Memorandum submitted by BT Cellnet
Overwhelmingly enthusiastic demand from industry,
commerce, government and consumers has, within the last decade,
transformed the role and significance of the UK's cellular radio
assets. A useful support technology has become a vital component
in the nation's commercial and social infrastructure. This position
can only be reinforced by developments from evolving second-generation
and forthcoming third-generation networks, including always-available
data connections, higher data speeds and greater flexibility for
Continuing heavy investment by network operators
has democratised this crucial enabling technology. Services which,
some years ago, were effectively the preserve of the wealthy and
powerful in the most prosperous areas of the country are now almost
universally available and affordable. This is one "digital
divide" which was closed even before most people noticed
it was there.
Having been avoided in the context of today's
mobile voice and data services, it would be ironic if such a divide
were to become institutionalised in more advanced services. Any
measures which slow and limit investment in network infrastructure
must be considered in the light of the hidden costs they would
impose on the 70 per cent of the population who are now consumers
of existing services, and the potential future costs for "UK
PLC". This applies especially to less advantaged parts of
society as the natural progression of innovative new services
from "niche" to "mass-market" is inevitably
affected by delays in realising economies of scale and the physical
availability of networks.
Like industrial development, transport, energy
supply, housing and the availability of food and water supplies
in a modern society, effective communication requires infrastructure.
The provision of all socially beneficial infrastructure requires
trade-offs to be made between the benefits and the costs. It is
a fact of life that these costs invariably include a degree of
Throughout the modern world it is therefore
healthy and necessary for societies periodically to weigh the
balance between benefits and costs. The irony of anti-mast protestors
using their mobile phones to organise protests encapsulates the
dilemmas inherent in this debate.
Continuing growth in demand for services, and
the continuing availability of services to those who already rely
on them, can only be supported by continuing investment in network
infrastructure. The phones cannot work without the networks, and
the networks can only operate according to the laws of physics.
It is inherent to the operation of mass-market mobile phone networks
that they operate at high frequencies and short ranges, so that
the available spectrum can be re-used every few kilometres. Many
customers are therefore able to talk simultaneously using the
same frequency, without interfering with each other, across the
country. It follows that the base stations must necessarily be
very close to the customers they serve, otherwise power levels
would have to be radically increased, to levels more comparable
to broadcast TV and radio stations, thus increasing exposure to
RF, and the overall capacity of the networks would shrink to the
point that they were not practically usable.
As cellular radio has become a simple-to-use
mass-market service, its ubiquity has outstripped general understanding
of the technical principals by which its numerous benefits are
realised. In this, it is similar to most mass-market consumer
technologies. It is axiomatic that unkown and invisible forces
have great potential to provoke fear, and the industry should
perhaps address this by doing more to educate its customers and
the communities in which it works about the operating principles
of cellular networks. As the Stewart report points out, consultation
is key, yet consultation and consent can only be truly effective
when they are suitably informed.
BT believes that it would be most helpful for
the Government to show a lead in this, working with the industry
to open up an informed debate on the relative balances of risks
and rewards in this and other aspects of life in a modern industrialised
The need for continuing research into possible
health effects is unarguable, and BT believes that the scope of
research could beneficially be widened further by examining the
full spectrum of social, environmental impacts, enabling the whole
picture to be considered "in the round".
BT also believes that the best interests of
overall UK industrial and environmental policy would be supported
by stronger links and greater integration between the two bodies
of public policy. Both areas of policy are vital to the UK's future
and each has an indisputable impact on the other. The earlier
that environmental considerations are taken into account in the
forming of industrial policy, and industrial considerations taken
into account in the forming of environmental policy, the higher
the overall quality of the outcomes will be.
The industry in turn must, of course, delivery
consistently on its commitments, including those on local consultation
as well as its licence obligations to deliver widespread coverage
and adequate network capacity.
The BT Group is involved in the deployment and
use of wireless technologies in many different aspects of its
business. We therefore appreciate from a number of perspectives
the need to strike appropriate balances between consumer demand
for high quality services, and other stakeholder interests including
visual amenity and potential health concerns.
BT Cellnet, wholly owned by BT, provides cellular
network coverage to more than 11 million customers throughout
the UK, and is continually upgrading the network to increase capacity
and improve coverage quality. In addition to its significant investment
in first and second generation technology and services, BT has
invested more than £4 billion in a third generation (3G)
licence for the UK, and is currently planning its rollout of 3G
infrastructure and services.
