KK0319920ENN en

FR
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:
Digital
Single
Market
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
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
SCF Associates Ltd 1

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 Limiting value for exemption
exemption
For outdoor SAWAPs emission power a) For an active antenna system (AAS) with multi-user MIMO
(in absence of valid field measurement beamforming antenna, an upper limit of 1 Watt maximum transmit
and monitoring techniques for AAS power. Note that this is a provisional initial estimate. This value should
beamforming with MIMO in any band) 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 20-30 litres, including power supplies and batteries. Note that this
transceiver enclosure if exposed volume range depends on configuration and technology used.
outdoors (and not hidden inside street
furniture when it may be larger).
For indoor SAWAPs emission power Less than 0.2 W EIRP for non-AAS. For AAS to be determined.
(in absence of valid field measurement
and monitoring techniques for AAS
beamforming with MIMO in any band)
Physical size of indoor SAWAP No size limits.
transceiver enclosure.
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 Agencija za komunikacijska omrežja in storitve Republike Slovenije
(formerly (Agency for Communications Networks and Services of the Republic of
APEK) 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)
2019 2020 2021 2022

Region 2015 2016 2017 2018
(est.) (est.) (est.) (est.)
Central & Eastern 546 901 1,355 2,153 3,119 4,317 5,834 7,752
Europe
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
-- 66% 49% 49% 43% 37% 35% 34%
increase
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 standards 15 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_li
mits; 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 km 2 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
External
DC power supply
facing
Wi-Fi
MIMO
or 5G
antenna
Air interface
array
Wi-Fi hub
or 5G SAWAP
BTS unit
Through
wall
cabling
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 Electronic communications development permit
Kingdom
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 Definition
State
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 Antenna masts up to 8 m in height (including their support structures) do not

Republic 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 “’Small antenna’ means an antenna which (a) is for use in connection with a
Kingdom 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
Number
Groups Sub-groups Details
of MS
Outside built-up Cyprus: on ground outside boundary of urban

area development when antenna mast is <25 m tall
Location 3
Indoors Lithuania: “transmitters inside buildings”
Spain: in privately owned buildings
Cyprus: mast is <9 m above main roof level or

Rooftop
<6 m on unoccupied two-story building
Sweden: does not “materially change” building

Building facade
appearance
Mounting 5
Hungary: can be deployed without reinforcing
Building building structure
without
reinforcement Latvia: does not reduce “bearing strength or
stability” of an existing construction
Street furniture Netherlands: <0.5 m tall on street furniture
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
Total size Form factor dimension 4
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
Belgium: Flanders: ≤2W

ERP Estonia: Health Board approval not needed
≤100W
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
Power EIRP in advance about… stations whose EIRP is 8
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)
Italy: radiating surface < 0.5m² and power <7

Antenna input W at the antenna input
Luxembourg: <50 W
Belgium: Flanders – no height increase when

Antenna Mast height added to existing structure 7
Czech Republic: Antenna masts <8 m in height

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)
Denmark: “Panel antennae for mobile

communication with associated radio modules
and transmission links in neutral colours, set on
Panel type
existing masts used for public mobile
communications, silos or high chimneys, when
the height of the building is not increased”
Italy (some regions): radiating surface

Radiating area
<0.5m² and power <7 W at the antenna input
Denmark: “Panel antennae for mobile

communication with associated radio modules
and transmission links in neutral colours”
Appearance 3
Poland: “low impact on the landscape”
Sweden: does not “materially change” building
appearance
Cyprus: <3 m tall and ground area <6 m2

Equipment Denmark: floor plan <2 m2 and height <2.5 m, 2
cabinet used with panel antenna in neutral colour and
mounted on mast, chimney, etc.
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 Precautionary

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)
Bulgaria No power-based exemptions found Precautionary
Croatia No power-based exemptions found Precautionary
Cyprus Base stations emitting <63 W exempt from planning ICNIRP

permits
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 ICNIRP

stations with ERP ≤100W
Finland No power-based exemptions found ICNIRP
France No declaration or ANFR authorisation needed for ICNIRP (except in Paris)

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
Germany BNetzA and civic authorities must be notified about ICNIRP

the deployment of stations emitting more than
100mW but less than 10W EIRP. Stations emitting
<100mW EIRP do not need a site certificate
Greece “Low power, low interference potential antenna Precautionary

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).
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 Precautionary

