Memorandum submitted by Vodafone
Vodafone recognises that there is controversy
and public concern regarding the development of telecommunications
masts and is committed, along with the other mobile operators
in the UK, to address this concern and to deliver a new way of
The mobile industry cannot address the controversy
alone. Whilst the industry can show that it is jointly acting
responsibly, the UK Government (at both a national and local level)
needs to show leadership and provide clear and consistent policy
guidance on both telecommunications mast development and advice
in response to health concerns. This needs to involve all relevant
Government Departments, the local planning authorities and individual
MPs from all political parties.
An inconsistent approach to telecommunications
network development across England, Scotland, Wales and Northern
Ireland will only serve to fuel the controversy debate and will
inevitably lead to network development that favours those areas
that adopt less restrictive planning regimes.
The mobile sector brings many positive benefits
to the UK Economy and the response to the controversy needs to
be measured and balanced so not to unnecessarily hinder the operators'
ability to provide a service for which there is enormous public
The scale of the perceived impact in terms of
numbers of masts is sometimes grossly exaggerated and misinterpreted,
resulting in excessive reactions to all developments. Vodafone
recognises that it needs to continue to make information on its
industry and site selection process available to all stakeholders.
1.1 The Vodafone Group is one of the world's
leading providers of mobile telecommunication services and great
commercial successes of the UK. The Group now has interests in
25 countries outside of the UK (soon to be 29 with the completion
of deals in Mexico, Switzerland and Ireland and the award of a
licence in Albania). The number of subscribers connected to Vodafone's
cellular networks worldwide (on an equity-adjusted basis) currently
exceeds 78 million.
1.2 Vodafone continues to have the widest
roaming capability of the UK operators, with agreements in 122
countries and across 275 networks, giving nearly 173 million customers
access to its networks.
1.3 Vodafone's principal business in the
UK is the operation of its cellular networks. It currently provides
service to over 11 million customers in the UK through a network
of approximately 7,000 macro base stations. In the year to 31
March 2000, £523 million was spent on capital expenditure
enabling the company to maintain and improve overall network quality
through a period of significantly increasing demand. Vodafone
employs over 10,000 staff in the UK.
1.4 Customers are connected to Vodafone's
analogue and digital networks through service providers or retailers
who sell or rent handsets, provide billing and offer customer
support services. Vodafone in the UK has its own wholly owned
service provision companies with more than 350 retail outlets.
1.5 In April 2000 Vodafone was successful
in acquiring the largest UK third generation (3G) licence available
to an existing operator for £5.964 billion. In parallel with
the development of the 3G network, Vodafone is launching its GPRS
(General Packet Radio Service) offering in April 2001. GPRS provides
much higher speed date transmission and means that data can be
sent and received significantly faster than using the existing
mobile data services and offering performance comparable to fixed
telephone lines. The introduction of 3G will deliver customers
a new generation of services including full internet, video-conferencing
and many other mobile multimedia services.
2. THE MOBILE
2.1 The UK mobile industry is currently
recognised as one of the most advanced and sophisticated in Europe,
if not the world.
2.2 The use of mobile phones in the UK has
increased dramatically over recent years. In the quarter ended
31 December 2000, over 1.4 million customers joined the Vodafone
network and the total UK base for the four networks was over 40
million customers. This equates to a penetration figure of 67
per cent meaning around two out of three people in the UK now
own and use a mobile.
2.3 Competitiveness in mobile service provision
has resulted in significant customer benefits, namely falling
prices, greater choice and enhanced services. In a recent review
of the mobile sector, OFTEL concluded that it considered that
the UK consumer is, in many respects, currently getting a good
2.4 A recent NERA study commissioned by
the FEI found that the UK mobile industry annually contributes
some £5.3 billion to UK GDP, £1.3 billion to the UK
Exchequer in tax revenue and employs around 164,000 people directly
and indirectly across the country. The industry has also recently
contributed a one off payment of £22.5 billion for the 3G
2.5 The fundamental benefit of cellular
technology ie mobility, has revolutionised the way people lead
their working or personal lives providing them with the ability
to stay in touch whenever and wherever they are. Not only have
consumer customers and business people had their communications
options changed, but also staff in essential services, such as
doctors, nurses, and vets have had their working lives transformed
by the advent of the mobile phone. Vodafone alone typically carries
over 20,000 potentially life-saving, emergency (999) calls every
day. The part that the mobile operators play in society by, for
example, providing the infrastructure to make sure that these
emergency calls can be made is often forgotten.