BT is part of the consortium providing mobile
telecommunications to the Home Office for the emergency services
through its dedicated Airwave network, which needs to provide
comprehensive coverage. The service will enable the emergency
services to speak directly to each other without having their
calls managed by their control centre, saving valuable time in
major emergencies. This is vital in the event of a major incident
that affects more than one force, with significant benefits in
the potential to save lives. It is currently estimated that around
3,000 additional masts will be needed for this service over the
next four years.
BT, through its wholesale business, is a supplier
of infrastructure services, including cell sites and transmission,
to other operators and service providers. BT is exploring ways
of minimising the need for new ground-based masts, for example,
through an agreement with Crown Castle International to use up
to 4,000 of its operational buildings within BT's property portfolio
to site antenna.
We are also looking for ways to site micro and
pico cells to provide infrastructure services to othersfor
example we are trialling the siting of micro cells in the roofs
of certain types of BT payphones to further enhance GSM coverage
and are considering how micro or pico cells could best be situated
in or on other "street furniture" (see Annex A
for illustrative examples).
BT uses wireless technologies in its own fixed
PSTN network, to provide point to point services, so as to reach
areas where it would not be possible or cost-effective to lay
cable, to provide temporary services including disaster recovery
and to provide reliable fault-tolerant services for customers.
BT installs around 200 dish antennas, each month, using a combination
of new and established sites. These arrangements serve not only
BT's own network infrastructure but also infrastructure that BT
builds and provides for others.
BT has a further range of additional products
and services employing wireless technology, including pagers,
cordless and satellite phones.
3. MARKET DEMAND
Wireless communications are self evidently an
integral and vital part of modern society, At the end of 2000,
there were 41 million mobile phones connected to networks in the
UK. Based on independent forecasts by NERA, the number of mobile
devices is anticipated to grow to more than 70 million by 2010.
NERA estimated that the UK mobile phone industry (not counting
wider wireless technologies) generated directly and indirectly
£5.3 billion in contribution to GDP, and supported an estimated
164,000 jobs in 1999. NERA further estimated that over the next
10 years the mobile industry could be expected to generate a cumulative
total of £214 billion in contribution to GDP, supporting
519,000 jobs in 2010.
Wireless technology plays an important role
in both business and personal lives. As well as enabling conversations,
texting (SMS), mobile business, mobile internet, location based
services, and mobile commerce, mobile phones provide individuals
with the reassurance of improved safety and security, and peace
of mind for parents whose children are out and about. Wireless
technology also underpins the ubiquity of emergency services operations,
providing essential, lifesaving communications services. Growth
in mobile communicationsnotably enhanced, second generation
and third generation systemswill support a rapid move to
more capacity for the information era. The market will be extended
through higher quality voice services, higher speed data and multimedia
Mobile communications are an essential contribution
to the national economy and the competitive position of the UK.
By early summer 2002, a fifth of all voice and data minutes is
expected to be mobile and this figure is set to rise dramatically
The UK's leadership position in mobility and
e-commerce is dependent upon the continued investment in new technologies
and provision of the necessary supporting infrastructure. It is
simply not possible to have mobile phones and devices without
the network of base stations which enable them to work. Further
innovation in this area will underpin the UK's ability to compete
with others in developing the knowledge economy
4. THE NEXT
Third generation services will significantly
improve the speed of data transmission. In so doing, they will
encourage the mobile data market as well as providing additional
spectrum capacity for growth. 3G networks will improve voice quality,
"always-on" data services (such as fast internet access),
and roaming. In addition, enhanced data rates will facilitate
the provision of broadband data services over laptop-style devices
and future generations of mobile phones, such as video, music
and multi-media. There is a rich variety of possible applications,
ranging from entertainment (music, games, video) and information
(location based services, maps, guides, news), to personal financial
transactions (banking, shopping, broking) and improved communication
services (interest groups, video conferencing). Many as yet unimagined
new ideas will emerge as time progresses. Apart from the commercial
and lifestyle benefits, improved personal safety and security
opportunities will inevitably arise. The 3G licences awarded in
the UK contain an obligation from Government to cover the geography
in which 80 per cent of the population lives by the year 2008.
BT shares the Government's vision of delivering
broadband Britain. Under current technological constraintsuse
of ADSL technology is limited by the distance between the exchange
and the customer and by the economies of installing it in small
rural exchangeswireless becomes a potentially important
"bridge" technology for providing "wider band"
services in remoter parts of the UK which are not currently viable
for ADSL or equipped for cable.
