4-201809-I/en

106 Industry Canada (2014), “Radiocommunication and Broadcasting Antenna Systems,” Client Procedures Circular CPC-2-0-03 (Issue 5) - https://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/cpc-2-0-03-i5.pdf/$file/cpc-2-0-03-i5.pdf

107 US Code of Federal Regulations, Title 47, Sections 1.1307(b)(3)(i) and (ii) - https://www.law.cornell.edu/cfr/text/47/1.1307

108 BoR (19) 110 - https://berec.europa.eu/eng/document_register/subject_matter/berec/download/0/8605-berec-common-position-on-infrastructure-_0.pdf



A key question, according to BEREC, is whether the coordination between networks is ad

hoc, informal and reversible, or does it lead to a formal site sharing agreement whose

purpose is anti-competitive. The latter would be illegal, while an informal arrangement

aimed at ensuring a more efficient use of spectrum is acceptable. Assessing such

situations is thus “likely to be highly context specific.”

All countries have rules regarding RF exclusion zones near base stations. But site sharing

with low-power equipment is usually an “honour system” with informal relationships and

little or no enforcement – unless someone specifically asks the regulator or

environmental health agency for a site check, as is possible in some Member States

(Greece, Malta, etc).

The situation is different in the licence-exempt bands. Power limits for individual devices

are low enough that there is a very low probability of aggregate signal levels exceeding

safety standards. Moreover, there is no right of non-interference, no policing of

interferers, no regulator assigned locations, and an understanding that if one user

suffers interference there may be no recourse.

But if SAWAPs combine licensed and licence-exempt radio access and users do not know

what type of channel they are using – maybe both simultaneously, as in

‘channel/bandwidth bonding’ – situations can arise that merit fresh thought from

regulators. Licensed spectrum traditionally recognises primary and secondary users

(primary users having priority) while license-exempt applications in licensed bands are

tertiary users (e.g. UWB underlays, “white space devices”, animal tags coexisting with

medium wave broadcasting). The situation is different at 5250-5350 MHz and 5470-

5725 MHz, the first bands to have a licence-exempt application (RLANs) designated

globally as primary. However, those bands are designated for mobile services and RLANs

must also defer to incumbent radar systems as co-primaries - in effect making RLANs

“secondary primaries”.109 SAWAPs and 5G are thus key drivers in the convergence of

licensed and licence-exempt media. The relative rights of these user classes when

sharing frequencies for mutually aligned services need to be clarified. It is particularly

important for end-users to retain the right to choose which WLAN/RLAN network they

want to access when using a SAWAP provided, controlled or configured by a mobile

network operator.

Denser Deployments and RF EMF Compliance

The Terms of Reference for this study indicate that the Commission’s main concern is

not just SAWAP/SAWAP interference but the aggregated effect of multiple overlapping

RF emissions on the safety of citizens as the ToR’s section on Overarching Objectives

notes:

It is essential to assess the effect of denser deployment on the compliance with

electromagnetic field limits, which are relevant for the protection of human

health.

109 Electronic Communications Committee (2004), “ECC Decision of 09 July 2004 on the harmonised use of the 5 GHz frequency bands for the implementation of Wireless Access Systems including Radio Local Area Networks (WAS/RLANs),” ECC/DEC/(04)08 - https://www.ecodocdb.dk/download/3948246a-1552/ECCDEC0408.PDF.



The Commission also asked if emission power limits are sufficiently covered and

enforced through existing standards to comply with the Radio Equipment Directive

(RED):

Specific tasks

The contractor is required to carry out the following tasks:

Analysis of the existing definitions and classification of existing and planned

small-area wireless access points (outdoor/indoor) and presentation of their

physical and technical characteristics, such as size, weight, installation height,

visual characteristics/casing and where appropriate emission power and range.

With regard to the latter, verification whether emission power limits are

sufficiently covered and enforced through relevant existing standards (e.g. EN

50400, IEC 62232) in compliance with the Radio Equipment Directive or whether

further provisions are needed as part of the implementation of draft Article 56

(now 57) of the EECC.

As regards the various definitions, the contractor should present their deviations

from the definition of "small-area wireless access point" set out in Article 2 of the

EECC.

Responding to these assignments in reverse order, Appendix C provides a compilation of

current international standards relevant to SAWAPs and human exposure to RF energy.

Standards dealing with broadcasting transmitters, RFID tags, radars, etc, are omitted.

Bringing the standards together reveals a good deal of redundancy and overlap, as

CENELEC republishes IEC’s standards and IEC cooperates with the IEEE. A benefit of this

overlap is greater global consistency. These ETSI standards which are still in force need

to be updated to prescribe requirements for complying with the RED instead of the

R&TTE Directive:

EN 301 598 V1.1.1 - White Space Devices (WSD); Wireless Access Systems

operating in the 470 MHz to 790 MHz TV broadcast band; Harmonized EN

covering the essential requirements of article 3.2 of the R&TTE Directive

EN 305 550-2 V1.2.1 - Electromagnetic compatibility and Radio spectrum

Matters (ERM); Short Range Devices (SRD); Radio equipment to be used in the

40 GHz to 246 GHz frequency range; Part 2: Harmonized EN covering the

essential requirements of article 3.2 of the R&TTE Directive

In addition, there are relevant CENELEC standards that apply only below 6 GHz, so they

will not cover emission power limits when 5G networks begin operating in the so-called

“pioneer band” of 26 GHz. As such they do not yet enforce 5G compliance with

environmental health and safety limits and so the following are now in the process of

being updated:

EN 50360:2017 - Product standard to demonstrate the compliance of wireless

communication devices, with the basic restrictions and exposure limit values

related to human exposure to electromagnetic fields in the frequency range from

300 MHz to 6 GHz: devices used next to the ear

EN 50566:2017 - Product standard to demonstrate the compliance of wireless

communication devices with the basic restrictions and exposure limit values

related to human exposure to electromagnetic fields in the frequency range from



30 MHz to 6 GHz: hand-held and body mounted devices in close proximity to the

human body

EN 62209-1:2016 - Measurement procedure for the assessment of specific

absorption rate of human exposure to radio frequency fields from hand-held and

body-mounted wireless communication devices - Part 1: Devices used next to the

ear (Frequency range of 300 MHz to 6 GHz)

EN 62209-2:2010/A1:2019 - Human exposure to radio frequency fields from

hand-held and body-mounted wireless communication devices - Human models,

instrumentation, and procedures - Part 2: Procedure to determine the specific

absorption rate (SAR) for wireless communication devices used in close proximity

to the human body (frequency range of 30 MHz to 6 GHz)

Extending these standards to frequencies above 6 GHz may be contingent on the

availability of new ICNIRP guidelines (publication is expected in December 2019)

because it is possible that the recommended approaches to measurements will change.

Currently there are inconsistencies in the metrics used in the major international

standards promulgated by ICNIRP, the FCC and IEEE. They all switch from specifying

maximum safe exposure limits at lower frequencies using Specific Absorption Rate (SAR,

measured in watts per kilogram) to Power Density at higher frequencies (measured in

watts per square centimetre). Unfortunately, those parameters require different methods

of measurement and switching between them causes a discrepancy in measured levels,

of about 6 dB. Moreover, the major international standards call for this change in

measurement parameters to occur at different frequencies, as illustrated in Figure 5.5.

Figure 5.5. Limit measurement inconsistencies due to parameter changes at 3-10 GHz

Source: SCF Associates Ltd.

As Ericsson researchers explain:

Above 6 GHz for FCC and 10 GHz for ICNIRP, EMF exposure limits are defined in

terms of free-space power density rather than SAR… [W]here the exposure

metric changes, the maximum radiated power to meet compliance with ICNIRP

and FCC EMF limits, for a device used in close proximity of the body, presents a



strong discontinuity (in the order of 6 dB…). This discrepancy has no scientific

basis and is due to inconsistencies in the exposure limits…110

Comments by the ITU submitted in the public consultation on ICNIRP’s new draft

guidelines in 2018 offer a solution: use absorbed power density instead of free-space

power density as the metric.111 This would update previous approaches. Absorbed power

density can be calculated by subtracting reflected power from free-space power – both

of which are readily measurable. If absorption becomes the metric above and below 6

GHz, the discrepancy in measured levels should disappear. A presentation at a workshop

hosted by ANFR in April 2019 on “EMFs and 5G” suggest this change could be

implemented in the new ICNIRP guidelines, with SAR being specified up to 300 GHz.112

That would solve another problem which is not widely recognised. Even though power

density has been nominally used to define RF safety limits above 6-10 GHz, “power

density is not suitable to determine exposure compliance when millimetre wave devices

are used very close to the body”, as one group of researchers noted113. According to

Euramet, the European association of metrology institutes, above 10 GHz there actually

“are no standards for assessing power density in close proximity to the transmitters.

Traceability of nearfield power density measurements to national standards must be

provided, which requires the development of tests and procedures to assess whether

devices are compliant when touched or held”.114 The quote is from Euramet’s invitation

to researchers to apply for funding to develop compliance tests and safety standards for

hand-held transmitters operating above 10 GHz (5G handsets, for example).

Unfortunately, no one applied, which reveals a gap in current standards for compliance

with the Radio Equipment Directive (RED).

There are also potential gaps that deserve attention before they become more serious.

Council Recommendation 1999/519/EC said Member States “should evaluate situations

involving sources of more than one frequency in accordance with the formulae set out in

Annex IV, both in terms of basic restrictions and reference levels…”. Annex IV (titled

“Exposure from sources with multiple frequencies”) provides summation formulas from

ICNIRP’s 1998 guidelines for “situations where simultaneous exposure to fields of

different frequencies occurs…”. Those passages provide the basis for a recommendation

that Member States evaluate aggregate field strengths and enforce safe cumulative

exposure limits in the context of dense deployments of SAWAPs. But as

Recommendation 1999/519/EC may be replaced by newer legislation – to reference

newer ICNIRP guidelines – it will be important to retain the recommendation to control

exposure to overlapping radio signals (assuming that ICNIRP keeps that ruling in the

110 D. Colombi et al. (2015), “Implications of EMF Exposure Limits on Output Power Levels for 5G Devices above 6 GHz,” IEEE Antennas and Wireless Propagation Letters - https://www.ericsson.com/assets/local/news/2015/11/implications-of-emf-exposure-limits.pdf

111 ITU-T Study Group 5 (2018), “Liaison Statement from ITU-T SG5 to RAG [Radiocommunication Advisory Group] on ITU Intersectoral Response to ‘ICNIRP Public Consultation of the Draft ICNIRP Guidelines on Limiting EMF Exposure (100kHz to 300 GHz),” Document RAG19/2-E – https://www.itu.int/dms_pub/itu-r/md/19/rag19/c/R19-RAG19-C-0002!!MSW-E.docx

112 Unfortunately, the presentation announcing this change is still embargoed against citation.

113 T. Wu, T. S. Rappaport and C. M. Collins (2015), “The Human Body and Millimetre-Wave Wireless Communication Systems: Interactions and Implications,” IEEE International Conference on Communications (ICC), June - https://arxiv.org/ftp/arxiv/papers/1503/1503.05944.pdf

114 Euramet (2018), “EMF exposure compliance for 5G and IoT devices” - EMPIR Call 2018: Selected Research Topic number: SRT-n16, Version 1.0 - https://msu.euramet.org/current_calls/pre_norm_2018/SRTs/SRT-n16.pdf



new edition of their guidelines). If ICNIRP does introduce absorbed power density as the

metric over 6 GHz, that will simplify their current summation formula.

The Situation Across the EU Member States

Aggregate signal levels are taken into account in the determination of safe exposure

limits in most Member States, although some (including Germany and Spain) exempt

transmitters below 10 W. Thus, asking the Member States to control aggregate RF levels

for SAWAPs could be portrayed as a return to non-streamlined procedures. Nevertheless,

it seems most unwise to deregulate base station locations and encourage densification

without also ensuring public protection against cumulative RF exposures. But current

practices show that requiring “evaluation” of high density situations does not necessarily

lead to the enforcement of limits – Greece being a case in point, even though they have

“precautionary” limits that are more restrictive than ICNIRP’s. So any successor to

1999/519/EC might need to use a stronger verb than “evaluate”.

Propagation for 5G NR

Finally, because 5G aims to be a bigger leap than previous generations of cellular, it is

necessary to consider if the assumptions underlying past specifications of safe RF

exposure limits are still appropriate for networks based on beamforming active antenna

arrays and multi-user MIMO. Earlier generations of cellular technology had nearly

uniform distributions of radio energy across each base station sector (typically 120

degrees for 3 sector configurations) and that uniformity was assumed when setting

limits on the transmitter power output fed into the antennas. With MU-MIMO and

beamforming – core features of 5G – that assumption is no longer valid. Nor can one

assume that field intensity decreases at a steady, predictable rate with distance from the

transmitter. Because the path loss in the new bands for 5G is so much greater than in

earlier cellular allocations, the base station’s antenna output must be focused into

narrow beams aimed at the antenna on the subscriber’s terminal. The net effect is that

the power emitted in other directions is much lower, but the power aimed at the user is

higher.