2.6 To respond to the increasing demand
for both the volume of services, and the increasingly high expectations
for coverage of the networks, the UK mobile operators have to
invest heavily in network expansions.
2.7 If people want to be able to use their
mobile phones where they work, live and whilst travelling then
there have got to be radio base stations in those areas to carry
the calls. This does mean more radio base stations but only a
minority of these will require the erection of a mast.
3. THE CURRENT
What is the controversy?
3.1 In Vodaphone's opinion there are many
facets to the current controversy surrounding telecommunication
masts that are combining to create public concern.
3.2 The controversy about masts in general
is to some extent perpetuated by mystification surrounding the
technology and how it works, how many more radio base stations
are going to be built and the misplaced belief that all base stations
are lattice masts. The controversy is further fuelled by a lack
of clarity in the health advice emerging from central Government
and local Government. It is also due to a lack of trust in both
the industry and Government to recognise and respond to the public
concerns especially at a local level.
3.3 The controversy at any one particular
site is often due to varying degrees of concern on:
(a) a perception that a base station will
adversely affect the health of local residents;
(b) a feeling that a base station has been
(c) a perceived lack of empowerment and a
feeling that a base station has been imposed on local residents,
that they do not have any choice and were not consulted; and
(d) perception of multiple, uncoordinated
applications from different operators, when site sharing is perceived
to be the best solution.
3.4 Vodaphone finds that these factors can
often together create a general feeling of anxiety about a site
and a feeling amongst residents that "they just don't want
it". This can be despite Vodaphone demonstrating compliance
with radio frequency emissions guidelines and also endeavouring
to minimise the environmental impact and visual intrusion.
3.5 To add to this, the controversy surrounding
masts has become a political agenda item. Vodaphone would therefore
urge the Trade and Industry Select Committee, with its cross party
representation, to consider the damage that such party political
statements can do to concerted attempts to resolve the controversy.
What are the misconceptions that fuel this controversy?
"The mobile operators will need 100,000 new
masts for 3G"
3.6 It is important to point out that a
radio base station is not necessarily a mast. A mast is a free-standing
structure that supports antennas. The mast structure together
with the equipment cabin comprises a radio base station. Currently
approximately 65 per cent of all Vodafone radio base stations
are not masts/poles but are located on existing structures such
as buildings, electricity pylons, water towers etc. Therefore
whatever the number of new sites required, Vodafone believes that
at least 65 per cent will not be new masts/poles.
3.7 It is true that 3G will necessitate
an increased number of base stations due to the characteristics
of the technology, but by far the majority of these will be on
existing sites (buildings/poles and masts). This will reduce costs,
visual instrusion, and improve speed of deployment so as to bring
the benefits of the new technologies to the UK market ahead of
the rest of the world's major mobile markets.
3.8 As business and consumers products and
applications are forecast to demand ever higher data volumes being
available, so large quantities of that data will be transmitted
across mobile (3G) network. It is for this reason that the early
deployment of 3G is likely to be concentrated in the urban centres
and along principal road routes where Vodafone has the highest
concentration of sites on existing structures. If additional sites
are required they are likely to also be on buildings rather than
masts, providing coverage infill.
3.9 It is interesting to consider that there
are many other structures of similar dimensions to the industry's
15m masts, (including masts for purposes other than mobile operators,
street lighting, road signs, water towers and pylons for instance)
which do not create the same controversy and reaction with the
general public when erected. Perhaps enforcing on authorities
and utilities a mandatory availability of such structures to be
able to carry operators' antennas where appropriate, should be
demanded by Government to help to alleviate some of these issues
"The mobile operators don't share sites"
3.10 The short answer is that the mobile
operators DO share a substantial numbers of sites. Vodafone, for
example, has a total portfolio of 2,800 free-standing structures
and of these:
(a) 1,900 have rights to share with other
operators incorporated into the lease agreements;
(b) 1,800 are poles which were deployed to
minimise visual intrusion and aid integration into urban environments
in keeping with other existing structures such as street lighting
(c) one or more operators currently share
25 per cent of Vodafone's 1000 lattice masts; and
(d) 32 per cent of all Vodafone macro radio
base stations are on third party towers or masts.
3.11 Vodafone and the other mobile operators
have reached agreement on publishing details of their site sharing
statistics for public scrutiny on a quarterly basis.