It is also in the interests of any region not
to put itself at a competitive disadvantage in the evolution of
Broadband Britain by the application of disparate local or regional
Current and past UK telecommunications policy
has sought to encourage investment and competition in infrastructure,
as well as in services, and this has led to a multiplicity of
networks and operators who have licenses, rights and obligationsin
terms of quality and coverage requirements and targets they must
BT fully supports site sharing and indeed the
entire industry is demonstrating increasing commitment to sharing.
Notwithstanding, this commitment there will undoubtedly be a need
for a large number of base station sites as services such as 3G,
emergency services network, broadband fixed wireless access, and
wireless LANs are rolled out. The precise extent of this requirement
for additional base station sites will depend on the technical
and practical limitations to site sharing.
In addition to exploring the potential of shared
sites and shared infrastructure, BT is driving forward other ways
to reduce environmental impact, including, for example:
Increasing the proportion of pico
and micro cells.
Environmental design (eg on church
Small unobtrusive antennae on lamp
posts, street signs, shop signs, and even telegraph poles.
Currently, the mix of BTCellnet sites is 40
per cent new sites, 24 per cent on an existing structure, 15 per
cent on another radio site/shared site and 21 per cent microcells
(eg on shop or street furniture). Around one in four of the new
sites are shared with other operators. So in total, around 70
per cent of current BTCellnet sites are either shared sites or
base stations on existing structures.
We see the relative number of micro and pico
cells growing in comparison to macro cells over the next few years.
The pictures at Annex A
illustrate the different categories of base station sites; clearly
in terms of visual impact micro and pico cells are generally to
be preferred, albeit it is not feasible to rely entirely on micro
and pico cells for 3G core coverage.
We are currently awaiting the outcome of the
review of planning rules undertaken as a result of the recent
DETR consultation. Similar exercises are being undertaken in Scotland,
Wales and Northern Ireland. There are two crucial issues here:
(i) The risk that each of the countries will
adopt a different approach, skewing investment and resultant coverage
and services, and fragmenting the UK customer benefits. This could
also potentially load additional costs onto suppliers, if standards
and requirements are different in each part of the UK, leading
to loss of economies of scale to the detriment of the ability
of UK based suppliers to be competitive on a global basis. The
consequences of this could include unnecessarily high prices for
UK consumers and an overall loss of competitiveness for the UK
as a whole in the global context.
(ii) In the event that full planning permission
becomes a requirement for all new sites, the industry would face
substantial additional costs and customers unnecessary delays
as 3G services are delivered later than anticipated. Furthermore,
full planning permission could do very little to address community
concerns. In itself it would neither require community communications
and consultation, nor give communities a power of veto. It would
however impose a substantial and, it is believed, unwelcome administrative
and cost burden on planning authorities.
In its response to DETR, BT acknowledged that
some changes are needed. The operators, BT included, have not
always been as sensitive as they might have been in choosing sites,
nor in managing implementation. The development of some sites
has aroused concern and controversy in local communities, and
with local politicians. The concerns stemmed primarily from a
perception that base stations could pose a potential health risk,
despite the current scientific consensus, summarised in the report
of the Independent Expert Group on Mobile Phones.
There is, however, a strong crossover between
health concerns and visual amenity issues, and fears that base
station construction could have other negative consequences including
depression of local house prices.
Although there is no scientific evidence that
there is a health problem, we recognise that there is a perception
problem. We believe that Government, the industry and community
opinion formers need to work together constructively to find solutions
to the challenge of satisfying the growing appetite for communications
on the move, and keeping the UK in the vanguard of mobile commerce
and other service developments, while addressing public concerns.
In its response to the DETR, BT recommended
the creation of a new planning template, universally and consistently
applied throughout the UK, designed to be rapid but effective.
The template should have built-in requirements for:
Proactive communication and consultation
with the local community.
Provision of information by operators
to local planning authorities at the "pre-planning stage"
giving them an overview of planned activity within a particular
Access for and contribution by local
authorities to a UK Sites Database Specific timescales for each
part of the process.
Notification by operators to local
communities (not just publication of planning notices) but leaflet
drops to households close by and provision for meetings involving
community representation, planning authorities and operators.
Such an approach would be underpinned by a code
of practice, setting out simply what local communities could expect
and how operators would work.