Figure 5.6. Adaptive beamforming in 5G

Source: E. Ali et al. (2017), “Beamforming techniques for massive MIMO systems in 5G:

overview, classification, and trends for future research,” Frontiers of Information Technology &

Electronic Engineering, Vol. 18, No. 6, https://link.springer.com/article/10.1631/FITEE.1601817



Tight focusing by the array of antenna elements makes the directed beam intensity

many times greater than a uniform (isotropic) distribution. And depending on where the

user is located, they could be in the path of several beams, as Figure 5.7 shows.

To illustrate the effectiveness of beamforming, here are results given in three recent test

reports from the FCC’s equipment certification website:

Table 5.1. Representative MIMO antenna gains for 5G base stations

Base station

model

Transmitter

rating Band

Antenna

configuration

Measured

gain

EIRP

equivalent

Nokia AirScale

AEUA Flexi-Zone 0.63 W

27.5-28.35

GHz 16 x 16 MIMO 29 dBi

60 dBm =

1000 W

Ericsson AIR

6468 5G radio 60 W

2500 MHz

(Without

integrated

antenna)

Supplied

test antenna

= 23.5 dBi

71.3 dBm =

13,490 W

Nokia AirScale

5G NR (MAA-

64T64R-128AE)

80 W 2496-2690

MHz 8 x 8 MIMO

19.1 - 23.3

dBi (varies

with angle)

74.8 dBm =

30,199.5 W

Source: FCC wireless device applications database, https://fccid.io/ (July 2019)

These intensified beams are dynamic, formed when a communication session begins and

halted when it ends. They also track the subscriber’s movement, with frequent feedback

between the base station and the handset terminal to adjust the power and direction.

The techniques of closed loop automatic power control and dynamic beam steering

represent positive advances in the efficient use of spectrum as they add spatial diversity

to frequency division and time division techniques. However, the emission patterns have

yet to be replicated in test equipment to verify compliance with existing emission limits

and new mathematical models are thus needed to fill the gaps (Rumney, 2019). The

gaps are in both measurement techniques and translation of measured energy levels

into Specific Absorption Rates (SAR) and absorbed power density for human tissues at

5G frequencies. Such models are likely to be more complex than those in earlier

generations of mobile cellular radio. Whether it will be more difficult to determine if a

given 5G transmitter site is or is not compliant with RF exposure limits is difficult to

assess today. The challenge lies in finding the most efficient and accurate procedures

and then developing appropriate field test equipment.

While most public exposure situations today from 3G and 4G base stations are well

within the limits of safety, the concentration of energy by active antenna arrays means

that most areas around future base stations will often produce lower exposures, even as

the high gain directive antennas that are essential to 5G could entail some risk of

overexposure during communication sessions. Since end-user terminals monitor signal

strength for the automatic power control loop, it may be possible to forward some of

that information to regulators as well.115

115 Tests by the EU-funded LEXNET project show that ambient power measurements by the current generation of smartphones are too unreliable for use in regulatory compliance assessments: the device’s orientation strongly affects results. Future models might provide better data if improvements were required and performance standards imposed. See G. Vermeeren, ed. (2014), LEXNET Deliverable D3.3: “Exposure Index Assessment v2” -

http://www.lexnet.fr/fileadmin/user/Deliverables_P2/LEXNET_WP3_D33_Exposure_Index_Assessment_v2_v4.0.pdf



Compliance Assessment

In June 2018, the ITU-R Working Party 5D, responsible for the radio aspects of mobile

telecommunication networks, issued a “Liaison Statement to External Organisations and

Regional Organisations” which noted:

TRP [Total Radiated Power, the parameter best suited to MIMO compliance

assessment] can only be accurately determined in a suitable laboratory

environment using an anechoic chamber or through a suitable antenna port.

Today, it is not possible to make an accurate TRP measurement in the field (over

the air) that could be used for the purposes of enforcement. There is no way to

mathematically derive TRP from e.i.r.p. measurements made in the field

(over the air). For these reasons, the verification of license compliance in the

field (in live operational environments) is not yet possible, if it is to be based on

TRP and there is no suitable antenna port… For enforcement purposes, other

limits than TRP are required.116 (our bold emphases)

The liaison document notes that CEPT SE21 is also looking at this problem in the context

of a revision to ERC Recommendation 74-01. The revision was published in May 2019

and includes preliminary suggestions for measuring TRP for mobile base stations and

terminals that use beamforming via integrated Active Antenna Systems (AAS). It adds

that:

There is currently no information on base stations using AAS and beamforming

with integrated antennas operating between 6 and 24.25 GHz. These could be

considered in a future revision as necessary.117

Additionally, the text states that:

The parameters in Table 1 reflect the increasing difficulty in undertaking real

tests at higher frequencies, taking into account such factors as availability and

usability of suitable measurement equipment… it is recognised that testing at

higher frequency may not have a defined measurement uncertainty due to

absence of primary references. In addition further simplifications of measuring

techniques to achieve time/cost savings, while still guaranteeing with fair

confidence the fulfilment of the requirement may be possible.118

3GPP recently offered a preliminary report on compliance verification for individual 5G

base stations, i.e., SAWAPs.119 It assumes a worst-case scenario (just as a regulator

would) proposing measurement of only the narrowest beam when the transmitter is

operating at maximum power. The report does not address the issue of aggregated

multiple overlapping signals from a dense deployment.

116 ITU-R Working Party 5D (2018), “Liaison statement to External Organisations and Regional Organisations (copy to Working Parties 1A and 1C) - Definition of and test methods for OTA unwanted emissions of IMT radio equipment,” Temporary Document 571(Rev.1): Attachment 7.4 to Document 5D/1011 - https://www.itu.int/md/R15-WP5D-180613-TD-0571

117 ECC (2019), ERC Recommendation 74-01: Unwanted emissions in the spurious domain, amended 29 May - https://www.ecodocdb.dk/download/3af8bcdd-43ae/ERCREC7401.pdf

118 Ibid.

119 3GPP (2019), TR 37.843 V15.4.0 - Technical Report: Radio Frequency (RF) requirement background for Active Antenna System (AAS) Base Station (BS) radiated requirements - http://www.3gpp.org/ftp//Specs/archive/37_series/37.843/37843-f40.zip.



The 3GPP report's approach might not be acceptable to MNOs since it can be argued that

maximum beam intensity is not representative of the entire coverage area. That is the

crux of the problem in assessing 5G compliance with current safety standards: using

peak (maximum permitted) exposure as the test of compliance means that severe limits

must be imposed on transmitter power output. Anything else can lead to excessive –

even if temporary – exposure (although in a fixed 5G deployment, the exposure might

not be temporary).

However, radio energy emitted by 5G beamforming SAWAPs may prove to be less of a

concern than the RF emissions of 5G handsets. These devices may emit much less power

but they are in direct contact with head and hand during normal use. Moreover, because

some 5G frequencies have more path loss than 4G or 3G, 3GPP has already developed

standards for handsets to operate at higher power than any previous cellular

generation.120 The FCC recently issued its first authorisation of a 5G handset operating

at mmWave frequencies.121 Test reports indicate that the handset’s “worst case front

side total power density value” was about 76% of the FCC’s safety limit. Typical

exposures to RF emissions from LTE base stations in Europe have been found to be less

than 8% of ICNIRP’s recommended limit, often much less.

Figure 5.7. Comparing SAR for 4G and 5G handsets

Source: W. Hong, et al. (2014) “Study and prototyping of practically large-scale mmWave

antenna systems for 5G cellular devices,” IEEE Communications Magazine122

The premise that beamforming handsets could be of greater concern than SAWAPs is

also borne out by research from France’s National Agency for Food, Environmental and

Occupational Health & Safety (Agence nationale de sécurité sanitaire de l’alimentation,

de l’environnement et du travail, ANSES). The EN 62209-2 standard allowed cellular

120 3GPP (2017), “Work Item Description RP-171492: LTE Advanced high power TDD UE [User Equipment] (power class 2)” - https://www.3gpp.org/ftp/TSG_RAN/TSG_RAN/TSGR_76/Docs/RP-171492.zip “...many operators and vendors have realized the significant benefit for increasing the UE transmits power. Now the HPUE for many other bands, e.g., Band 38, Band 40 and Band 42, is gradually requested by operators.

Especially, specifying a 26dBm UE [400 mW] for Band 38 [2600 MHz] may help to grow the LTE TDD ecosystem in Europe…”

121 PC Labs (2019), “FCC Report A3LSMG977U: Samsung Portable Handset,” 25 April - https://fcc.report/FCC-ID/A3LSMG977U

122 https://www.semanticscholar.org/paper/Study-and-prototyping-of-practically-large-scale-5G-Hong-Baek/7461d2013d34a8d925e7f87bd6171e03cdd46d7c/



handsets to be designed for exposure limit testing with the handset and test dummy

separated by up to 25 mm, and the R&TTE Directive (1999/5/EC) allowed manufacturers

to define the separation distance for testing (15 mm was typical).

When re-measured with zero separation (i.e. typically how people actually speak on

phones) 89% of the handsets induced SAR greater than 2 W/kg and 25% induced SAR

greater than 4 W/kg123 (2 W/kg is the SAR limit set by ICNIRP for exposures of head and

torso, 4 W/kg is the whole-body SAR limit). The Radio Equipment Directive

(2014/53/EU), which replaced the R&TTE Directive, is a step forward in that it requires

conformance testing under “reasonably foreseeable conditions” – not conditions chosen

by manufacturers. We expect this change to ensure that newer handsets radiate less

than older models.

However, since the RED came into force, regulators, standards development

organisations and equipment manufacturers have struggled to agree on a common

interpretation of “reasonably foreseeable conditions” for compliance testing. The

Commission might wish to offer guidance on that topic, perhaps in the RED Guide.

France’s ANSES has also sponsored research by Chobineh et al. (2018) based on a

promising new metric developed by the EU-funded LEXNET project:

“There is an important correlation between EM radiations transmitted by UE [user

equipment] and received from BS [the base station]. However, for a long time

the downlink and uplink exposures have been considered and assessed

separately. In the framework of LEXNET, a new exposure metric named Exposure

Index (EI) was developed to quantify the exposure induced by UE and BS

simultaneously.” 124

The Exposure Index (EI) takes the time dimension of exposure to RF emissions from

multiple sources into account, as well as environmental factors, giving a more detailed

representation of variations in signal strength. Observing small LTE cells in real indoor

and outdoor settings showed that “the propagation channel [between base station and

end user] is strongly dependent on the local environment and can be affected by any

minor change, eg a passing car”. Path losses vary widely over short distances, making

exposure levels more uncertain, but beyond about 30-60 m from the base station, power

density tends to stabilise. Comparing indoor to outdoor RF exposure levels, the

researchers found that indoor exposures were about 4 times larger than outdoor, due

entirely to the stronger emissions of user terminals compensating for the attenuation of

signals passing through walls to and from outdoor base stations as shown in Figure 5.8

below (note that indoor SAWAPs can circumvent this problem.) Indoor or outdoor,

exposure levels were but a tiny fraction of the ICNIRP limits. However, LTE is not 5G and

so these findings do not consider the impact of beam forming.

123 ANSES (2015), Exposition aux radiofréquences et santé des enfants - https://www.anses.fr/en/system/files/AP2012SA0091Ra.pdf.

124 A. Chobineh et al. (2018), “Statistical Model of the Human RF Exposure in Small Cells Environment” - https://arxiv.org/pdf/1811.02317



Figure 5.8. Uplink and downlink RF exposure levels for LTE, indoors and outdoors

Source: Chobineh et al. (2018)

We now turn to responding to the key question of emission power limits being

sufficiently covered and enforced through existing standards to comply with the Radio

Equipment Directive (RED). The other question posed by the Terms of Reference was:

Are additional provisions needed as part of the implementation of EECC

Article 57?

Such provisions could be part of an implementing act expected from the Commission for

20 June 2020, or alternatively, these provisions could be put forward in some form of

amendments to the EECC. Note that the content of the implementing act should be

limited to the specification of “physical and technical characteristics, such as maximum

size, weight, and where appropriate emission power of small-area wireless access

points”. Thus, considerations for the physical and technical characteristics of SAWAPs

are prepared here in Chapter 5 and recommendations are given in Chapter 6.

On the question of amending the EECC, we have found no suggestions that might

improve the EECC, apart from one proposal below, on exclusion zones being based on

received or absorbed power, as explained in section 5.5.

In conclusion – the main issues of public concern regarding network

densification and deployment of small cells are safety and aesthetics

As the Commission’s recent consultation in February to April of 2019 on SAWAPs rollout

showed, the main issues of public concern regarding network densification and

accelerated deployment of small cells, in order of priority, are safety and aesthetics.

Failure to address these concerns might provoke acceptance issues. However, a well-

crafted EU-wide campaign of public education and involvement in the design and

selection of outdoor SAWAPs could mitigate that risk.

Specific safety-related standards clearly need to be updated in light of 5G. The imminent

release of a new set of ICNIRP guidelines could help with that and might lead to a

cascade of updates among other standards, particularly those dealing with compliance

issues above 6 GHz. A successor to Recommendation 1999/519/EC may be needed to

reference newer ICNIRP guidelines and if that occurs it will be essential to preserve and

even strengthen the Member States’ attention to aggregate RF signal levels as a best

practice as network densification progresses and control over small cell siting is relaxed.