W; in other areas, if <10 W just notify local planning
authorities
Latvia No power-based exemptions found ICNIRP recommended but

not mandatory
Lithuania Base stations emitting <25 W ERP do not need public Precautionary
health authority certification
Luxembourg Stations <50 W do not need individual site Precautionary

authorisations

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 ICNIRP

authorisation” (e.g. Wi-Fi)
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 No power-based exemptions found ICNIRP recommended but

Kingdom 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
Time required Permit costs
State
Austria Varies by region, from an average of 10 Wide variation by region

weeks up to 6 months
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 More research needed

but no time limit on local planning
permits
Cyprus 6 weeks is the legal limit but 6 months Varies from one municipality to
is more typical 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 Depends on which services requested
no environmental protection issues from which municipalities
Estonia 20 days (10 + 10) separated by actual €85

construction
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 Fee exemptions for mobile broadband
which permit is “deemed granted.” 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 If a deployment permit is needed it

that delays for permits may be avoided generally costs less than €100 (one-
for BTS below 10 W emitted power time payment), but there may also be
under certain conditions. For larger base site survey costs.
station sites delays may be several
months but are highly variable.
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 €29 fee for agreement that the radio
authority about the radio technical part technical part of the project complies
of the project (compliance with EMF with EMF public health requirements,
limits, approval of the EMF monitoring plus €29 fee for agreement on the EMF
plan) must be made within 20 working monitoring plan.
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.
Luxembourg Typically 2 months Every urban area sets their own fees.
Malta Applications for planning permits are A “full development permit” costs
decided in 15 days plus 15 more days €19,695 plus €450 to process the
for public comment. Hearings are held Notice of Completion. But such permits
within 2 weeks and then the decision is are rarely required, certainly not for
due within 2 months. So the whole small base stations.
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.
Netherlands Permits for base stations mostly not €258 if one is needed at all.
needed but environmental permits often
needed for buried backhaul links. Time
varies from one municipality to another.
Poland Permit regulations under review – past Permit regulations under review – past
practices may no longer be relevant 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 The “urbanism certificate” seems to be
“urbanism certificate” to verify that free of charge, but the cost of a
supporting a base station is an allowed building permit is 0.9% of the
use of the property – this will be construction project’s cost.
decided within 30 days. Then issuing a
building permit is to be decided within
30 days. But actual processing

apparently takes months.
Slovakia Depends on project complexity and local €30 - €200 per site, depending on
site restrictions, generally 30-90 days. location and project complexity.
Slovenia Time allowed by law is 60 days, which is If full vetting required, the cost can be
often but not always achieved. up to €789.
Spain From one to several months, depending Permits have mostly been replaced by
on jurisdiction. But permits mostly not installers’ statements of responsibility
needed anymore. and notices of work completion.
Sweden Generally 10-20 weeks, but “worst Differs from one municipality to
cases” can take up to a year. another.
United 8 weeks for “prior approvals” and “full In England, £462 for full planning
Kingdom development planning permits” 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 England: neither prior approval nor full planning permission needed for
Kingdom “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
EIRP EIRP
Class Product installation criteria
(W) (dBm)
The product complies with IEC 62479 or the product compliance

E0 n/a n/a boundary dimensions are zero. No specific requirement for product
installation.
The product is installed according to instructions from the

manufacturer and/or entity putting into service. Compliance with the
E2 ≤2 ≤33
exposure limits is generally obtained at zero distance or within a few
centimetres.

manufacturer and/or entity putting into service and the lowest
E10 ≤10 ≤40
radiating part of the antenna(s) is at a minimum height of 2.2 metres
above the general public walkway.

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 D m and
E100 ≤100 ≤50 (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.

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
E+ >100 >50 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

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
Figure 1: Aprone to vandalism
co-located by local
cluster of residents.
different SAWAP designs in China
Figure 3.3. A co-located cluster of different small cell 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 Equivalent radiation power
E (V/m) 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 3G 69. 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 movement 75 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_Mor
atorien_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 rules 81
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.

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).”
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.

