1.  SUMMARY

  Overwhelmingly enthusiastic demand from industry, commerce, government and consumers has, within the last decade, transformed the role and significance of the UK's cellular radio assets. A useful support technology has become a vital component in the nation's commercial and social infrastructure. This position can only be reinforced by developments from evolving second-generation and forthcoming third-generation networks, including always-available data connections, higher data speeds and greater flexibility for multimedia applications.

  Continuing heavy investment by network operators has democratised this crucial enabling technology. Services which, some years ago, were effectively the preserve of the wealthy and powerful in the most prosperous areas of the country are now almost universally available and affordable. This is one "digital divide" which was closed even before most people noticed it was there.

  Having been avoided in the context of today's mobile voice and data services, it would be ironic if such a divide were to become institutionalised in more advanced services. Any measures which slow and limit investment in network infrastructure must be considered in the light of the hidden costs they would impose on the 70 per cent of the population who are now consumers of existing services, and the potential future costs for "UK PLC". This applies especially to less advantaged parts of society as the natural progression of innovative new services from "niche" to "mass-market" is inevitably affected by delays in realising economies of scale and the physical availability of networks.

  Like industrial development, transport, energy supply, housing and the availability of food and water supplies in a modern society, effective communication requires infrastructure. The provision of all socially beneficial infrastructure requires trade-offs to be made between the benefits and the costs. It is a fact of life that these costs invariably include a degree of environmental impact.

  Throughout the modern world it is therefore healthy and necessary for societies periodically to weigh the balance between benefits and costs. The irony of anti-mast protestors using their mobile phones to organise protests encapsulates the dilemmas inherent in this debate.

  Continuing growth in demand for services, and the continuing availability of services to those who already rely on them, can only be supported by continuing investment in network infrastructure. The phones cannot work without the networks, and the networks can only operate according to the laws of physics. It is inherent to the operation of mass-market mobile phone networks that they operate at high frequencies and short ranges, so that the available spectrum can be re-used every few kilometres. Many customers are therefore able to talk simultaneously using the same frequency, without interfering with each other, across the country. It follows that the base stations must necessarily be very close to the customers they serve, otherwise power levels would have to be radically increased, to levels more comparable to broadcast TV and radio stations, thus increasing exposure to RF, and the overall capacity of the networks would shrink to the point that they were not practically usable.

  As cellular radio has become a simple-to-use mass-market service, its ubiquity has outstripped general understanding of the technical principals by which its numerous benefits are realised. In this, it is similar to most mass-market consumer technologies. It is axiomatic that unkown and invisible forces have great potential to provoke fear, and the industry should perhaps address this by doing more to educate its customers and the communities in which it works about the operating principles of cellular networks. As the Stewart report points out, consultation is key, yet consultation and consent can only be truly effective when they are suitably informed.

  BT believes that it would be most helpful for the Government to show a lead in this, working with the industry to open up an informed debate on the relative balances of risks and rewards in this and other aspects of life in a modern industrialised society.

  The need for continuing research into possible health effects is unarguable, and BT believes that the scope of research could beneficially be widened further by examining the full spectrum of social, environmental impacts, enabling the whole picture to be considered "in the round".

  BT also believes that the best interests of overall UK industrial and environmental policy would be supported by stronger links and greater integration between the two bodies of public policy. Both areas of policy are vital to the UK's future and each has an indisputable impact on the other. The earlier that environmental considerations are taken into account in the forming of industrial policy, and industrial considerations taken into account in the forming of environmental policy, the higher the overall quality of the outcomes will be.

  The industry in turn must, of course, delivery consistently on its commitments, including those on local consultation as well as its licence obligations to deliver widespread coverage and adequate network capacity.

2. BACKGROUND

  The BT Group is involved in the deployment and use of wireless technologies in many different aspects of its business. We therefore appreciate from a number of perspectives the need to strike appropriate balances between consumer demand for high quality services, and other stakeholder interests including visual amenity and potential health concerns.

  BT Cellnet, wholly owned by BT, provides cellular network coverage to more than 11 million customers throughout the UK, and is continually upgrading the network to increase capacity and improve coverage quality. In addition to its significant investment in first and second generation technology and services, BT has invested more than £4 billion in a third generation (3G) licence for the UK, and is currently planning its rollout of 3G infrastructure and services.