Meanwhile, the task of developing field tests and appropriate safety standards for radio

equipment that utilises beamforming and active MU-MIMO antennas needs to be

addressed. The most important issue is that the focussing of energy by active antenna

arrays produces much greater power densities than were anticipated when transmitter

output levels were originally defined for compliance with human RF exposure limits.

While the Exposure Index developed by the EU-funded LEXNET project is promising, it is

complex – perhaps too complex to be widely adopted. Until there is a consensus solution

to the challenge of assessing 5G compliance with RF safety standards, it seems

necessary to put conservative limits on transmitter power for SAWAPS to qualify as

permit-free.

5.5 Adapting RF EMF Limits to 5G

Analysis of the technical specifications and reports from 3GPP and others on small cells

indicates that with 5G, far more than with previous mobile generations, there are

numerous possibilities for aggregating signals. This implies dynamic complexity and a

linear increase in power as more channels are added:

Multiple frequency bands from UHF to over 60 GHz (although 5G in the EU may

initially develop in the sub-6 GHz bands).

Carrier aggregation across multiple bands for wider bandwidth at the handset and

BTS.

Multiple channels if the BTS is shared among several MNOs.

Multiple emissions originating at other sites and overlapping with the cell being

used in a communication session. Over time, the number of 5G sites will tend to

increase, in order to expand throughput and compensate for loss of range due to

the use of higher frequencies.

Multiple generations of mobile technologies with different waveforms and duty

cycles including GSM, the mutually incompatible variants of 3G, LTE, possibly

others (e.g. Wi-Fi, narrowband IoT, PMR, and so on).

Multiple terminal devices within one 5G cell: e.g. embedded sensors in addition to

handsets attempting simultaneous contact with the BTS.

Reflections from the landscape and interactions among MIMO beams are difficult

to predict despite being line-of-sight.

MIMO increases the antenna gain and so intensifies the RF field. For instance, the

1024 element (32x32) array used in Verizon’s Fixed Wireless Access BTS has a

gain of 30dBi over isotropic antennae (1000 times) and is fully steerable.

It is important to note that 3GPP and ETSI are mainly concerned with communication

between devices. The ICNIRP guidelines for limiting human exposure to RF energy are

not part of the 3GPP problem set. Cellular standards try to minimise energy consumption

for better battery life and lower operating costs, but 3GPP does not consider the impact

of radio energy on the human body as part of their competence. Assuring that

consideration would require a new mandate from the Commission to ETSI.

A worthy objective in any case would be for one of Europe’s specialised standards

organisations or scientific committees125 (if not ETSI then CENELEC or SCHEER, the

recently formed Scientific Committee on Health, Environmental and Emerging Risks) to

define norms for ensuring and verifying that SAWAPs using MIMO, beamforming active

125 Commission Decision of 5 August 2008 setting up an advisory structure of Scientific Committees and experts in the field of consumer safety, public health and the environment and repealing Decision 2004/210/EC - https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:241:0021:0030:EN:PDF



antenna array systems and other advanced (5G) technologies, comply with existing or

updated ICNIRP guidelines. By linking those norms to the Radio Equipment Directive

(particularly Articles 6 and 7), only equipment that is compliant could be deployed in the

EU without further national provisions for the protection of public health and safety.

The EMF-related health and safety regulations in Europe (Recommendation 1999/519/EC

and the relevant EECC Articles) require exclusion zones to prevent access to spaces

where RF field intensity is too great and limits on the signal power absorbed by users.

Exclusion zones are commonly included in manufacturers’ deployment instructions to

conform with regulations and norms – particularly CENELEC EN 50383, IEC 62232 Ed 2.0

and the ICNIRP guidelines. An overview of the principles of the range and frequency-

related constraints for safety around a SAWAP BTS is given in Figure 5.9.

Figure 5.9. Exclusion zones and the impact of frequency limits on range

24Simon Forge SCF ASSOCIATES Ltd all rights reserved 2018

Frequency/Power/Range – (Diagrammatically)

Power

emitted

EIRP

W

Log Range for MIMO propagation, m

26GHz

6GHz

5 10 100 1000m

700MHz

Exposure

Limit Value

(ELV) -

SAWAP

Exclusion

Zone

SAWAP

SAWAP Cell Outdoor Exclusion zones

Occasional (passing use)

Installation Limit

Value (ILV) (residential/

working environment

Exclusion zone)

Frequency

band

Unless the power limits are set very low, the characteristics of SAWAPs defined by

the implementing act called for in EECC Article 57 will need to consider exclusion

zones based on received or absorbed power. (Specifications based on emitted power

are easier to formulate and enforce but they affect safety only indirectly.) For

outdoor SAWAPs, the recommendation is thus to define two exclusion zones

differentiated by the use of beamforming and the expected duration of exposure:

A normal exclusion zone is for short-term exposures from the SAWAP, defined by

an Exposure Limit Value (ELV) distance

A second (larger) exclusion zone would be defined for situations where prolonged

exposures are likely – workplaces, residences, schools, etc – or where

beamforming is used. This exclusion zone is defined by the Installation Limit

Value (ILV) distance

A consensus of measurements in EU and non-EU countries is needed to produce

median estimates for emission limits and exclusion zones. Recent measurements

show that in the immediate proximity of a small cell (“microcell”) antenna, within a

radius of less than 2 m the maximum exposure at frequencies below 6 GHz varies

between 0.7 V/m and 2.7 V/m. Only some 3% of measurements exceeded 3 V/m.126

126 ANFR (2018), «Connectivite Urbaine: Rapport technique sur les déploiements pilotes de petites antennes en France pour favoriser l’accès au très haut débit mobile» - https://www.anfr.fr/fileadmin/mediatheque/documents/expace/petites-antennes/2018-12_Rapport_d%C3%A9ploiements_pilotes_petites_antennes_vf.pdf



This is well below the ICNIRP safety norm of 6 V/m. However, as shown in Chapter

2, current Power Density Limits are much lower in nine of the EU Member States as

well as in neighbouring countries such as Switzerland and Russia.

Implications for Recommended Output Power Levels

As noted in earlier chapters, the challenge of testing SAWAPs which use beamforming

antennae based on multi-user MIMO means that it is currently not possible to estimate

user exposure to emitted RF energy and thus it is not possible to assess compliance with

existing standards. In the light of this, it is necessary to err on the side of safety. As

EECC Recital 110 declares:

The need to ensure that citizens are not exposed to electromagnetic fields at a

level harmful to public health is imperative. Member States should pursue

consistency across the Union to address this issue, having particular regard to the

precautionary approach taken in Recommendation 1999/519/EC.

The only practical approach available at this time is to use emitted EIRP as a proxy for

received power, as has been done for previous generations of mobile cellular technology

(LTE, UMTS, GSM, etc). Consequently, power levels for exempting beamforming SAWAPs

from local permits should be set very conservatively at present, because exposure levels

are hard to predict. Even so, it should be emphasised that this approach suffers from a

lack of evidence of compliance with the SAR limits recommended by ICNIRP. However,

we understand that the revised version of IEC 62232 (publication expected in December

2019) may cover active antenna systems (AAS) so it may offer a new approach to

verifying compliance with the ICNIRP guidelines. Nevertheless, further simulations

backed by field measurements are needed to ensure that the essential safety

requirements of RED Article 3.1 are met.

With progress in measurement techniques, better understanding of mmWave

propagation in urban environments and more accurate mathematical models of both

active antennae and radio’s impact on living organisms, new field testing methods may

emerge for 5G. That would enable “erring on the side of safety” to be replaced by more

robust evidence-based power levels for permit-free SAWAPs. At that point, the

introduction of a higher power class of SAWAP would be feasible.

Because the higher frequencies used by 5G for MU-MIMO interact much more with the

environment than the lower frequencies used in earlier generations of cellular, field

measurements of actual intensity levels may be necessary on a more or less continuous

basis. That could be done with specialised sensors or apps installed in smartphones,

although tests with current handsets have been disappointing.127 Switzerland is already

building a nationwide monitoring network to complement 5G deployment and Poland has

proposed something similar.128 Most NRAs already have fixed and/or mobile monitoring

networks.

127 G. Vermeeren, ed. (2014), LEXNET Deliverable D3.3: “Exposure Index Assessment v2” - http://www.lexnet.fr/fileadmin/user/Deliverables_P2/LEXNET_WP3_D33_Exposure_Index_Assessment_v2_v4.0.pdf

128 Described in the Ministry for Digital Affairs’ substantiation of amendments to the Law on Telecommunication, “Uzasadnienie: Potrzeba i cel uchwalenia projektowanej ustawy” [Substantiation: The need and purpose of adopting the draft law], 30 November 2018, https://mc.bip.gov.pl/fobjects/download/476134/1-uzasadnienie-do-projektu-ud172-docx.html



5.6 SAWAPs under IEC E2 and E10

Automatic exemption from local permits for MIMO beamforming SAWAPs with a power

rating of 1 W maximum transmitted power or less need not prevent the deployment of

SAWAPs that do not use MIMO beamforming for higher power density, but use 3G UMTS

or LTE technology with power levels as the current IEC standard indicates (and as shown

in Figure 3.1, following IEC 62232, 2017). That could include E2 and E10 BTS as

SAWAPs (without focussed MIMO beamforming) with 2 W or 10 W output in broad

sectors, sited above street level at the specified heights with the principle lobe

characteristics required (see Figure 3.1). Examples of use could be for spot coverage

outdoors, of intersections, bus stops, car parks and indoor public spaces – metro

stations, shopping malls, sports stadiums, etc.

Moreover, the output transmission power limit is currently within the competence of the

Member States and in many (such as Estonia, Greece, Lithuania, Luxembourg) their

exemptions for higher power levels than 10W are already in place. These would

presumably continue after the introduction of an EU-wide permit exemption for SAWAPs.

Use of the IEC E2 and E10 specifications could mix LTE BTS types with 5G implying

either separate SAWAP networks or mixing core networks, BTS and RANs. Note that the

3GPP 5G NR specifications already anticipate mixing small cell types and core network

types in close configurations.129 So 5G SAWAPs can already use the control plane of an

existing LTE network (Release 15, 5G NR, Non-Standalone mode).

Thus, setting a SAWAP power limit for the EU within a light licensing regime need not

create a hard boundary between permit free and permit required small cells across the

Member States in terms of transmitted power. Higher power small cells, even with beam

forming, may also be permitted as that is dependent on decisions within each Member

State. The difference is more likely to be in the speed and cost of deployment, with a

slower pace for units which are not in EU SAWAP compliance. For non-compliant units,

network installers would need to obtain permits and to provide the authorities with

certain prior information about - and control over – site choices and environmental

integration issues. In line with the consideration in this study, that heavier regime would

apply to the more powerful BTS that do use beamforming above 1 W, or are

conventional LTE/ UMTS above 10 W (and still deployed according the current IEC

specifications following the ICNIRP recommendations).

What applications or use cases might be affected by the choice of a

power limit for SAWAPs?

The EU’s Better Regulation guidelines call for an impact assessment that considers what

applications or use cases might be affected by the choice of a high or low power limit on

SAWAPs. The main practical consequences of the choice between 2 and 10 watts would

be on building penetration, signal range, coverage area and link reliability. However

there is still uncertainty in calculating range and coverage due the different propagation

models of 5G technology which are currently being researched.

129 3GPP, Release 16, 16 July 2019, https://www.3gpp.org/release-16, and Technical Specification 21.916 (2019), “Release Description” - http://ftp.3gpp.org//Specs/archive/21_series/21.916/21916-010.zip



Despite this uncertainty, an approximate qualitative discussion of the practical impact of

power limits on various applications proposed by 3GPP for 5G follows below. This

assumes that an increase in power from 1W for MIMO beamformed SAWAPs to the

current IEC 62232 (2017) recommendations for the E2 and E10 power classes for

conventional LTE-type isotropic/sectored, non-beamforming antennae (as given in Figure

3.1).130

The use cases discussed here are taken from 3GPP TR 22.891 V14.2.0131 which aims:

“to identify the market segments and verticals whose needs 3GPP should focus on

meeting, and to identify groups of related use cases and requirements that the

3GPP eco-system would need to support in the future.”

That document maps over seventy use-cases to operational requirements including

network configuration and management – eg roaming, slicing, security etc. However,

while various baseline requirements for the use-cases are cited, transmitter power is not

among them, though it does feature in other 3GPP BTS specifications.

The following group of applications seems dependent on macrocells, so the SAWAP

power limit would not affect them (SAWAPs would have at most an in-fill role):

Public warning systems;

Lifeline communications during natural disasters;

Seamless wide-area communications coverage for rapidly moving vehicles with

frequent handovers as well as with remote static transceivers – eg in rural

situations;

Provision of essential services in very low-ARPU areas;

Wide-area sensor monitoring and event driven alarms over large distances;

Connected cars – moving vehicle Internet and infotainment;

Data services for passengers on high-speed trains;

Connectivity for drones.

The following group of applications would probably not be hindered or affected by a 1W

maximum transmitted power limit on SAWAPs with AAS-beam-forming:

Short messaging services (SMS);

Content caching within the network;

Device theft prevention/stolen device recovery;

Flexible participation in interactive gaming;

Simultaneous connectivity across multiple operators;

Temporary service for other operators’ subscribers in an emergency;

Priority classes, QoS and policy control;

Delivery assurance for high-latency-tolerant services;

“Wireless briefcase” (personal cloud content management);

Low-mobility devices (IoT);

Subscription security credential updates for the Internet of Things.