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 expected 96 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/antenneco
nvenant-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

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
Phase 1 Phase 2 Phase 3 Exemption from

planning permission
Aesthetics
Cultural Acceptance Aesthetics
Approval Verified compliance
for aesthetics parameters conditions
conditions with exemption
parameters
RF/EMF
Emissions Parameters
conditions
Measurement Process
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

Special Case
(never before
NOT in seen)
protected Visual impact Meets
area/ site assessment standards
NOT Standard
for SAWAPs assessment
SAWAP required approval
rollout:
- initial site Minimal
triage Visual case
Determine
analysis impact visual
assessment impact
Protected required Expanded
area/ site level
assessment
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

1 Visible but
acceptable
• An EU-wide competition on solutions – high appearance
promotion (“a small cell for Europe” contest –
with public exposure) in 2 classes, either:- 2 Hide in plain sight
eg in bus stop/
display panel
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:

 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

No visual clutter:- Under the street inside
Inside Street furniture manhole covers -deep or
- Bus Stop just below street surface
Source: JC Decaux 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 densification 104 – 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 Transmitter Antenna Measured EIRP
Band
model rating configuration gain equivalent
Nokia AirScale 27.5-28.35 60 dBm =
0.63 W 16 x 16 MIMO 29 dBi
AEUA Flexi-Zone GHz 1000 W
(Without Supplied
Ericsson AIR 2500 MHz 71.3 dBm =
60 W integrated test antenna
6468 5G radio 13,490 W
antenna) = 23.5 dBi
Nokia AirScale 19.1 - 23.3

2496-2690 74.8 dBm =
5G NR (MAA- 80 W 8 x 8 MIMO dBi (varies
MHz 30,199.5 W
64T64R-128AE) with angle)
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
Frequency/Power/Range – (Diagrammatically)
26GHz
6GHz
700MHz
Power
emitted SAWAP Cell Outdoor Exclusion zones
EIRP nd
y ba
W nc Installation Limit
ue
eq Exposure Value (ILV) (residential/
Fr Limit Value working environment
(ELV) - Exclusion zone)
5 10 100 1000m SAWAP
Exclusion
Log Range for MIMO propagation, m Zone
SAWAP
Occasional (passing use)
Simon Forge SCF ASSOCIATES Ltd all rights reserved 2018 24
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 Limiting value for exemption
exemption
For outdoor SAWAPs emission power a) For an active antenna system (AAS) with multi-user MIMO
(in absence of valid field measurement beamforming antenna, an upper limit of 1 Watt maximum transmit
and monitoring techniques for AAS power. Note that this is a provisional initial estimate. This value should
beamforming with MIMO in any band) 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 20-30 litres, including power supplies and batteries. Note that this
transceiver enclosure if exposed volume range depends on configuration and technology used.
outdoors (and not hidden inside street
furniture when it may be larger).
For indoor SAWAPs emission power Less than 0.2 W EIRP for non-AAS. For AAS to be determined.
(in absence of valid field measurement
and monitoring techniques for AAS
beamforming with MIMO in any band)
Physical size of indoor SAWAP No size limits.
transceiver enclosure
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” -

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
Outdoor SAWAP unit in, or on, street furniture
MIMO
Edge server Active
& storage External Femto cell–like
RF Array
Facing indoor SAWAP hub
processor Antenna
MIMO - wall transceiver
Antenna BTS unit with its
array DC power supply
Power supply
& cooling
5G NR
Through Air interface
Enclosure shell wall cabling plus Wi-Fi &
Backhaul (-front face transparent to Bluetooth
& power RF emissions).
cabling May be surplus to needs
if unit sited inside street
furniture
Simon Forge SCF ASSOCIATES Ltd all rights reserved 2018 1
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.

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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
KK-03-19-920-EN-N
CATALOGUE NUMBER
DOI: 10.2759/508915 ISBN: 978-92-76-13357-5

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Light Deployment Regime for Small-Area

A study prepared for the European Commission

DG Communications Networks, Content & Technology by:

This report is for use by the European Commission services

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

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

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

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

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

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

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

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

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

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

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

SCF Associates Ltd 1

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

SCF Associates Ltd 2

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

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

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

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

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

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

SCF Associates Ltd 3

Terminology Used in the Report

SCF Associates Ltd 4

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

“Radio” usually implies radio communications using electromagnetic transmission of

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

SCF Associates Ltd 5

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

SCF Associates Ltd 6

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

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

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

SCF Associates Ltd 7

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

SCF Associates Ltd 8

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

An EC public consultation1 and study consultations with industry representatives and

SCF Associates Ltd 9

Table 0.1. Definition of parameters for exemption of SAWAPs

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

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

SCF Associates Ltd 10

SCF Associates Ltd 11

2G Second generation mobile communications (GSM)

SCF Associates Ltd 12

ECC Electronic Communications Committee

SCF Associates Ltd 13

MTTR Mean Time To Repair

SCF Associates Ltd 14

VHC Very High Capacity

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1. Developing a Lightweight Regulatory Regime

1.1 The Context for the Study

Why is a lightweight regulatory regime for small cells necessary?