  BT is part of the consortium providing mobile telecommunications to the Home Office for the emergency services through its dedicated Airwave network, which needs to provide comprehensive coverage. The service will enable the emergency services to speak directly to each other without having their calls managed by their control centre, saving valuable time in major emergencies. This is vital in the event of a major incident that affects more than one force, with significant benefits in the potential to save lives. It is currently estimated that around 3,000 additional masts will be needed for this service over the next four years.

  BT, through its wholesale business, is a supplier of infrastructure services, including cell sites and transmission, to other operators and service providers. BT is exploring ways of minimising the need for new ground-based masts, for example, through an agreement with Crown Castle International to use up to 4,000 of its operational buildings within BT's property portfolio to site antenna.

  We are also looking for ways to site micro and pico cells to provide infrastructure services to others—for example we are trialling the siting of micro cells in the roofs of certain types of BT payphones to further enhance GSM coverage and are considering how micro or pico cells could best be situated in or on other "street furniture" (see Annex A[1] for illustrative examples).

  BT uses wireless technologies in its own fixed PSTN network, to provide point to point services, so as to reach areas where it would not be possible or cost-effective to lay cable, to provide temporary services including disaster recovery and to provide reliable fault-tolerant services for customers. BT installs around 200 dish antennas, each month, using a combination of new and established sites. These arrangements serve not only BT's own network infrastructure but also infrastructure that BT builds and provides for others.

  BT has a further range of additional products and services employing wireless technology, including pagers, cordless and satellite phones.

3.  MARKET DEMAND AND ECONOMIC IMPACT

  Wireless communications are self evidently an integral and vital part of modern society, At the end of 2000, there were 41 million mobile phones connected to networks in the UK. Based on independent forecasts by NERA, the number of mobile devices is anticipated to grow to more than 70 million by 2010. NERA estimated that the UK mobile phone industry (not counting wider wireless technologies) generated directly and indirectly £5.3 billion in contribution to GDP, and supported an estimated 164,000 jobs in 1999. NERA further estimated that over the next 10 years the mobile industry could be expected to generate a cumulative total of £214 billion in contribution to GDP, supporting 519,000 jobs in 2010.

  Wireless technology plays an important role in both business and personal lives. As well as enabling conversations, texting (SMS), mobile business, mobile internet, location based services, and mobile commerce, mobile phones provide individuals with the reassurance of improved safety and security, and peace of mind for parents whose children are out and about. Wireless technology also underpins the ubiquity of emergency services operations, providing essential, lifesaving communications services. Growth in mobile communications—notably enhanced, second generation and third generation systems—will support a rapid move to more capacity for the information era. The market will be extended through higher quality voice services, higher speed data and multimedia capabilities.

  Mobile communications are an essential contribution to the national economy and the competitive position of the UK. By early summer 2002, a fifth of all voice and data minutes is expected to be mobile and this figure is set to rise dramatically thereafter.

  The UK's leadership position in mobility and e-commerce is dependent upon the continued investment in new technologies and provision of the necessary supporting infrastructure. It is simply not possible to have mobile phones and devices without the network of base stations which enable them to work. Further innovation in this area will underpin the UK's ability to compete with others in developing the knowledge economy

4.  THE NEXT GENERATION AND IMPLICATIONS FOR BROADBAND BRITAIN

  Third generation services will significantly improve the speed of data transmission. In so doing, they will encourage the mobile data market as well as providing additional spectrum capacity for growth. 3G networks will improve voice quality, "always-on" data services (such as fast internet access), and roaming. In addition, enhanced data rates will facilitate the provision of broadband data services over laptop-style devices and future generations of mobile phones, such as video, music and multi-media. There is a rich variety of possible applications, ranging from entertainment (music, games, video) and information (location based services, maps, guides, news), to personal financial transactions (banking, shopping, broking) and improved communication services (interest groups, video conferencing). Many as yet unimagined new ideas will emerge as time progresses. Apart from the commercial and lifestyle benefits, improved personal safety and security opportunities will inevitably arise. The 3G licences awarded in the UK contain an obligation from Government to cover the geography in which 80 per cent of the population lives by the year 2008.

  BT shares the Government's vision of delivering broadband Britain. Under current technological constraints—use of ADSL technology is limited by the distance between the exchange and the customer and by the economies of installing it in small rural exchanges—wireless becomes a potentially important "bridge" technology for providing "wider band" services in remoter parts of the UK which are not currently viable for ADSL or equipped for cable.