130 Use of E2 and E10 BTS might extend the signal range for indoor penetration from outside at UHF frequencies. But all depends on the frequencies of transmission and ambient propagation conditions as well as the distance.

131 3GPP (2016), Technical Report TR 22.891 V14.2.0: “Feasibility Study on New Services and Markets Technology Enablers; Stage 1 (Release 14) - http://www.3gpp.org/ftp/Specs/archive/22_series/22.891/22891-e20.zip



The following applications might be affected by the choice of a SAWAP power limit – not

in an absolute way (enabled or prevented), but in terms of the quality of experience, the

cost of infrastructure or the choice of a suitable frequency range:

• Wireless local loop;

• Fixed wireless access (FWA);

• Transmission of scheduled programming and on-demand audio and video;

• Industrial control networks;

• Factory automation;

• Inventory management/location tracking;

• Ultra-reliable communications (for URLLC);

• Ad hoc broadcasting;

• Virtual presence;

• Cloud robotics;

• Tactile internet.

Some applications in this group are still just ideas rather than actual markets of

measurable size (e.g., tactile Internet, cloud robotics, virtual presence). Many of those

that already exist (wireless local loop, industrial control, factory automation) are able to

adapt to the available signal range or use non-cellular alternatives. That, plus the

uncertainty of future revenue from potentially significant new markets (URLLC, factory

automation) makes forecasting the economic impact of a exemption power limit quite

speculative.

Finally, the following set of applications can operate well with – and might perhaps

benefit from – a 1W maximum transmitted power limit on SAWAPs with beamforming:

• Indoor and outdoor hotspots in dense urban areas;

• Wireless self-backhaul over short distances;

• On-demand networking at large public gatherings;

• Medical telemetry for bio-connectivity;

• Wearable device communications to a SAWAP or relayed via a smartphone;

• Domestic home monitoring.

This discussion suggests that the economic impact of a SAWAP power limit higher than 1

watt is likely to be minor, because the range of applications affected is a small subset of

those foreseen. Also, adaptations will be possible (e.g. by adjusting the inter-site

spacing and network topology) and non-cellular alternatives such as Wi-Fi are also

readily available. As current reconsiderations of safe human exposure limits and

compliance testing methods for 5G are still incomplete and conventional (non-

beamforming) E2 and E10 type transceivers could be exempt at higher powers, avoiding

problems with public acceptance should also be taken into account

5.7 Gaining Planning Authority Exemption

Adopting regionally consistent rules for exempting SAWAPs from building permit

requirements means overcoming differences among Member States’ current siting and

construction controls while developing a consensus on appropriate dimensions for small

cells using SAWAPs. Qualitative and quantitative characteristics are suggested for the

criteria listed below based on our examination of commonly accepted values in Member

States (Chapter 2 and Appendix). These should be modified in response to the

examination procedure referred to in EECC Article 118(4):



Physical size of equipment enclosure: 20-30 litres (i.e. 27 cm x 27 cm x 27

cm or 31 cm x 31 cm x 31 cm respectively, if a cube) or less and may be

separate from the antenna; may be larger if enclosed within existing street

furniture.

Physical size of antenna: longest dimension, under 0.3 m, unless within

existing street furniture.

Height above street (which gives separation distance from humans):

more than 3 m but less than 5 m.

Cabling: concealed.

Mounting position: on wall or roof with concealed attachments.

Mounting structure: brackets and supports not visible to passers-by

Surface treatment of enclosure: colours consistent with the surrounding area.

Weight: <50 kg for equipment, enclosure and antenna.

While buildings and sites of historic or cultural importance should continue to require

specific permits, that should not be the case for any other structure. But minimising

disturbance of the visual environment must be a goal, in addition to protecting public

health and safety. Ease of installation is a further priority, i.e. minimisation of disruption

for power and backhaul connection:

No street closure for assembly and installation

No cabling and ducting street works that close access paths.

SAWAPs that do require such civil works might need a planning or building permit.

The following chapter describes our analysis to define a minimal parameter set for a

simple permit-free qualification of a SAWAP.



6. Recommendations for the Implementing Act

Following the discussion in Chapter 5, this chapter proposes recommendations for

physical and technical specification of SAWAPs for inclusion in an implementing act.

6.1 A Minimalist Approach

Rapid small cell rollout on a large scale across the EU will be facilitated by the exemption

of SAWAPs from any individual town planning permit or other prior individual permits.

The Terms of Reference of the study note that specification of SAWAPs should be based

on explicit technical and physical characteristics (for instance, maximum size, weight,

installation height, antenna size, antenna height above ground or rooftop, etc, and

where appropriate emission power and range).

Analysis from information collated in the previous chapters, drawn from the interviews,

workshops and questionnaires with the relevant authorities in the Member States and

with the telecommunications industry indicates that a "minimalist" approach is optimal.

It is minimalist in terms of the number of specifying parameters, aimed at reducing the

quantity of possible objections and conflicts. Simplification of specifications becomes

essential when the main objective is to reduce the time and administrative burden

currently experienced to deploy SAWAPs, in order to facilitate the network densification

needed for 5G services.

This approach is based on the need to deal with the wide range of existing differing

criteria across the Member States in a practical manner. This conclusion comes from

both the current laws in the 28 Member States and the relevant players in the telecoms

industry, including MNOs, suppliers and installers, and regulators. The conclusion is that

a minimal definition is essential for reaching any EU-wide agreement.

In terms of deployment, a minimal specification leaves open the applications – be they

for enterprise use in industrial zones or for use in the street for the general public.

In consequence, we recommend restricting the parameters and parameter values as

shown in Table 6.1.

However, for safety, their values should be subject to final confirmation using

further analysis and study from a proposed expert consultation on human

exposure for health and safety for beamforming active antenna systems for all

frequencies that may be used (for example, over the range 450 MHz – 100 GHz). The

revisions expected from the IEC in its future publications in 2020 and 2021 on this,

following ICNIRP and WHO reviews on RF EMF affects, should also be taken into account.

Industry approval of the proposed volume for physical size of a SAWAP will also be

needed despite the recommendation of this size in various interactions with the industry.

Also, the health and safety aspects of the emitted power should always conform to the

EU regulations en vigeur at the time and their evolution. SAWAPs will have to be

upgraded to keep within any revisions in legal limits. Note that the Member States may

still impose extra conditions, as implementation of RF EMF limits is a national

competence.



Table 6.1. Recommended SAWAP defining parameter set for permit exemption

Definition of parameter for exemption

Limiting value for exemption

For outdoor SAWAPs emission power (in absence of valid field measurement and monitoring techniques for AAS beamforming with MIMO in any band)

a) For an active antenna system (AAS) with multi-user MIMO beamforming antenna, an upper limit of 1 Watt maximum transmit power. Note that this is a provisional initial estimate. This value should be redefined in terms of a SAR value received by users in W/kg for a MIMO beamformed transmission to meet any subsequent ICNIRP guidelines when new research establishes the appropriate limit. b) For an antenna system not using beamforming with AAS MIMO but instead using conventional 120 degree or 90 degree sectors, the upper limit guidelines are as given in the IEC 62232 (2.0) 2017-08 standard for the categories E2 (2W EIRP) or E10 (10W EIRP) with a minimum 2.2 metre height above ground level.

Physical size of outdoor SAWAP transceiver enclosure if exposed outdoors (and not hidden inside street furniture when it may be larger).

20-30 litres, including power supplies and batteries. Note that this volume range depends on configuration and technology used.

For indoor SAWAPs emission power (in absence of valid field measurement and monitoring techniques for AAS beamforming with MIMO in any band)

Less than 0.2 W EIRP for non-AAS. For AAS to be determined.

Physical size of indoor SAWAP transceiver enclosure

No size limits.

Physical aesthetic considerations Installation principles, as in the seven clauses of section 6.6.

Notes for Table 6.1:

Each of the defining parameters above is further described in the following

subsections.

For indoor use from outdoors for the low power beamforming SAWAP, through-wall

transmission to indoor users may be supported using the AAS MIMO beamforming,

perhaps assisted by an amplifying repeater on or in the building for fixed wireless

access (FWA).

The volume in litres indicated above for an outdoor SAWAP unit describes a unit that

can house the main components which may include the antenna array if integrated

into the unit, with space for power supplies and cooling. It follows industry

suggestions in the Stakeholder Workshop and after, also taking into account

technological developments.

Importantly, in the case of setting an upper power limit, the chosen value should

take into account the latest research, which is still emerging, on measuring 5G multi-

user MIMO AAS EMF for safe power levels to meet the ICNIRP Specific Absorption

Rates (SAR) upper limit in the field, for user sessions with a 5G NR MIMO handset

device.

Note that the recommended specification in Table 6.1 sets the benchmark for

Europe. Moreover, its silence on specifying other potential parameters leaves open

the question of additional parameters being applied under the subsidiarity principle

for each Member State, which may be mentioned in the implementing act.

Aesthetics considerations are included as being physical characteristics for

deployment, as required by Article 57 (1).



Further collaboration on an EU-wide regional standard is required with the standards

development organisations, to arrive at an expert concertation on the power levels

for application EU-wide. That would define the ultimate version of the above table.

6.2 Selecting the Level of Emitted Power for Beamforming

SAWAPs

The level chosen is at the low end of the dominant recommendations for today’s LTE and

UMTS base stations. This is because MIMO with beam forming antenna gives a focussed

signal from the SAWAP that can be between 25 dBi and 35 dBi greater in power than the

uniformly radiated isotropic signal from conventional LTE or UMTS antennae (see Table

5.1 in Chapter 5, Representative MIMO antenna gains for 5G base stations from FCC

tests).

The current recommendations in IEC 62232 Ed 2.0 were made for today’s generations of

mobile cellular coverage with segmented and isotropic antennae, most often divided into

multiple segmented transmission areas, commonly as three 120 degree segments. Such

recommendations do not yet include 5G technology SAWAPs using beamforming active

array antenna with MIMO. For current isotropic antenna, the IEC 62232 recommendation

gives standard BTS powers for specific classes of GSM, UMTS, and LTE base stations,

notably E2 with up to 2W output EIRP, E10 (<10W) and E100 (<100W EIRP) and E+ for

higher power. They also cover very low-power access points (similar to Wi-Fi routers) for

those technology generations only, which typically have an isotropic output power of

<200mW. A relevant class of emissions (termed E0) is described in the IEC 62232

standard (see Figure 3.1) as being touch compliant with zero exclusion zone. This norm

may not include the new 5G access points with AAS using MIMO.

The range from a SAWAP will vary with frequency – so that sub 6GHz will tend to have a

greater propagation range than current LTE and UMTS 3G base stations of the same

power, being extended by AAS beamforming. But the much higher mmWave frequencies

(24-28GHz) would offer significantly reduced ranges, depending on power, local

weather, obstruction and foliage conditions, for ranges of the order of 100s of metres or

less.

The actual maximum power used in any cellular deployment is set by the inter-site

distance (ISD) between base stations. For the cellular principle of frequency re-use, this

distance must be far enough so the power density decays sufficiently to avoid interfering

with the next cell. Hence the level of emitted power for beamforming SAWAPs must be

just enough to operate the network but no more - the same engineering principle for

cellular systems with isotropic coverage. Also, 5G deployment may use TDD, whose

frame synchronisation must take account of other emissions, to the extent of avoiding

interference, especially in a multi-operator environment, so range (given by frequency

as well as power) and ISD are the prime variables.

Safe working distances for users scale as the square root of the transmitted power. With

multiple users and multiple simultaneous sessions, the link budget will be shared among

them, reducing power to each.

In a dense network of beamforming SAWAPs of the recommended

power, EMF exposure can be lower than for macrocell configurations



However, there is also the effect of playing off cell density against power to lower the

cumulative RF exposure. With suitable signal levels, higher density networks could lead

to an overall lowering of the net RF exposure, partly from the SAWAP but particularly

from the communicating user terminal, as the signal needs lower power (being much

closer to the SAWAP) than for a macrocell. So for a normal two-way communication in a

dense SAWAP deployment, there is the benefit of a lower power requirement from the

handset as the distance to the base station is reduced (Rumney, 2019). Just as long as

the (5G) SAWAP power is adequate, but no more, then inter-site spacing should be

arranged such that overlapping SAWAPs’ power is minimal, which also attenuates

interference effects. Thus, if beamforming small cells are used in a dense deployment,

the overall effect can be to lower aggregated RF exposure from multiple cells, compared

to what is necessary when accessing a macrocell.

Small cells of up to 1 W (or equivalently up to 2W or 10W in the case of isotropically

radiating antennas) can be envisaged in at least three major applications:

First, for dense coverage of urban areas, offering high speed local broadband

connections to pedestrians in the street.

Second, through-wall connectivity into buildings for nomadic users, or fixed

wireless access (FWA) to houses or apartment blocks. 5G signals can be focussed

for FWA using MIMO and beamforming for line of sight communications to

external antennae, for through-window communication and/or for wall

penetration. Signal quality and performance will vary with distance and the

actual frequencies used, as well as the weather conditions for mmWave

emissions. Frequencies in the UHF range, especially the bands below 1GHz, and

macro-cells would be ideal for outdoor-to-indoor penetration at lower power,

which T-Mobile USA is proposing, with its 600 MHz 5G network132.