As outlined above, BT is committed to exploiting
better the opportunities which exist for site sharing to minimise
the need for new sites, although we recognise that this can make
particular sites less attractive to local communities from a visual
amenity perspective. The establishment of a national sites database
would support such a concept.
We also support the FEI's proposal to equalise
fees for prior approval and full planning applications in recognition
of the fact that local authorities will need to find specialist
resources to work on increasingly complex and technical issues.
It is important that, whatever the planning
process, some customers in the UK are not disenfranchised or deprived
of the benefits of innovative services or top quality coverage.
BT has also a particular perspective here, due to its unique position
in having a Universal Service Obligation in relation to it's fixed
services. BT needs to be enabled to install quickly emergency
or temporary infrastructure from time to time so that it can maintain
essential fixed network services to remote rural populations and
7. OPERATOR COMMITMENTS
BT supports the 10 operator commitments for
cellularset out in Annex Bdeveloped under the auspices
of the FEI.
These commitments recognise that the key to
addressing public concern lies in improved dialogue with the community,
based on better communication and consultation. The planning system
is not equipped to deal with concerns about health; nor should
it be. The commitments provide a template on planning as advocated
by the Stewart report. The industry is committed to better stakeholder
consultation and to building bridges between the industry and
those affected by network rollout.
8. HEALTH ISSUES
BT takes the health and safety of its customers,
employees, and the broader community very seriously. Last year
we welcomed publication of the Stewart Report.
BT has in place a cross company programme, advised
by its Chief Medical Officer, to ensure that BT keeps abreast
and takes account of research findings, that its working practices
in the wireless arena are safe for its employees and others, and
that it complies with all relevant standards.
The independent National Radiological Protection
Board (NRPB) and other reputable agencies have advised that there
is currently no convincing scientific evidence of a risk to health
though exposure to radio frequency (RF) waves below the national
guidelines. BT has adopted a "precautionary approach"
in keeping with the recommendations of the Independent Expert
Group on Mobile Phones (known as the Stewart inquiry). We work
to the International Commission on Non-Ionising Radiation Protection
(ICNIRP) public exposure guidelines, which are tighter than those
of the NRPB, and support and help fund continuing independent
In contrast to the uncertainty on risk, there
is absolute evidence of the benefits of mobile services. In addition
to the economic, social and convenience benefits to millions of
customers, mobile phones have saved numerous lives and helped
many more people in unpleasant and dangerous situations.
BT has recently audited its ICNIRP compliance
both through predictive computer modelling and validating field
measurements and has found that emissions are all many times below
the ICNIRP public exposure guidelines. In fact the Radiocommunications
Agency has just published data showing some exposure levels typically
1/1000th to 1/10,000th of the guidelines.
The internationally recognised expert bodies
that are widely relied upon to set limits and standards are NRPB
and ICNIRP but as can be seen above, our equipment generally operates
several orders of magnitude within the independently prescribed
BT already supports UK and European research
to address the World Health Organisation Research agenda, and
meets the WHO criteria for good research. BT has recently committed
£552,000 over three years towards funding the Government's
£7.68 million radio frequency research programme, as recommended
by the Stewart Report.
It is imperative that the way forward is predicted
on robust methodology and peer-reviewed work. We are concerned
that some of the research which dominates the media headlines
does not always pass the test of scientific rigour once examined
more closely. Scaremongering is as ill-advised as over-claiming
9. MANAGING RISK
We believe that the risks which may be associated
with radio frequency emissions (RF) must be set into the context
of the everyday risks which most of us take each day without a
thought. For example, ROSPA figures indicate that accidents at
home accounted for 4,000 deaths and 2.7 million injuries in 1995
and road accidents accounted for 3,500 fatalities and 316,000
injuries the following year.
Wireless technologies, and devices which emit
EMF are such an intrinsic part of our lives that emissions are
all around usTV transmitters, TV sets, radios, LANs/WANs,
PCs, microwave ovens, hairdryers, baby alarms, and even light
bulbs all emit EMF.
Better information and education about risk
assessment and risk management is desirable if we are to raise
the level of this debate. The attitude to various types of risk
also has a bearing on any application of the "precautionary
principle". We are concerned that the precautionary principle
is currently being seen in some quarters as a tool to prevent
erection of all further base stations.
BT feels that it would be beneficial if the
Government were to take a lead in informing and educating the
public on relative risks, and risk management generally.
7 March 2001
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