  It is also in the interests of any region not to put itself at a competitive disadvantage in the evolution of Broadband Britain by the application of disparate local or regional planning regulations.

5.  INFRASTRUCTURE

  Current and past UK telecommunications policy has sought to encourage investment and competition in infrastructure, as well as in services, and this has led to a multiplicity of networks and operators who have licenses, rights and obligations—in terms of quality and coverage requirements and targets they must meet.

  BT fully supports site sharing and indeed the entire industry is demonstrating increasing commitment to sharing. Notwithstanding, this commitment there will undoubtedly be a need for a large number of base station sites as services such as 3G, emergency services network, broadband fixed wireless access, and wireless LANs are rolled out. The precise extent of this requirement for additional base station sites will depend on the technical and practical limitations to site sharing.

  In addition to exploring the potential of shared sites and shared infrastructure, BT is driving forward other ways to reduce environmental impact, including, for example:

—  Increasing the proportion of pico and micro cells.

—  Rooftop siting.

—  Environmental design (eg on church spires/flagpoles).

—  Small unobtrusive antennae on lamp posts, street signs, shop signs, and even telegraph poles.

  Currently, the mix of BTCellnet sites is 40 per cent new sites, 24 per cent on an existing structure, 15 per cent on another radio site/shared site and 21 per cent microcells (eg on shop or street furniture). Around one in four of the new sites are shared with other operators. So in total, around 70 per cent of current BTCellnet sites are either shared sites or base stations on existing structures.

  We see the relative number of micro and pico cells growing in comparison to macro cells over the next few years. The pictures at Annex A[2] illustrate the different categories of base station sites; clearly in terms of visual impact micro and pico cells are generally to be preferred, albeit it is not feasible to rely entirely on micro and pico cells for 3G core coverage.

6.  PLANNING

  We are currently awaiting the outcome of the review of planning rules undertaken as a result of the recent DETR consultation. Similar exercises are being undertaken in Scotland, Wales and Northern Ireland. There are two crucial issues here:

(i)  The risk that each of the countries will adopt a different approach, skewing investment and resultant coverage and services, and fragmenting the UK customer benefits. This could also potentially load additional costs onto suppliers, if standards and requirements are different in each part of the UK, leading to loss of economies of scale to the detriment of the ability of UK based suppliers to be competitive on a global basis. The consequences of this could include unnecessarily high prices for UK consumers and an overall loss of competitiveness for the UK as a whole in the global context.

(ii)  In the event that full planning permission becomes a requirement for all new sites, the industry would face substantial additional costs and customers unnecessary delays as 3G services are delivered later than anticipated. Furthermore, full planning permission could do very little to address community concerns. In itself it would neither require community communications and consultation, nor give communities a power of veto. It would however impose a substantial and, it is believed, unwelcome administrative and cost burden on planning authorities.

  In its response to DETR, BT acknowledged that some changes are needed. The operators, BT included, have not always been as sensitive as they might have been in choosing sites, nor in managing implementation. The development of some sites has aroused concern and controversy in local communities, and with local politicians. The concerns stemmed primarily from a perception that base stations could pose a potential health risk, despite the current scientific consensus, summarised in the report of the Independent Expert Group on Mobile Phones.

  There is, however, a strong crossover between health concerns and visual amenity issues, and fears that base station construction could have other negative consequences including depression of local house prices.

  Although there is no scientific evidence that there is a health problem, we recognise that there is a perception problem. We believe that Government, the industry and community opinion formers need to work together constructively to find solutions to the challenge of satisfying the growing appetite for communications on the move, and keeping the UK in the vanguard of mobile commerce and other service developments, while addressing public concerns.

  In its response to the DETR, BT recommended the creation of a new planning template, universally and consistently applied throughout the UK, designed to be rapid but effective. The template should have built-in requirements for:

—  Proactive communication and consultation with the local community.

—  Provision of information by operators to local planning authorities at the "pre-planning stage" giving them an overview of planned activity within a particular geography.

—  Access for and contribution by local authorities to a UK Sites Database Specific timescales for each part of the process.

—  Notification by operators to local communities (not just publication of planning notices) but leaflet drops to households close by and provision for meetings involving community representation, planning authorities and operators.

  Such an approach would be underpinned by a code of practice, setting out simply what local communities could expect and how operators would work.