IoT applications, if industrial use of 5G takes off: SAWAPs may be deployed over

short ranges indoors in factories, labs and offices and also outdoors across

industrial campuses and smart cities, which may potentially drive major

deployments of SAWAPs. Note that for indoor applications the lower limit (200

mW) may often be the best choice to protect workers in an RF field.

6.3 Precedents for Power Levels

Similar power levels for small cells are already recommended in international standards

and used in current practice. The LTE specifications from ETSI/3GPP define a local area

base station as having maximum rated power of 250 mW (24 dBm).133 The proposed

design specification for LTE small cells is just above the typical power of mobile

handsets, of the order of 200 mW (23 dBm) EIRP for 3G and LTE. That is typically a

sectored transmission with 120 degree sectors and 12 degree horizontal spread. This

small LTE local area base station is intended to be mounted on or inside street furniture

132 Use of AAS with frequencies below 1GHz is well established, based on designs for longer wavelengths that shrink the antenna size. See, for example, Roberson and Associates LLC (2013), “Exhibit A before the FCC: Analysis of the 35x35 MHz Band Plan Proposal for 600 MHz Spectrum, on behalf of T-Mobile USA” - https://ecfsapi.fcc.gov/file/7022130364.pdf or W. Martinsen (2018), "A High Performance Active Antenna for the High Frequency Band", DST-Group-TR-3522, Australian Dept of Defense (unclassified) https://www.dst.defence.gov.au/sites/default/files/publications/documents/DST-Group-TR-3522.pdf.

133 3GPP TS 36.104 version 16.2.0 (Release 16), “Evolved Universal Terrestrial Radio Access (E-UTRA); Base Station (BS) radio transmission and reception” - http://www.3gpp.org/ftp//Specs/archive/36_series/36.104/36104-g20.zip



in high density deployments. Using directional antennae with higher gain for extra range

may offer an inter site distance (ISD) of 200-500 metres, depending on the frequency

band134. 5G small cells both in mmWave and sub-6Ghz bands will have directional

antennae which concentrate output power.

There are other potential small cell models from international norms with this order of

power, for instance ITU-T Recommendation K.52135 and its companion document on RF

limits, ITU-T Recommendation K.70 (2018).136 Recommendation K.52 defines an

“inherently compliant” base station as having “EIRP of 2W or less”. However, that

recommendation is for previous generations of isotropic mobile technology and the

current ICNIRP limits. It may not apply to 5G high gain MIMO AAS with beamforming, so

setting a lower power is prudent.

However, K.52 does also consider microwave beams for line-of-sight point-to-point fixed

networks. That can be considered comparable to beamformed MIMO signals. Thus, for

low-gain small aperture microwave or millimetre-wave antennas, K.52 continues:

“the total radiating power of 100 mW or less can be regarded as inherently

compliant” with ICNIRP limits (Appendix IV). This EIRP corresponds to “a power

density of 0.16 W/m2 at a distance of 1 m, while the lowest ICNIRP power density

limit for the general public is 2 W/m2, for the (2004) ICNIRP levels”.

6.4 The Possibility of a Higher Power Small Cell

In Table 6.1 on the recommended SAWAP specifications, the option is given to use

transceiver units without MIMO beamforming that follows the IEC 62232

recommendations for E2 and E10 classes with upper limits of 2 W and 10 W respectively

for LTE and UMTS technology. The various applications which may need a 10 W or 2W

non-MIMO-AAS-beamforming SAWAP were considered in Section 5.6 including what

services may be constrained or problematic if the maximum power limit is limited.

There is also the possibility that outdoor small cell units beyond the SAWAP power and

size limits could be introduced. For instance, a fixed wireless access (FWA) unit with 10

W total transmitted power might be envisaged that uses beam forming for its directional

focus. That would require a suitable exclusion zone for health and safety and for

deployment would not qualify within the EU lightweight deployment regime as being

permit free.

It could have the same physical dimensions for outdoor siting as the permit-free unit and

thus may conform to standards for aesthetics that are accepted for the SAWAP permit-

free designs. As the power level is in the competence of each Member State that could

form an adjunct national class to the EU-wide permit free SAWAP standard, if it

conforms to the Member State’s health and safety limits.

134 M. Rumney (2019), “5G safety, the myths, maths and medicine of RF safety”, Cambridge Wireless Journal,

Vol. 2, issue 4 (June), pp 10-17 - http://flickread.com/edition/html/5d0cb90aee811#10

135 ITU-T (2018), Recommendation K.52: “Guidance on complying with limits for human exposure to electromagnetic fields, Series K: Protection Against Interference” - https://www.itu.int/rec/T-REC-K.52-201801-I/en

136 ITU-T (2018), Recommendation K.70: “Mitigation techniques to limit human exposure to EMFs in the vicinity of radiocommunication stations” - https://www.itu.int/rec/T-REC-K.70-201801-I/en



It has been suggested by some industry organisations that higher power limits for

SAWAPs could be a useful way forward for two main reasons:

a) Better penetration of buildings from outdoor BTS, especially for ferro-concrete

structures

b) Greater range for outdoor users (this may include pedestrians and perhaps

moving vehicles, depending on handover). It might also include longer range IoT

applications.

The key question is which frequency would be used as this determines the range and so

the received power density. Higher frequencies have less range and greater attenuation

by walls as well as by foliage and rain. Such units would still need to be in compliance

with each Member State’s national RF EMF limit rules, and in conformity with the IEC's

installation principles that follow the ICNIRP limits. While 1999/519/EC defines the

ICNIRP specifications as the reference exposure limits, enforcement and assessment are

still left to each Member State’s competence. Member States must respect these ICNIRP

limits or give their reasons if they diverge from them. Under Article 58 of the EECC,

Member States must justify their national differences and take comments on board from

the other Member States about those differences, in accordance with the Transparency

Directive (EU) 2015/1535. As the current specification in the IEC 62232 standard may

be radically revised over 2019 and 2020, it is difficult to predict how viable this would be

as the future limits have not been published. Future European norms will follow an EU

transcription by CEPT/CENELEC of the impending IEC standards, primarily a revised IEC

62232 standard, currently being updated for 5G, with use-cases.

What is likely to change? The new ICNIRP recommendations now being developed will

encompass 5G development directions - propagation patterns with active antenna

systems that are coupled between handset and BTS plus new higher centimetric

frequencies. This was previewed in a presentation by ICNIRP’s chairman at an ANFR

seminar in April 2019: the current limits on whole-body SAR for the general public are

expected to be extended up to 300 GHz. A new approach to exposure measurement

above 6 GHz may be proposed,137 while measurement protocols below 6 GHz might be

amended. Introduction of a new compliance approach is expected for steerable beams at

all frequencies from sub 6 GHz to the centimetric bands in updates to IEC 62232. A first

consolidated committee draft is expected for December 2019 with a further edition and a

technical freeze in December 2020 for a new edition to be published in 2021.138

6.5 Physical Size for a Standalone Outdoor SAWAP Unit

The enclosure shell should be able to encase the main components of a SAWAP base

station which can be expected to include:

• Antenna array and drive circuits

• RF processor and memory

• SAWAP management functions processor and storage

• Cooling system

137 ANFR website, posted May 2019, accessed 19 July 2019.

138 C. Grangeat (2019), “On the Road to 5G, Nokia, Use Cases, Technology and EMF Standardisation”, 17 April, from the ANFR website, downloaded 19 July 2019.



• Power supply

• Cabling connections and support for backhaul, power supply and earthing

• Fixing brackets

• (Optional:) edge processor and local storage for content

The dimensions have been defined in litres as this gives the most flexibility for exterior

design. We have been advised by industry representatives that a volume range of 20-30

litres (20,000-30,000 cm3) is sufficient for the SAWAP’s component PCBs. In a

rectangular form, it can house an industry standard rack (19 inch, 48.26cm width, with

20 cm length and depth of 20 cm or 19 inch, 48.26 cm width, with 24.5 cm length and

depth of 24.5 cm respectively) to contain the main component boards.

A possible layout is depicted diagrammatically in Figure 6.1. An indoor femtocell might

be a smaller version of the same components with total transmitted power suitable for

short-range, indoor use and perhaps with multiple radio air interfaces.

Figure 6.1. Outdoor to indoor via beam connection from external SAWAP

1Simon Forge SCF ASSOCIATES Ltd all rights reserved 2018

Through

wall cabling

External

Facing

MIMO

Antenna

array

Enclosure shell

(-front face transparent to

RF emissions).

May be surplus to needs

if unit sited inside street

furniture

MIMO

Active

Array

AntennaRF

processor

Edge server

& storage

Outdoor SAWAP unit in, or on, street furniture

Power supply

& cooling

Backhaul

& power

cabling

Femto cell–like

indoor SAWAP hub

- wall transceiver

BTS unit with its

DC power supply

5G NR

Air interface

plus Wi-Fi &

Bluetooth

Source: SCF Associates Ltd.

6.6 Aesthetics: SAWAP Integration with the Visual Environment

There is a need to encourage, through various instruments, the rollout of dense

networks of SAWAPs in a way that is aesthetically acceptable to the public. It should be

based on the discussion in the relevant section of Chapter 5, aiming to satisfy aesthetic

requirements and the approvals process for visual impact acceptance.

Installation principles

The following principles are adapted from the Código de Buenas Prácticas para la

Instalación de Infraestructuras de Telefonía Móvil [Code of Best Practices for the



Installation of Mobile Telephone Infrastructures]139 drafted by Spain’s Sectoral

Commission for the Deployment of Radiocommunication Infrastructure (see Appendix D

for more information):

Box 6.1. Installation Principles for SAWAPs to Assure Minimum Standards of Aesthetics

1. As a general rule – especially in urban areas - before deploying equipment housings of

standard design that would be visible to the public, other spaces should be considered,

including pre-existing enclosures that are capable of housing and hiding the equipment

essential for SAWAP operation.

2. Equipment housings should have the smallest dimensions that can contain the equipment

needed to operate the SAWAP, i.e. 20-30 litres. If operators foresee that the site might be

shared with other networks, the equipment housing may have somewhat larger dimensions to

avoid the need to install additional housings in close proximity later, while always remaining

within the specified limit. Site sharing can, in some cases, solve specific deployment problems

and reduce the visual impact of radiocommunication infrastructures.

3. In urban areas, mount SAWAP antennas on the facades of buildings or existing street furniture

whenever that is technically feasible, using a radome (an enclosure permeable to

electromagnetic waves), designed to match the surroundings, to cover the antenna, or

another discrete arrangement, where possible.

4. For roof installations in urban areas, place SAWAP equipment and its housing in locations that

are the least visible to observers at street level. New installations should be covered,

emulating as far as possible architectural structures like those located nearby (chimneys,

water tanks, an upward extension of a building corner, etc.). In case the installation of a

radome is not technically feasible, masts should be painted a colour that best suits the

environment.

5. The height of the antenna support should be the minimum needed to overcome obstacles in

the immediate environment for adequate radio signal propagation.

6. As a general rule, outdoor equipment housings should have an exterior finish consistent in colour with their surroundings. The same colour or colours should be applied to connectors, brackets and cables attached to the enclosure as for the enclosure itself, so that the total visual effect is consistent and homogeneous.

7. Cabling should not be apparent, being concealed as much as possible.

6.7 Limits on Permit Exemption

A SAWAP with a permit free status would still be subject to each Member State’s national

laws, restrictions and permits. This section examines the kinds of permits from which

SAWAPs would not be exempted.

It should be emphasised in the implementing act that the SAWAP specification exempted

from local planning permission will still be subject to national laws, with obligations and

conditions perhaps requiring permissions supplementary to basic planning permission.

These permits are largely for outdoor installations of any type in a public space. But in

some situations, they also apply to indoor electrical equipment. Naturally they vary

significantly by Member State and may include:

139 Comisión Sectorial para el Despliegue de Infraestructuras de Radiocomunicación (2005) - http://www.lineaverdeestepona.com/documentacion/antenas/Codigo_Buenas_Practicas.pdf



National RF exposure limits for protection of public health in a public space and in

private working occupational and residential spaces (each of these may be

different)

Power supply presence and connection permission (e.g. Italy)

Approval for compliance with local wiring regulations (e.g. Germany, France),

both outdoors and indoors and for consumer appliances (e.g. AFNOR in France) –

applies in most MS

Physical construction of the SAWAP itself for health and safety in public areas

(most MS) and in the home (consumer protection) for all MS

Attachment of equipment and physical support structures in public areas to

prevent dangerous installations - applies in all MS

Specific laws on fixing and siting equipment on roofs and walls – varies by MS

Access, sharing and siting inside street furniture according to local laws including

health and safety (e.g. earthing and electrical wiring in a public space) - varies by

MS, and possibly by municipality, province, etc

Access to ducts and wayleaves and sharing according to local laws – varies by

MS, and possibly by municipality, province and utility, if sharing

Health and safety regulations relating to the siting of microwave installations for

line-of sight backhaul – e.g. not across a school yard – varies by MS

Restrictive regulations at sites of national and cultural significance, or where

additional health and safety considerations apply – e.g. schools and hospitals -

varies by MS

Restrictive regulations on antenna – siting, size, height above ground, weight,

colour and visual impact – varies by MS (e.g. see Ireland)

The implementing act could refer to these powers on local permissions and conditions as

still requiring approvals and possibly permits.

