Outcomes of the SAWAP Stakeholder Workshop

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Outcomes of the SAWAP Stakeholder Workshop

Light-touch Regulation Regime for Small Area Wireless Access Points

The launch of commercial 5G services will require extensive enlargement and densification of fixed (fibre) and wireless networks, among other changes. Some mobile operators are planning to roll out 200 or more cells per square kilometre for high traffic environments. Density is projected to increase further, i.e. to support approximately one million connections per square kilometre, which could involve 1000 small cells in some scenarios. 

A light-touch regulation regime would help speed up the deployment of small area wireless access points (SAWAP) but needs to be acceptable to the EU Member States, protect the public and the environment. 

The European Electronic Communication Code: State of Play in Member States

The main findings of SCF Associates for an EC-Commission tender study underscore the current lack of harmonisation despite some progress in 2018:

  • No single definition of small cells is used throughtìout the European Union. Some countries have a working definition of "small cells" but most don't. 
  • Some countries offer exemptions or simplified/streamlined approval processes but most don't.
  • Article 57 of the European Electronic Communications Code (EECC) sets out a harmonised light deployment regime as essential for 5G rollout. The EECC is expected to be adopted by the end of 2018. However, there are gaps between the current situation in member states and EECC Articles 2 and 57. 
  • Land use planning, construction permit, requirements, wayleaves and laws vary widely, even within single countries and from one city or region to another. 
  • RF legal limits for health and safety vary across the EU.
  • Deployment rules still tend tp assume that base stations are large outdoor UHF macrocells (ultra high frequency).

The EECC's SAWAP concept is therefore a major opportunity to achieve harmonisation by clearly defining a new type of access point for both fixed and mobile radio, esential to future wireless networks and their regulation. We need to define how dense is 'dense' and how small is 'small', and also lunderstand divergences from recommended standards and practices as well as varying degrees of enforcement across member states. A key challenge is that it is becoming harder to determine if a base station or handset complies with standard emission limits for health and safety because MIMO (multiple input/multiple output) produces dynamic and irregular distribution of radio energy unlike current systems.

Four Perspectives on SAWAPs

2018 marked a period of great change to SAWAP regulations in member states and other leading markets. Findings from the SCF Associates' Study show that member states typically adopt three different approaches to human RF exposure: countries that follow 1999/519/EC; countries with no national laws (recommending ICNIRP use) and countries that apply a more cautious approach with stricter conditions, property rights, access wayleaves and conditions of use. 

To help build consensus, the workshop explored four key perspectives: 

1. Operational: comparisons of cell types, where and how they are deployed, regulated and used.

2. Technical: physical parameters, technology standards, specifications and measurable limits.

3. Environmental & aesthetic: impact on surroundings, public visibility.

4. Legal & regulatory: permits needed, administrative fees, site lease.

Panel discussions and break-out sessions raised several key issues: How much do we publicly disclose? How do we go about communicating the benefits to non-technical people? Should we discourage camouflaging? From an administrative perspective: what needs to be done and when? What are the blocking points?

It's always a local discussion

  • Experience over the past 5 years on small cells and antennas shows the value of helping cities react positively to change but does it always work? 

As a general rule, cities don't want antennas to be seen. Experience has also revealed different reactions to them, with some mayors even banning them. It is also hard to standardise the design because of individual tastes and many disucssions with mayors take place to find the right approach. Regulators should be the ones communicating the benefits, such as reduced exposure. However, some regulators like the French authority, Arcep, believe that explaining to the public doesn't always work because even the benefits are hard to understand for non-technical people.

Good Practices

  • UK lightweight approach. 

The UK's Ofcom has adopted a lightweight approach with a 5G expert engagement group looking at the multi-faceted issues and explaining cases where we really need authorisation and licence-exempt deployments. This regulatory authority has looked at the situation backwards, starting from routers and moving upwards.


China has an integrated approach, including training for installers. This puts a brake on how fast you can deploy. It also creates new skills and jobs: site resource providers. This is a good example of business creation through new services. China is also deploying small cells into the fabric of buildings. 

  • Consensus Building and Common Understanding of key Issues 

We need to ensure efficiency and better coverage, avoiding a situation where cities might block deployment. It's also important to keep costs low for operators, including deployments in rural areas to avoid the digital divide. It's a multi-faceted discussion spanning technology, standards, business models, economics of deployment, regulatory perspectives. It is key to have the same understanding of the goals of network densification and put in place rules facilitating small cell deployments. 

  • Coloured boxes and camoflouging; Costs.

Coloured boxes is the new trend but everything has a cost for the operators. However, modifications can cost more than the asset itself. For example, the cost of colouring the SAWAP box to fit local deployment could cost up to 100 Euro. For concealed deployments you need to be transparent to the people, but also transparency creates possibility of protests. It's key to choose the right way of communicating benefits/low risk of small cells to the public.

The cost of backhaul to achieve scale (1000s of small cells) needs to be factored in. The highest costs come from fibre plus connectivity. It is very expensive to build a site.

  • Power levels and cumulative effects across operators. Debate on licensed-exempt vs light licensing regimes (as recommended in the EECC). 

Aggregation is an issue because we need to factor in power differences; urban vs. rural. We need to avoid deployment only in selected cities and the possible fragmentations that are likely to occur in the U.S., where there is no obligation to expand coverage. There are also issues around the lack of harmonisation: safety, performance could be addressed by a more centralised approach: more infrastructure sharing. Cities have to be neutral for any operator, also for sharing.

What is actually the difference between small cells and WiFi Access Points (which are license exempt). Small cells may have carrier aggregation, multiple bands, multiple RATS, multioperators etc. Aggegration means linear aggregation of everything that is transmitted (different RATs, bands etc.) from a small cell site but it is quite complex. 

In conclusion, definitions need to be useful, credible, simple, sellable and explicit, including size, weight, height and power. There may be some limitation on weight, e.g. for lamp posts, and maximum height for applicability of light touch. Power means different things to different people so we need to be careful about how we define it as it will be a major parameter. It's also important to consider the implications of mobile beams for regulation.

Finally, conformance is a challenge for safety. Who’s responsible? It is particularly complicated in multi-party settings. We also have to consider the cumulative effects of exposure limits as there is a whole series of problems here. There are several bodies looking at how to measure EMF, e.g. CENELEC CLCTC 106x; ECC PT1; ITU-R WP-5D. 





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