  As outlined above, BT is committed to exploiting better the opportunities which exist for site sharing to minimise the need for new sites, although we recognise that this can make particular sites less attractive to local communities from a visual amenity perspective. The establishment of a national sites database would support such a concept.

  We also support the FEI's proposal to equalise fees for prior approval and full planning applications in recognition of the fact that local authorities will need to find specialist resources to work on increasingly complex and technical issues.

  It is important that, whatever the planning process, some customers in the UK are not disenfranchised or deprived of the benefits of innovative services or top quality coverage. BT has also a particular perspective here, due to its unique position in having a Universal Service Obligation in relation to it's fixed services. BT needs to be enabled to install quickly emergency or temporary infrastructure from time to time so that it can maintain essential fixed network services to remote rural populations and "sensitive users".

7.  OPERATOR COMMITMENTS

  BT supports the 10 operator commitments for cellular—set out in Annex B—developed under the auspices of the FEI.

  These commitments recognise that the key to addressing public concern lies in improved dialogue with the community, based on better communication and consultation. The planning system is not equipped to deal with concerns about health; nor should it be. The commitments provide a template on planning as advocated by the Stewart report. The industry is committed to better stakeholder consultation and to building bridges between the industry and those affected by network rollout.

8.  HEALTH ISSUES

  BT takes the health and safety of its customers, employees, and the broader community very seriously. Last year we welcomed publication of the Stewart Report.

  BT has in place a cross company programme, advised by its Chief Medical Officer, to ensure that BT keeps abreast and takes account of research findings, that its working practices in the wireless arena are safe for its employees and others, and that it complies with all relevant standards.

  The independent National Radiological Protection Board (NRPB) and other reputable agencies have advised that there is currently no convincing scientific evidence of a risk to health though exposure to radio frequency (RF) waves below the national guidelines. BT has adopted a "precautionary approach" in keeping with the recommendations of the Independent Expert Group on Mobile Phones (known as the Stewart inquiry). We work to the International Commission on Non-Ionising Radiation Protection (ICNIRP) public exposure guidelines, which are tighter than those of the NRPB, and support and help fund continuing independent research.

  In contrast to the uncertainty on risk, there is absolute evidence of the benefits of mobile services. In addition to the economic, social and convenience benefits to millions of customers, mobile phones have saved numerous lives and helped many more people in unpleasant and dangerous situations.

  BT has recently audited its ICNIRP compliance both through predictive computer modelling and validating field measurements and has found that emissions are all many times below the ICNIRP public exposure guidelines. In fact the Radiocommunications Agency has just published data showing some exposure levels typically 1/1000th to 1/10,000th of the guidelines.

  The internationally recognised expert bodies that are widely relied upon to set limits and standards are NRPB and ICNIRP but as can be seen above, our equipment generally operates several orders of magnitude within the independently prescribed limits.

  BT already supports UK and European research to address the World Health Organisation Research agenda, and meets the WHO criteria for good research. BT has recently committed £552,000 over three years towards funding the Government's £7.68 million radio frequency research programme, as recommended by the Stewart Report.

  It is imperative that the way forward is predicted on robust methodology and peer-reviewed work. We are concerned that some of the research which dominates the media headlines does not always pass the test of scientific rigour once examined more closely. Scaremongering is as ill-advised as over-claiming on safety.

9.  MANAGING RISK

  We believe that the risks which may be associated with radio frequency emissions (RF) must be set into the context of the everyday risks which most of us take each day without a thought. For example, ROSPA figures indicate that accidents at home accounted for 4,000 deaths and 2.7 million injuries in 1995 and road accidents accounted for 3,500 fatalities and 316,000 injuries the following year.

  Wireless technologies, and devices which emit EMF are such an intrinsic part of our lives that emissions are all around us—TV transmitters, TV sets, radios, LANs/WANs, PCs, microwave ovens, hairdryers, baby alarms, and even light bulbs all emit EMF.

  Better information and education about risk assessment and risk management is desirable if we are to raise the level of this debate. The attitude to various types of risk also has a bearing on any application of the "precautionary principle". We are concerned that the precautionary principle is currently being seen in some quarters as a tool to prevent erection of all further base stations.

  BT feels that it would be beneficial if the Government were to take a lead in informing and educating the public on relative risks, and risk management generally.

7 March 2001

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