Select Committee on Trade and Industry Minutes of Evidence

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 working.

  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 demand.

  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.


  2.1  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 deal.

  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 licences.

  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.


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 insensitively sited;

    (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 etc;

    (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 2001.

"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 issue—site sharing means larger mast structures with the resultant higher visual impact.

  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 environmental solution.

  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 more antennas.

"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 business?

  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 the controversy?

  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 authorities.

  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 issues.

Can a change in the planning regime address the controversy?

  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 can cause.

  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 following reasons.

    (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 research?

  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 controversy?

  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 MPs.

  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 UK economy.


  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

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2001
Prepared 3 April 2001