Note that using these national laws it may be possible to apply less restrictive conditions

at national level to SAWAPs with a different specification to that of the EU SAWAP and so

exempt additional types of SAWAP from planning permission.

It may necessary to revisit the implementing act periodically in the light of

issues/problems arising from SAWAP deployment, as it is impossible to anticipate all

issues in advance. Hence, the implementing act should refer to the flexibility necessary

for expected updates (e.g. through delegated acts) to provide future proofing. This will

be especially important for citation of new accepted standards at EU level such as the

revised ICNIRP and IEC guidelines.



7. Additional Recommendations Beyond the

Implementing Act

This chapter describes additional aspects discussed in the study as being important for

Member States and the Commission to consider in the context of an EU light deployment

regime but which fall outside the scope of an implementing act.

The Commission services may decide whether to address these aspects, detailed below,

and how, either in some published form (e.g. a Staff Working Document for the guidance

of the Member States) – or perhaps by amending Article 57 (as we were asked to

consider).

From the study’s findings in the previous chapters, eight areas stand out for the support

of the EU’s SAWAP ecosystem that cannot be part of the implementing act. They are

nevertheless likely to need the Commission’s attention to accelerate deployment. The

form of their implementation is not defined but left open for the Commission’s services

to decide:

1. A form of technical type-approval of SAWAPs to facilitate rollout

2. Notification of site installations

3. Geolocation databases for SAWAP deployments, especially in dense urban

settings

4. The role of the Member States in monitoring RF limits and their enforcement

5. Automated monitoring systems for ongoing checking of the RF environment

6. Further research and development projects urgently required

7. Training campaigns for installation – and employment opportunities

8. Cybersecurity for SAWAPs – the threat of rogue small cells

7.1 Technical Type-Approval to Accelerate Network Rollout

The Need for Type-Approval

SAWAP type-approval for accelerating rollout falls outside the implementing act but will

be important, given the large number of access points to be installed – as with Wi-Fi,

where EU technical standards, recognised by all Member States, enable a conforming

hub to be sold and used across the EU. It avoids individual technical approvals by each

MS.

In this technical authorisation process, SAWAP units should conform to the simple

specification parameters outlined in Chapter 5, designed to define them in a minimal but

standard way. However, that requires verification. Type-approvals are the normal

prerequisite for such radio equipment to be placed on the EU market.

Type-approval is already the norm for those categories of radio equipment governed by

the Radio Equipment Directive (RED). A section on SAWAPs could be added to the EU’s

RED Guide,140 as well as the specific manuals for rollout on aesthetics mentioned in the

section above, or an additional regulatory guide which could point to the RED Guide (see

140 Guide to the Radio Equipment Directive 2014/53/EU, Version of 19 December 2018 - https://ec.europa.eu/docsroom/documents/33162/attachments/1/translations/en/renditions/native



specifically 1.2.3 Agreements on Conformity Assessment and Acceptance (ACAAs) and

1.6.3.11 Fixed Installations).

The RED’s Agreements on conformity assessment and acceptance of industrial products

are also intended to be established between the EU and the government of EU neighbour

states (Chapter 9.1 of the Blue Guide), which will be important for exports of SAWAPs.

The Process

The process would follow that of the RED with manufacturers assessing and declaring

compliance and successful application of EU technical standards, as well as specialist

laboratories that can test units for conformance to SAWAP specifications in size and

emitted power. The process is fairly straightforward.

There is already an organisation of approved testing laboratories (‘notified bodies’) and

national authorisers of such bodies (‘notifying administrations’) as well as national

monitoring enforcement bodies (‘market surveillance’ organisations) for radio equipment

placed on the EU market.

This would be the most efficient approach to approvals for SAWAP units: using existing

instruments for testing radio equipment before it enters the Single Market.

7.2 The Need for Notification

The concept of permit-free SAWAPs to enable rapid rollout envisages deployment of

dense small cell networks. These kinds of networks will be present across the built

environment in their thousands if their role as the local loop infrastructure for 5G

broadband succeeds. Such deployments will require four major assets:

Physical locations – sites that can host the unit either exposed outdoors, or inside

street furniture or indoors

Services connection – AC power and backhaul – either cabling or line-of-sight

microwave to the site

Connectivity to end-users with coverage for nomadic access

Respect for limits on aggregated RF EMF transmissions.

In these conditions knowing where the SAWAPs are sited is essential, especially if health

and safety laws with their RF EMF limits are to be met, and the logistics of rollout

managed, for three groups of users:

MNOs – to understand what sites are taken, and the connecting services locally

accessible with ducts and wayleaves, and whether they are taken, available or

shareable

Local authorities – who will wish to know the infrastructure details to manage the

built environment, including information vital for PPDR services and for protected

sites (historic interest, natural beauty areas, schools, hospitals, etc.)

Utilities – those must supply power and those that may share backhaul ducts and

wayleaves – water, gas, electricity and public transport.

Importantly, notification can also show the existing coverage, in terms of the RF EMF

levels and frequencies. In consequence, the impacts of adding another transmitter to the



site can be estimated as well as the potential for overlap and interference if new small

cell sites are activated.

The Notification Process – What it Entails and How it Would be Used

As Table 2.6 shows, notifications are already accepted in lieu of some permits for small

cells in the Czech Republic, Finland, France, Germany, Ireland, Italy, Spain, Sweden and

the United Kingdom. The process envisaged for SAWAPs involves a simple form stating:

The owner and operators

Where located geographically

Backhaul route and source of power supplies used

Measured RF EMF levels after installation

The notification data would be used by:

Other operators and installers when siting SAWAPs, including searches for

shareable sites

Local authorities to manage their built environment and contract street

furniture in their remit (e.g. lampposts)

Utilities who wish to share buried assets – e.g. host small cells inside drain

covers and supply ducts and pipes for cable runs

Two key national databases would be involved in notification:

Geographic coverage of RF EMF with signal levels and frequencies

Geographic mapping of buried services for national and local/municipal

reporting

7.3 Location Databases for Planning SAWAP Deployment

As mentioned above, 5G deployment is a major construction and logistics venture. There

is thus a need to log and map the dense rollout of SAWAPs in their thousands and

eventually millions. That implies the set-up of suitable databases to plan deployments

and then manage the built environment safely and efficiently.

Their role is to help to reduce the installations costs, which the stakeholder workshop

and other research highlighted as being the main cost centre of small cell rollout –

usually more, and perhaps far more – than the SAWAP hardware itself. The databases

would support each MS in managing their 5G rollouts.

Responsibility for the data and databases should be shared between the MS and EU

together, with the EC providing guidance. Mapping would only be useful if it offers

access to all approved stakeholder entities – installers, MNOs, local authorities, national

ministries, utilities, etc.

Building these databases would rely on the SAWAP notifications to assess and monitor

existing sites with the coverage and aggregated signal levels –making them essential to

manage deployments in dense urban environments for both RF EMF and electrical safety.

The real driver is knowledge of backhaul routing which sets bandwidth - and for power

supplies which set the viability of each site and the difficulty of cabling. This measure

would provide support for implementation of databases to:



Record SAWAP location and map the RF coverage of SAWAP deployments,

Map each SAWAP connectivity route for power supplies and backhaul. That

would be stored, in graphical form preferably, in a buried services database

which would be coupled with a geospatial street furniture database to show

both buried cable routes and surface level and above-surface street furniture

and cabling (designed to be especially useful for urban planning).

Ducts, cableways, wayleaves and pipe work for utilities would also be shown.

Existing communication services for fibre optic broadband, xDSL and other

copper services could also be shown on the same geospatial layouts together

with the mobile cellular macrocell sites, their backhaul routes and power supply

runs.

Such practices are not new but are now being implemented nationally in several MS.

Cybersecurity protection of these databases would be necessary, as they provide a map

of the critical 5G infrastructure. Thus, controls will be essential to restrict access to bona

fide users.

7.4 The Responsibility of Member States for RF EMF limits

Member States will continue to be responsible for enforcing the RF EMF limits they

impose for SAWAPs. This is foreseen in the division of competences embodied in the

EECC.

Dense networks of small cells of the SAWAP type will multiply the problems and

administrative efforts needed. Below we suggest several supporting technologies for this

task but the overall responsibility lies with the MS and their various administrations

locally and centrally to implement and operate them.

Operator/site-owner/regulator responsibilities for monitoring and enforcing RF limits

regularly and frequently, particularly the aggregate fields, need to be reinforced if they

are not already appropriate to the task. For standalone private 5G networks inside

industrial plants, offices and private/public spaces (such as shopping malls), the

responsibilities for verifying the private networks' conformance over time may need to

be considered and possibly reinforced.

This Member State’s role is thus likely to require action plans for enforcement, which

could be centrally orchestrated via the NRA, with possible specialised testing services

who take over the task but also with the agreement and participation of local authorities

as appropriate to the MS. Enforcement methods will rely on effective detection and

measurement methods.

7.5 Automated Monitoring Systems for the RF EMF Environment

The MS will need a low-cost geographically ubiquitous method of gaining country-wide

feedback on signal levels within the SAWAPs’ RF fields for monitoring and enforcement

purposes. The costs of a dedicated field measurement system, based on a nationwide

monitoring network, could be substantial.

One approach, akin to an IoT sensor network, could be to use feedback from ordinary

users’ handsets. Today’s handsets automatically measure signals levels continuously.

That data could be fed back to a third party acting to monitor RF levels continually - and



to the MNOs if required. 5G handsets may not be available today to do that but it would

fairly straightforward to add an app that measures signal strength and reports it.

Thus, the MS can each use crowd sourcing with volunteer handsets that record signal

levels and send back data to a central database, to build a map of the RF EMF levels as

observed by the user. The users would have to have a guarantee of anonymity so there

is no invasion of privacy by tracking an individual. Such a scheme would act 24h x 7. It

would only need to communicate low volume, low speed data at regular intervals e.g.

every 10 minutes or every hour. Moreover, it can send back peak values instantly if a

major anomaly is detected – be it too high or too weak.

Such field measurement would be the actual strength experienced and so would

measure the aggregated field level at each point. That would reveal just how the

declared notifications add up. Such readings for a given point can be compared over

time and against the original notifications. Consequently, it is possible to see

immediately if an undeclared SAWAP suddenly comes into operation – either by mistake,

or if added as a rogue small cell with malicious intent. That could offer useful

cybersecurity intelligence.

Such a scheme may be organised at EU or at MS level. It could recompense its

volunteers with some form of monetary or in-kind reward (e.g. data allowances). MNOs

would tend to support it as makes 5G network operation simpler and can report outages.

7.6 R&D on RF EMF Exposure and Measurement

There is clearly a need for more understanding of the propagation patterns of 5G

technology in different environments, especially the beamforming multi-user fields with

aggregation and closed loop interactions across the spectrum, from under 600 MHz to

over 30 GHz.

Enquiries on current EU R&D in the subject area in late August 2019 with the DG CNCT

5G Networking Unit confirmed that there is no recent study or ongoing EU research

project directly addressing the health impact and bioeffects of mmWave frequencies and

the SAR levels of AAS and beam formed emissions, particularly with aggregated multiple

RF EMF sources.

The Commission’s Scientific Committee on Health, Environmental and Emerging Risks

(SCHEER) has a standing mandate to provide an independent update of the scientific

evidence available, including the assessment of health risks that may be associated with

EMF exposure. This Committee’s most recent opinion was in March 2015,141 the last of

five relevant opinions that so far have not provided any scientific justification to revise

the limits set by the Council Recommendation of 1999. The updates have not covered

the latest 5G technology emerging today.

The only other initiative in the subject area is the ongoing revision of the international

limits by ICNIRP, expected to be adopted by the end of 2019, or after. That could take

into account any additional evidence regarding the use of mmWave spectrum.

141 https://ec.europa.eu/health/sites/health/files/scientific_committees/emerging/docs/scenihr_o_041.pdf



Thus, further efforts are needed on accurate models of field propagation, medically

significant RF affects and measurement methods. Consequently, there is a requirement

for the EC to sponsor a crash programme of R&D in three areas:

1. New mathematical models for the 5G RF propagation patterns beyond the

analytics used in the mobile industry today (some of which date back to the

1940s).

2. The second R&D task, based on the new propagation models, would be to perfect

field measurement methods for MIMO and beamforming active antenna. They

should encompass the propagation interactions of small cells and handsets across

all the frequency ranges involved, from below 700 MHz142 to above 30 GHz.

Measurement methods should be for practical application of 5G technologies in

the field every day, not just laboratory simulation. They would examine

compliance with the ICNIRP set limits for SAR or other exposure metrics.

3. Third, medical research into the effects of these RF emissions, oriented to the

development of a next generation of standards (since 3GPP does not have the

competence to examine bioeffects and ETSI, CEPT and CENELEC do not have

medical expertise either). That leaves the major university and medical research

institutes and groups possibly advised by SCENIHR and EURAMET, or under the

DG JRC, following the next Digital Europe programme. This initiative would

examine the impacts on human tissue and metabolic functioning of RF fields from

the closed loop interactions of 5G BTS and handsets, across the frequency ranges

allocated for mobile telephony.