3.12 The dichotomy that site sharing presents
though in terms of addressing public concern should also be highlighted.
On the one hand the industry is encouraged to site share to minimise
the number of new masts. At the same time the industry is also
encouraged to minimise the emission levels from radio base stations
in line with providing public reassurance. Unfortunately site
sharing cannot deliver both objectives simultaneously. This view
was recently supported by the French report from Zmirrou January
"If the mobile operators did share sites
we would not have this problem"
3.13 In Vodafone's opinion, and as alluded
to above, site sharing is not always necessarily the answer because,
for example, a shared site has to be "larger" and "bulkier"
to accommodate the additional equipment. There are no proven or
practical technical solutions to this issuesite sharing
means larger mast structures with the resultant higher visual
3.14 Vodafone believes that sharing an existing
structure or undertaking a joint development to accommodate two
or more operators is therefore only appropriate when the local
planning authority has been consulted and agrees that the location
is suitable to accommodate the higher mast that sharing is likely
to necessitate. This is also against an assessment that co-location
of two or more masts on the site would not be a more acceptable
3.15 There are also practical implications
with site sharing. The landlord, for example, must agree to the
increased height, increased traffic across their land and be convinced
that the new development will not interfere with their operational
use of the site. It must also be physically possible to acquire
sufficient land to accommodate the additional sharers equipment
cabin and the potentially larger structure required supporting
"The radio frequency emission levels from
mobile infrastructure are harmful"
3.16 The controversy surrounding radio base
station development has been fuelled most significantly in the
last two years by concern over radio frequency emission levels.
To the mobile industry this appears incongruous when viewed in
context with other emitting devices and systems such as broadcast
radio and TV, medical and factory equipment. These are all devices
that already exist and are accepted into our environment and everyday
lives. The answer may be that mobile telecoms radio base stations
are more recently erected and, because of the nature of cellular
networks, are much more likely to be located near to where people
live and work.
3.17 It is important to stress here the
conclusion of the Independent Expert Group on Mobile Phones that:
"We conclude that the balance of evidence
indicates that there is no general risk to the health of people
living near to base stations on the basis that exposures are expected
to be small fractions of guidelines".
3.18 The Stewart Inquiry Report also concluded
that public concern and anxiety has also led to an adverse impact
on the public's well-being as much as any direct health effects.
In Vodafone's opinion this has probably been fuelled by a feeling
of a lack of involvement in the decision making process in locating
radio base stations. This in turn has led to a feeling of outrage
and as a result other factors, such as these doubts about emissions,
have taken on a greater significance over and above visual intrusion
and environmental impact.
What is the impact of this controversy on Vodafone's
3.19 The very real and significant risk
on Vodafone's business of the current controversy surrounding
masts is that it is already dramatically slowing down deployment
of both the infrastructure to support the current second generation
of services and the preparation for the launch of the next third
generation services. This has the potential to significantly put
at risk the industry's ability to meet the obligations under the
new 3G licences recently issued by the Government (ie to reach
80 per cent of the UK population by 2007).
3.20 The greatest problems faced by Vodafone
at the current time are that:
(a) due to the lack of central Government
guidance, individual local authorities are putting in place moratoria
on the use of their buildings and land. This means more masts
are sometimes built in less environmentally acceptable locations
than if the original site was made available;
(b) an increasing number of local planning
authorities are making blanket refusals of applications stating
that they are waiting for clear Government guidance; and
(c) many authorities are insisting on information
with planning applications under GPDO and full planning that are
not a statutory requirement. This is information such as power
outputs and independent calculations of EMF levels. Whilst Vodafone
is happy to provide such information, the local planning authorities
do not always have the resources to interpret this information
but are sometimes, none the less, refusing to deal with applications
until they receive it.
3.21 In terms of the deployment of 3G, Vodafone
has verified (using its own business models) the DTI statement
that the loss in benefits to users of 3G services, as a result
of a one month delay in the implementation of 3G services, will
average about £100 million per annum over a 10 year period
at 2000 prices.
3.22 If the response to the current controversy
was, for example, to introduce full planning, this would cause
delays for all UK mobile operators including the new fifth operator.
We anticipate that this would have a detrimental effect on the
mobile industry generally and would threaten the ability of the
UK to be a leader and pioneer in 3G deployment in Europe. This
would be contrary to some of the UK Government's objectives. The
UK Online programme, for example, was launched by the Prime Minister,
Tony Blair MP, and has as one of its targets for the UK to be
the best place in the world for e commerce. Commenting on the
UK's achievements the Prime Minister said "we cannot afford
to slow down. Although the UK has surged forward and is leading
in some key areas, we still lag in others".
3.23 It is widely anticipated that more
people in the world will be accessing the internet from mobile
than fixed line by 2004. In the UK, we estimate 18 million customers
will be using their mobiles to access the internet. The United
States is currently behind the UK in the development of 3G and
has yet to schedule an auction date for 3G spectrum. As the founders
of the internet and with their current expertise, the US will
be able to capitalise on any delays in UK development and potentially
overtake the UK.
What are Vodafone and the industry doing to address
3.24 Vodafone believes that it has for many
years adopted best practice and has in many ways led the mobile
industry in working with local planning authorities and communities
to overcome objections to the siting of radio base stations.
3.25 Since 1994 Vodafone has offered to
hold consultation and pre-application discussions with all local,
metropolitan and unitary authorities. In 1995 Vodafone appointed
an Environmental and Planning Controller to liaise with local
planning authorities providing details of the company's network
requirements within each administrative area prior to the site
selection process commencing. In fact, as early as 1995 Vodafone
embarked on a programme of seminars to local planning authorities
aimed at improving planning officers' and members' understanding
of the telecommunications network development. This programme
continues to the present day and there are now seven such Environmental
and Planning Co-ordinators who each have a responsibility for
a particular region in the UK.
3.26 In 1994 Vodafone also published the
first edition of its Environmental Handbook (and the third edition
is to be published shortly). This document, which is publicly
available, sets out the criteria to be adopted by its acquisitions
personnel when selecting sites and their dealings with local planning
3.27 At the end of 1999 an EMF Advisory
Unit was created within Vodafone to co-ordinate and answer the
increasing amount of health and safety inquiries relating to radio
base stations. The unit is headed by a health physicist experienced
in the provision of advice detailing exposures to personnel from
electromagnetic emissions. Members of the EMF Advisory Unit frequently
meet with members of the public, local authorities and politicians
to discuss and address their concerns about base station health
and safety issues.
3.28 Also in recognition of growing public
concern, Vodafone's build guidelines for new radio base stations
in the UK were altered in July 1999. This was to ensure that new
base stations complied with the European Union Recommendation
(99/519/EC) on the limitation of exposure of the general public
to electromagnetic fields 0Hz-300GHz. These are more stringent
guidelines than those recommended by the NRPB and surveys on installations
built since this date have shown that they are actually typically
hundreds, or even thousands, of times below the EU Recommendations.
3.29 The industry as a whole is also taking
the whole issue of public concern over mast planning very seriously.
As a result we have jointly strongly supported the recommendations
in the Stewart Inquiry Report that seek to improve communication
and understanding between mobile operators, local planning authorities
and communities. The mobile operators have together publicly committed
to delivering new ways of working. They include commitments to
develop: clear standards and procedures to deliver significantly
improved consultation with local communities; a cross industry
agreement on mast sharing; providing certificates of compliance
with safety guidelines and financially supporting the Government's
independent research programme on mobile telecommunication health
Can a change in the planning regime address the
3.30 Vodafone acknowledges the findings
of the Stewart Report in respect of the lack of involvement by
the general public in the decision making process for planning
applications for radio base stations and the anxiety that this
3.31 Vodafone however strongly believes
that the recommendation of the Stewart Inquiry Report to consider
a move to full planning, as a requirement for all network development,
will fail to be effective in addressing public concerns for the
(a) the consultation process within the full
planning system will not provide the level of community consultation
that the public itself believes is necessary and to which the
Stewart Inquiry Report referred. Vodafone believes that the public
will continue to be concerned and not reassured if local planning
authorities become, by default, both the "owner" of
the issue and of the consultation process. It could even lead
to a greater feeling of outrage;
(b) whilst additional consultation and information
provision is essential to addressing public concern, this should
be outside the statutory planning process and the responsibility
of the operator;
(c) many local planning authorities are,
in Vodafone's experience already too under resourced to deal with
the current rollout procedures for radio base stations and Vodafone's
attempts to engage in pre-application discussions. If the Stewart
Report recommendation for full planning was to be adopted the
effect would be that many authorities would have to defer decisions
to afford them the time to process the application. This would
not enable Vodafone to plan the deployment of its infrastructure
with any certainty and would severely impact the industry's ability
to meet demand; and
(d) whilst local authorities and elected
representatives may exercise their judgement regarding the approval
of a full planning application, the operators would be entitled
to appeal against a decision through the normal processes. In
such circumstances the DETR Appeals Inspector can only execute
judgement within the proscribed guidelines, and inevitably a large
percentage of appeals will, after an extended period for the process,
probably be decided in the operator's favour. This circumstance
would result in dissatisfaction amongst the public who will then
feel further outrage. It will also involve tying up scarce resources
from both local and central Government bodies, and create extensive
delays to the operator's building schedules.