The aim of this fundamental research would be to verify the ICNIRP limits for 5G

technologies and to consider if further European and eventually international standards

for safe emission levels are necessary.

Using the results of these research programmes, an EU standards initiative could evolve,

perhaps via a mandate to CENELEC, CEPT and ETSI, to produce such a norm. It would

be also based on ETSI interaction with the other relevant SDOs including 3GPP, the IEC’s

TC-106 working group and relevant ITU standards groups.

7.7 Training Programmes to Support Installation

One further practical issue comes from the research into 5G in China: there is a need to

ramp up the training of SAWAP installers. The current shortage of such personnel puts a

brake on the pace of rollout.

Training for installers on a large scale is thus essential. This would also support new EU

employment opportunities, enhance technology-based skillsets and promote the growth

of a SAWAP ecosystem.

Large scale training across the EU MS would involve:

An awareness campaign and recruitment

Publication of manuals and teaching materials, with best practice guidelines and

examples that include planning, technical requirements and relevant legislation

for installation

142 Current rollouts of sub 1Ghz 5G networks are being proposed by T-Mobile in the USA

and in South East Asian countries for spectrum auctions in 2020.



A scheme to “train the trainer”

The set-up of training courses

The establishment of a certified installer scheme would also be a first step, with an EU-

wide certification perhaps based on an EU-wide installation qualification.

Public Participation

There may be significant public relations issues impacting small cell and 5G deployment

unless public concerns are taken seriously. Resistance to SAWAP rollouts has already

been reported by operators, installers and street furniture owner/operators who host

small cells. To remedy this, careful preparation of information and guidelines should be

considered, including:

Publicity/information campaigns that are transparent, scientifically well-grounded

and readily understood by non-specialists.

Catalogues of already approved designs for SAWAP enclosures for deployment in

public outdoor and indoor spaces that are harmonious with their surroundings

and that minimise visual clutter.

Best Practices Guides – support for publication of practical installation and

aesthetics guides for local authorities and installers, best practice examples and

technical manuals.

Design concours for publicity and to involve the public in approvals.

7.8 Cybersecurity for SAWAPs

SAWAP deployments will be in dense configurations, especially across urban settings. In

contrast to macrocells – located on a secure site owned by a tower operator or MNO -

SAWAP deployments will have low physical security. SAWAP units can be located on the

side of a wall, within office buildings and malls, public venues such as railway stations

and indoors in a customer’s home. Thus, many of them will be in exposed locations,

accessible to potentially malevolent hackers and vandals. That can pose a security risk if

control of the small cell is taken over physically or by cyberattack. The physical

introduction of malware or unauthorised hardware are additional foreseeable risks

In the USA, the NSA has been examining the expected phenomena of rogue 5G small

cells since 2016143 In March 2019 the European Commission issued a Recommendation

on Cybersecurity of 5G networks, calling on Member States to complete national risk

assessments, review national measures, work together on a coordinated EU-level risk

assessment and produce a common toolbox of mitigating measures.144 More recently, an

EU coordinated risk assessment of the cybersecurity of 5G networks was published.145

143 J.J. Uher, et al. (2017), "Investigating End-to-End Security in 5G Capabilities and IoT Extensions", NSA, The Next Wave, Vol. 4 No. 21 -https://www.nsa.gov/Portals/70/documents/resources/everyone/digital-media-center/publications/the-next-wave/TNW-21-4.pdf.

144 https://ec.europa.eu/newsroom/dae/document.cfm?doc_id=58154

145 https://ec.europa.eu/newsroom/dae/document.cfm?doc_id=62132



Access to ports and debugging interfaces all offer potential admittance points for

unauthorised access to the SAWAP software and firmware. The small cell may contain a

reconfigurable radio system (RRS) that could be tampered with by introducing software

and firmware to alter the frequency bands used and the entities corresponded with,

directing users to malicious websites. Subscriber communications could be monitored

and recorded, intentionally corrupted data could be fed in, credential and identity theft

perpetrated, etc.

As entry points into the 5G core network, it is crucial that the network authenticates the

SAWAP appropriately. This is a similar problem to verification of user handsets. In 5G

networks (as in LTE) the SAWAP should first correspond with some form of

authenticating security gateway. A problem for dense 5G deployments is that this may

add delay and lengthen latency. Importantly it also adds a point of vulnerability,

depending on the gateway’s own protection in terms of its physical location and its

counterattack configuration. After authentication, the SAWAP may be allotted operating

parameter values (e.g. its frequency assignments) by the operational support system

(OSS). Note that the authenticating process may occur in the street, shopping mall or in

a customer’s home so suitable encryption of the process is obligatory.



Bibliography

EU Documents

BEREC (2019), “Common Position on Mobile Infrastructure Sharing,” BoR (19) 110 -

https://berec.europa.eu/eng/document_register/subject_matter/berec/download/0/8605

-berec-common-position-on-infrastructure-_0.pdf

BEREC and RSPG (2017), “Joint Report on Facilitating Mobile Connectivity in ‘Challenge

Areas’,” BoR (17) 256 / RSPG18-001 –

https://berec.europa.eu/eng/document_register/subject_matter/berec/download/0/7574

-berec-and-rspg-joint-report-on-facilitat_0.pdf

M. Bucci (2002), “Report on mobile telephone base stations and local/regional

authorities,” Council of Europe, Explanatory Memorandum CG(8)12 Part II -

https://rm.coe.int/1680718fb7

CEPT (2018) “Roadmap for 5G” (rev. 2 March), ECC18(050) Annex 19 –

https://cept.org/Documents/wg-se/47513/se-19-009_cept-roadmap-5g-for-ecc

CEPT Report 67 (2018), “Report A: Review of the harmonised technical conditions

applicable to the 3.4-3.8 GHz ('3.6 GHz') frequency band” –

https://www.ecodocdb.dk/download/561367fd-1ac6/CEPT%20Report%2067.pdf

CEPT Report 68 (2018), “Report B: Harmonised technical conditions for the 24.25-27.5

GHz ('26 GHz') frequency band” - https://www.ecodocdb.dk/download/647092ab-

e807/CEPT%20Report%2068.pdf

P. Chadwick (2009), “The role of standards in product safety: products and equipment

emitting EMF” – CENELEC presentation for DG Health -

http://ec.europa.eu/health/ph_risk/documents/ev_20090211_co02_en.pdf

COCOM Working Group on 5G (2018), “Report on the exchange of Best Practices

concerning national broadband strategies and 5G ‘path-to-deployment’,” COCOM18-

06REV-2 –

Commission Staff Working Document (2014), Implementation of the EU regulatory

framework for electronic communications, SWD (2014)249 final -

http://ec.europa.eu/information_society/newsroom/cf/dae/document.cfm?doc_id=6473

Commission Staff Working Document (2015), Implementation of the EU regulatory

framework for electronic communication, SWD(2015)126 final -

https://ec.europa.eu/transparency/regdoc/rep/10102/2015/EN/10102-2015-126-EN-F1-

1.PDF

Commission Staff Working Document (2016), Connectivity for a Competitive Digital

Single Market - Towards a European Gigabit Society, SWD(2016)300 final,

COM(2016)587 final - https://ec.europa.eu/transparency/regdoc/rep/1/2016/EN/1-

2016-587-EN-F1-1.PDF

Congress of Local and Regional Authorities of Europe (2001) – “Recommendation 95

(2001) on mobile telephone base stations and local/regional authorities” -

https://books.google.com/books?id=eeYuizFtbYwC



“Directive 2014/61/EU of the European Parliament and of the Council of 15 May 2014 on

measures to reduce the cost of deploying high-speed electronic communications

networks” - https://eur-lex.europa.eu/legal-content/en/TXT/?uri=celex%3A32014L0061

“Directive 2014/53/EU of the European Parliament and of the Council of 16 April 2014 on

the harmonisation of the laws of the Member States relating to the making available on

the market of radio equipment” - https://eur-lex.europa.eu/legal-

content/EN/ALL/?uri=celex%3A32014L0053

ECC Report 203 (2013), “Least Restrictive Technical Conditions suitable for Mobile/Fixed

Communication Networks (MFCN), including IMT, in the frequency bands 3400-3600 MHz

and 3600-3800 MHz” – https://www.ecodocdb.dk/download/f5cd8793-

5692/ECCREP203.PDF

ECC Report 281 (2018), Analysis of the suitability of the regulatory technical conditions

for 5G MFCN operation in the 3400-3800 MHz band -

https://www.cept.org/files/9522/Draft%20ECC%20Report%20281%20PF_1.docx

EURAMET (2018), “EMF exposure compliance for 5G and IoT devices,” EMPIR Call 2018 -

https://msu.euramet.org/current_calls/pre_norm_2018/SRTs/SRT-n16.pdf

European Commission (2018), Annual Report On the Application of the Principles of

Subsidiarity and Proportionality, COM(2018) 490 final -

https://ec.europa.eu/info/sites/info/files/annual-report-2017-application-principles-

subsidiarity-proportionality.pdf

European Commission (2018), Event report: Study workshop on using mm-waves bands

for the deployment of the 5G ecosystem in the Union, IDATE and Plum Consulting, 30

May - https://ec.europa.eu/digital-single-market/en/news/study-workshop-using-mm-

waves-bands-deployment-5g-ecosystem-union

European Commission (2018), Guide to the Radio Equipment Directive 2014/53/EU,

Version of 19 December 2018 -

https://ec.europa.eu/docsroom/documents/33162/attachments/1/translations/en/renditi

ons/native

European Commission Staff Working Document (2018), Digital Economy and Society

Index (DESI) 2018, SWD(2018)198 final - http://edz.bib.uni-

mannheim.de/edz/pdf/swd/2018/swd-2018-0198-4-en.pdf

European Council (1999), “Recommendation of 12 July 1999 on the limitation of

exposure of the general public to electromagnetic fields (0 Hz to 300 GHz),”

1999/519/EC - https://publications.europa.eu/en/publication-detail/-

/publication/9509b04f-1df0-4221-bfa2-c7af77975556/language-en

European Parliament (2018), European Electronic Communications Code (recast), 14

November - http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-

//EP//TEXT+TA+P8-TA-2018-0453+0+DOC+XML+V0//EN

European Parliament Research Service (2019), “Briefing: Mobile phones and health:

where do we stand?” PE 635.598 (March) -

https://www.europarl.europa.eu/RegData/etudes/BRIE/2019/635598/EPRS_BRI%28201

9%29635598_EN.pdf



Radio Spectrum Policy Group (2017), “RSPG Second Opinion on 5G networks,” RSPG 18-

005 final (January) - https://circabc.europa.eu/sd/a/fe1a3338-b751-43e3-9ed8-

a5632f051d1f/RSPG18-005final-2nd_opinion_on_5G.pdf

Scientific Committee on Emerging and Newly Identified Health Risks (2015), Opinion on

Potential health effects of exposure to electromagnetic fields (EMF) -

https://ec.europa.eu/health/scientific_committees/emerging/docs/scenihr_o_041.pdf

Treaty on the Functioning of the European Union, Protocol No. 2: “On the Application of

the Principles of Subsidiarity and Proportionality,” - https://eur-lex.europa.eu/legal-

content/EN/TXT/HTML/?uri=CELEX:12012E/TXT

Standards Documents

3GPP (2018), Technical Report TR 37.977 V15.0.0: “Verification of radiated multi-

antenna reception performance of User Equipment (UE)” -

http://www.3gpp.org/ftp//Specs/archive/37_series/37.977/37977-f00.zip

3GPP (2018), Technical Report TR 38.810 V16.1.0: “NR; Study on test methods” -

http://www.3gpp.org/ftp//Specs/archive/38_series/38.810/38810-g10.zip

3GPP (2018), Technical Report TR 38.913 V15.0.0: “Study on Scenarios and

Requirements for Next Generation Access Technologies” -

http://www.3gpp.org/ftp//Specs/archive/38_series/38.913/38913-f00.zip

3GPP (2016) Technical Specification TS 36.886 V14.0.0 (2016), “Evolved Universal

Terrestrial Radio Access (E-UTRA); Band 41 High Power UE (HPUE)” -

http://www.3gpp.org/ftp/Specs/archive/36_series/36.886/36886-e00.zip

ETSI (2015), Group Specification GS mWT 002 V1.1.1: “millimetre Wave Transmission

(mWT); Applications and use cases of millimetre wave transmission” -

https://www.etsi.org/deliver/etsi_gs/mWT/001_099/002/01.01.01_60/gs_mWT002v010

101p.pdf

ETSI (2018), Technical Report TR 103 230 V1.1.1: “Fixed Radio Systems; Small cells

microwave backhauling” –

https://www.etsi.org/deliver/etsi_tr/103200_103299/103230/01.01.01_60/tr_103230v0

10101p.pdf

ETSI (2018), Technical Study TS 136 104 V15.3.0: “Evolved Universal Terrestrial Radio

Access (E-UTRA); Base Station (BS) radio transmission and reception (3GPP TS 36.104

version 15.3.0 Release 15)” -

https://www.etsi.org/deliver/etsi_ts/136100_136199/136104/15.03.00_60/ts_136104v

150300p.pdf

ETSI (2019), EN 301 489-50 V2.2.1: “ElectroMagnetic Compatibility (EMC) standard for

radio equipment and services; Part 50: Specific conditions for Cellular Communication

Base Station (BS), repeater and ancillary equipment; Harmonised Standard covering the

essential requirements of article 3.1(b) of Directive 2014/53/EU” -

https://www.etsi.org/deliver/etsi_en/301400_301499/30148950/02.02.01_60/en_3014

8950v020201p.pdf

International Commission on Non-Ionizing Radiation Protection (1998), “ICNIRP

Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic and Electromagentic



Fields (up to 300 GHz),” Health Physics, Vol. 74, No. 4, pages 494‐522 -

https://www.icnirp.org/cms/upload/publications/ICNIRPemfgdl.pdf

IEC (2017), “Determination of RF field strength, power density and SAR in the vicinity of

radiocommunication base stations for the purpose of evaluating human exposure,”

International Standard IEC 62232 (ed.2) - https://webstore.iec.ch/publication/28673

IEC (2019), “Case studies supporting IEC 62232 – Determination of RF field strength,

power density and SAR in the vicinity of radiocommunication base stations for the

purpose of evaluating human exposure, Technical Report TR 62669:2019 -

https://webstore.iec.ch/publication/62014

ITU Regional Initiative for Europe (2017), Report of the Expert Meeting “Electromagnetic

Field Level and 5G Roll-out,” Rome, Italy, November - https://www.itu.int/en/ITU-

D/Regional-

Presence/Europe/Documents/Events/2017/EMF/Expert%20Meeting%20ReportFinal.pdf

ITU-R (2017), Report P.2406-0: “Studies for short-path propagation data and models for

terrestrial radiocommunication systems in the frequency range 6 GHz to 100 GHz” –

https://www.itu.int/dms_pub/itu-r/opb/rep/R-REP-P.2406-2017-PDF-E.pdf

ITU-R, Working Party 5D (2018), “Liaison Statement to External Organisations and

Regional Organisations: Definition of and test methods for OTA [over the air] unwanted

emissions of IMT radio equipment,” Document 5D/TEMP/571(Rev.1) -

http://www.3gpp.org/ftp/TSG_RAN/TSG_RAN/TSGR_81/Docs/RP-181520.zip

ITU-T (2015), “Focus Group IMT-2020: Report on Standards Gap Analysis” -

https://www.itu.int/en/ITU-T/focusgroups/imt-2020/Documents/T13-SG13-151130-TD-

PLEN-0208!!MSW-E.docx

ITU-T (2017), K-series Recommendations – Supplement 9: “5G technology and human

exposure to RF EMF” - https://www.itu.int/rec/T-REC-K.Sup9-201711-I

ITU-T (2018), Recommendation K.52: “Guidance on complying with limits for human

exposure to electromagnetic fields” -

https://www.itu.int/rec/recommendation.asp?lang=en&parent=T-REC-K.52-201801-I

ITU-T (2018), Recommendation K.61: “Guidance on measurement and numerical

prediction of electromagnetic fields for compliance with human exposure limits for

telecommunication installations” –


ITU-T (2018), Recommendation K.100: “Measurement of radio frequency

electromagnetic fields to determine compliance with human exposure limits when a base

station is put into service” –


ITU-T (2019), K-series Recommendations – Supplement 16: “Electromagnetic field

compliance assessments for 5G wireless networks” - https://www.itu.int/rec/T-REC-

K.Sup16-201905-I/en

Key References and Expert Opinions

ANFR (2019), Colloque international sur la 5G et l’exposition du public aux ondes

électromagnétiques à l'ANFR, 30 April – https://www.anfr.fr/toutes-les-



actualites/actualites/colloque-international-sur-la-5g-et-lexposition-du-public-aux-

ondes-electromagnetiques-a-lanfr/

C. Blackman and S. Forge (2019), 5G Deployment: State of Play in Europe, USA and

Asia, ITRE Committee, European Parliament/DG Internal Policies, PE 631.060 (April) -

https://www.europarl.europa.eu/RegData/etudes/IDAN/2019/631060/IPOL_IDA%28201

9%29631060_EN.pdf

L. Chiaraviglio and G. Di Martino, “Planning 5G Networks under EMF Constraints: State

of the Art and Vision,” IEEE Access (August) -

https://ieeexplore.ieee.org/stamp/stamp.jsp?arnumber=8453791

A. Chobineh et al. (2018), “Statistical Model of the Human RF exposure in Small Cells

Environment” -

https://www.researchgate.net/publication/328781372_Statistical_model_of_the_human

_RF_exposure_in_Small_cells_environment

D. Colombi, B. Thors, and C. Törnevik (2015), “Implications of EMF Exposure Limits on

Output Power Levels for 5G Devices above 6 GHz,” IEEE Antennas and Wireless

Propagation Letters -

https://www.ericsson.com/assets/local/news/2015/11/implications-of-emf-exposure-

limits.pdf

European Commission, DG CNCT, (2016), Costing the new potential connectivity needs,

Final Report Analysys Mason, SMART 2015/0016 -

https://publications.europa.eu/en/publication-detail/-/publication/e81ae17f-9d27-4b68-

8560-7cd45dbe21d8

GSMA (2013), Base station planning permission in Europe 2013 -

http://www.gsma.com/publicpolicy/wp-

content/uploads/2013/05/GSMA_Base_Station_Planning_in_Europe-2013.pdf

W. Honcharenko (2019), “Sub-6 GHz mMIMO Base Stations Meet 5G’s Size and Weight

Challenges,” Microwave Journal, February –

http://www.microwavejournal.com/articles/31754-sub-6-ghz-mmimo-base-stations-

meet-5gs-size-and-weight-challenges

IDATE and Plum (2019), Study on using millimetre waves bands for the deployment of

the 5G ecosystem in the Union, Final Report, SMART 2017/0015

ITU (2017), Report of the Expert Meeting on Electromagnetic Field Level and 5G Rollout,

2-3 November, Rome - https://www.itu.int/en/ITU-D/Regional-

Presence/Europe/Documents/Events/2017/EMF/2017-12-

04%20Expert%20Meeting%20ReportFinal.pdf

D. Johnson (2018), “Test and Measurement Is a Major Hurdle for 5G,” IEEE Spectrum

(November), https://spectrum.ieee.org/tech-talk/telecom/wireless/test-equipment-a-

major-hurdle-for-5g

D. H. Kang et al. (2013), “High Capacity Indoor & Hotspot Wireless System in Shared

Spectrum - A Techno-Economic Analysis,” IEEE Communications Magazine, January -

https://people.kth.se/~sungkw/files/kang_sung_zander_commag_2013.pdf



M. Kottkamp and C. Rowell (2016), “Antenna Array Testing - Conducted and Over the

Air: The Way to 5G,” Rohde & Schwarz -

https://www.techonline.com/asset/download/4443243/tech-papers-download

LEXNET (2014), Deliverable D2.1: Current metrics for EMF exposure evaluation (v.4) -

http://www.lexnet.fr/fileadmin/user/Deliverables_P1/LEXNET_WP2_D2_1_Current_expo

sure_metrics_v4.0.pdf

D. Lopez-Perez et al. (2015) “Towards 1 Gbps/UE in Cellular Systems: Understanding

Ultra-Dense Small Cell Deployments,” arXiv:1503.03912v1 -

https://arxiv.org/pdf/1503.03912

M. Merlini (2017), “Addressing the Multi-Small Cell Challenge,” Small Cell Forum -

https://www.slideshare.net/SmallCellForum1/addressing-the-multismall-cell-challenge

E. Mutafungwa et al. (2018), “Dismantling Barriers to Hyperdense Network Deployments

for 5G: Study Perspectives from the Global5G.org Project,” WWRF40 meeting, Durban,

South Africa, May –

https://www.wwrf40.ch/tl_files/Themes/wwrf40/Presentations/Global5G_Small_Cells_St

udy_WWRF_31052018.pdf

S. Monahan (2017), “5G Asia: Small cells will support 4G continuity as well as 5G

innovation,” Small Cell Forum blog, 26 September -

https://www.smallcellforum.org/blog/5g-asia-small-cells-will-support-4g-continuity-well-

5g-innovation/

A. H. Naqvi and S. Lim (2018), “Review of Recent Phased Arrays for Millimeter-Wave

Wireless Communication,” Sensors, Vol. 18, No. 10 (September) -

https://www.mdpi.com/1424-8220/18/10/3194/pdf

A. Naehring (2019), “Over the Air Testing: Important Antenna Parameters, Testing

Methodologies and Standards,” Electronic Design Innovation Conference (EDICON China)

https://www.doc88.com/p-6724773669734.html

P.-Y. Potelle (2018), “Public acceptance to be one of the main challenges for 5G small

cells rollout,” Cullen International, 27 November – https://www.cullen-

international.com/product/documents/FLTEEP20180036

C. Roda and S. Perry (2013), “Mobile Phone Infrastructure Regulation in Europe:

Scientific Challenges and Human Rights Protection,” American University of Paris -

https://www.academia.edu/24818673/Mobile_phone_infrastructure_regulation_in_Europ

e_Scientific_challenges_and_human_rights_protection

M. Rumney (2019), “5G Safety: The Myths, Maths and Medicine,” Cambridge Wireless

Journal, Vol. 2, Issue 4 (June) - http://flickread.com/edition/html/5d0cb90aee811#4

M. A. Sahli et al. (2015), “Recent developments in EMF and SAR measuring techniques:

towards reliable assessment of exposure to electromagnetic fields” -

https://www.researchgate.net/publication/267424932

Small Cell Forum (2017), Small cell siting: regulatory and deployment considerations,

Small Cell Forum Document 190 - https://scf.io/en/get_email.php?doc=190.



Small Cell Forum (2017), “Small cell siting challenges and recommendations,” Document

195.10.01 - https://scf.io/en/documents/195_-

_Small_cell_siting_challenges_and_recommendations.php

R. Stam (2018), “Comparison of international policies on electromagnetic fields,”

Netherlands Ministry of Health - https://www.rivm.nl/sites/default/files/2018-

11/Comparison%20of%20international%20policies%20on%20electromagnetic%20fields

%202018.pdf

B. Thomas (2018), “5G Brings New RF Challenges for Handsets,” Microwave Journal,

October - http://www.microwavejournal.com/articles/31177-g-brings-new-rf-challenges-

for-handsets

C. Törnevik (2017), “Impact of EMF limits on 5G network roll-out,” ITU Workshop on 5G,

EMF & Health (Warsaw, December) – https://www.itu.int/en/ITU-T/Workshops-and-

Seminars/20171205/Documents/S3_Christer_Tornevik.pdf

C. Törnevik et al. (2017), “Time-averaged Realistic Maximum Power Levels for the

Assessment of Radio Frequency Exposure for 5G Radio Base Stations using Massive

MIMO,” IEEE Access, September –

https://www.researchgate.net/publication/319886731_Time-

averaged_Realistic_Maximum_Power_Levels_for_the_Assessment_of_Radio_Frequency_

Exposure_for_5G_Radio_Base_Stations_using_Massive_MIMO

B. Thors, B. Hansson and C. Törnevik (2009), “The generation of simple compliance

boundaries for mobile communication base station antennas using formulae for SAR

estimation,” Physics in Medicine & Biology, Vol. 54, No. 13 -

https://www.researchgate.net/publication/26297028_The_generation_of_simple_compli

ance_boundaries_for_mobile_communication_base_station_antennas_using_formulae_f

or_SAR_estimation

B. Thors, B. Hansson and C. Törnevik (2016), “Exposure to RF EMF from Array Antennas

in 5G Mobile Communication Equipment,” IEEE Access, January -

https://www.researchgate.net/publication/306266058_Exposure_to_RF_EMF_from_Arra

y_Antennas_in_5G_Mobile_Communication_Equipment

J.J. Uher, et al (2017) Investigating End-to-End Security in 5G Capabilities and IoT

Extensions, NSA The Next Wave, Vol 4 No 21, 2017 -

https://www.nsa.gov/Portals/70/documents/resources/everyone/digital-media-

center/publications/the-next-wave/TNW-21-4.pdf

M. J. van Wyk et al. (2018), “Measurement of EMF Exposure around small cell base

station sites,” Radiation Protection Dosimetry, ncy201 -

https://doi.org/10.1093/rpd/ncy201

Wireless Infrastructure Association (2016), “The Role of Street Furniture in Expanding

Mobile Broadband” - https://wia.org/resource-library/the-role-of-street-furniture-in-

expanding-mobile-broadband/

World Health Organization (2006), Framework for Developing Health-Based EMF

Standards - https://www.who.int/peh-emf/standards/EMF_standards_framework[1].pdf

World Health Organization (2013), Non-ionizing radiation, part 2: Radiofrequency

Electromagnetic Fields, IARC Monograph 102 on the evaluation of carcinogenic risks to

humans - https://monographs.iarc.fr/wp-content/uploads/2018/06/mono102.pdf

European Commission

Light deployment regime for small-area wireless access points

(SAWAPs)

Luxembourg, Publications Office of the European Union

2019 – 125 pages

ISBN: 978-92-76-13357-5

DOI: 10.2759/508915

Smart 2018-0017 Light Deployment of SAWAPs C

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DOI: 10.2759/508915 ISBN: 978-92-76-13357-5