3.32 It is not just Vodafone or indeed the
industry that holds these views and concerns with regards to the
suggestion that the introduction of full planning can resolve
the controversy. In a recent MORI survey, three out of five local
planners agreed that a move to full planning would not resolve
the public concern surrounding mast development.
3.33 It is for these reasons that Vodafone
and the mobile industry have together committed to make significant
improvements in the way that it interacts and consults with local
communities in the form of its "ten commitments".
Why can't the controversy be fully addressed by
3.34 Whilst Vodafone is happy to financially
support Government-led initiatives in relevant scientific research,
we believe that evaluations in a research project can clearly
never succeed in fully proving a negative statement.
3.35 Wht has become evident to Vodafone
over the last two years is that as a result of situations such
as the BSE issues, the general public will not be reassured by
scientific debate alone. This is why Vodafone believes that the
research in Risk Communication has established that the way to
provide effective reassurance is through dialogue, engagement
and transparency of the industry's activities.
3.36 It is for this reason that the mobile
industry has been fully co-operating with the Radiocommunications
Agency in compiling a publicly accessible database of all radio
base stations, their emission levels and relevant operator contact
details for further information.
3.37 Vodafone also welcomes the Radiocommunications
Agency audit of operator sites and will continue its co-operation
to provide reassurance to the public that Vodafone's sites are
being independently audited in line with the recommendations of
the Stewart Report.
What can the Government do to help resolve the
3.38 Vodafone, together with the other mobile
operators, believes that the key to addressing public concern
lies in improved dialogue with the community, based upon communication
and consultation and not through a move to full planning. The
Government should seek to help address public concern through
supporting the industry in the implementation of its new ways
of working and not through a move to full planning.
3.39 One critical factor to the success
of the industry's initiative with the introduction of its "ten
commitments" is outside of the operators' control. That is
the co-operation and involvement of the local planning authorities
in the consultation process, not only in terms of consultation
with the mobile operators but also with their local communities.
The Government must ensure that the resources and expertise required
within local planning authorities will be made available to facilitate
improved consultation and communication.
3.40 For this consultation to work however,
it needs to be set against a background of clear and consistent
policy guidance from Central Government on both telecommunications
mast development and advice in response to health concerns. This
will remove the current uncertainty and confusion within many
local authorities who are, as a result, invoking individual and
often contradictory advice and policy to their officers and communities
with respect to telecommunication mast development. The Government
needs to present clear and consistent policy guidance with regards
to telecommunications mast development and all related issues.
This must then be adhered to at a local Government level.
3.41 Vodafone would also welcome the Trade
and Industry Select Committee's thoughts on how to address the
problems that will and do arise as a result of "different"
advice being given by the devolved administrations and by particular
political parties. Despite best endeavours by the mobile operators,
the public controversy will continue as long as respected elected
political representatives continue to hold and give different
views on telecommunications mast development. The local MP, for
example, is very often involved in controversial sites and can
play a very important role in bringing the mobile operator and
local community closer together. The Government needs to recognise
the problem of conflicting policy advice be that from devolved
administrations, local Government political parties or even individual
3.42 Finally Vodafone would urge the Government
to continue to recognise and promote the contribution that the
UK mobile sector makes to consumers, business, society and the
4.1 Vodafone would welcome the opportunity
of working closely with both central and local Government and
the devolved administrations to finalise and implement the industry's
"ten commitments" to deliver new ways of working. By
working with Government and other stakeholders to establish new
methodologies and consultation processes the industry hopes to
provide the public with the reassurance they desire with regards
to telecommunication mast development. This, we hope, will go
some way towards addressing the current controversy and is critically
important since it will ensure the continued success and competitiveness
of the UK mobile industry and help the government meet its own
objectives of making Britain a leader in the communications industries.
9 March 2001