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Memorandum submitted by the Mobile Operators Association(DIW 3)
Introduction
The Mobile Operators Association (MOA) represents the five UK mobile network operators - 3, O2, Orange, T-Mobile and Vodafone - on radio frequency health and safety and associated town planning issues.
This submission provides the views of the UK mobile network operators on:
· The adequacy of technological infrastructure provision throughout Wales (including Broadband, wireless, mobile, digital TV and digital radio), and · The ways in which commercial and non-governmental organisations contribute to digital inclusion in Wales, and the opportunities available.
Summary
Mobile broadband should be considered as a vital part of the overall solution to digital inclusion in Wales. While there are some constraints to investment due to the topography and population density of Wales, mobile broadband is a viable alternative to more traditional fixed networks, especially in urban areas. With the right policies in place, including ensuring an appropriate planning regime remains in place, ensuring that mobile communications is a fundamental part of the digital inclusion strategy could help Wales deliver its citizen engagement objectives and wider economic plan.
The provision of mobile communications services is only possible through the deployment of the infrastructure that supports the networks. This infrastructure can only be easily deployed if the planning system does not put in place unnecessary barriers to development. Any assessment of the telecoms planning regime should take account of the economic and social benefits of high quality communications services in Wales. Policy makers in Wales must ensure that the planning system does not act as a disincentive to investment in infrastructure.
Technological infrastructure provision in Wales
The mobile phone industry has made a significant contribution to technology and communications infrastructure in Wales in the past 20 years. Each of the five UK mobile network operators has invested heavily in mobile networks infrastructure in Wales, particularly in those areas of heaviest mobile phone use, including the main urban centres of Cardiff, Swansea, Neath-Port Talbot and Bridgend.
A wide variety of services are now provided through the mobile networks in Wales - voice and data (including SMS and MMS) provision through the second generation (2G) networks, to larger data transfer, including mobile broadband, through the third generation (3G) networks.
According to data available on the Welsh Assembly web site the overarching infrastructure strategy to date in Wales appears to have been to provide fixed line broadband access. However, Ofcom recently reported its Mobile Citizen, Mobile Consumers consultation that evidence about the rapid take-up of mobile broadband services is striking[1]. We therefore believe that mobile broadband, where practical and profitable to roll out, should also be considered as part of the overall solution.
There are many factors which contribute to the availability of mobile network coverage across Wales. These include license requirements, population density, topography and availability of potential mobile base station sites as well as the ability of the operators (or their planning agents) to obtain planning permission to build new sites. Therefore in considering mobile broadband as part of the overall solution, the following factors also need to be understood.
1. License
The mobile operators have met their regulatory obligation of providing third generation (3G) network coverage for 80% of the UK population. In Wales in 2007, 98% of the population were living in postal districts where at least one operator reports at least 75% 2G area coverage. At the same time, 68% of the population in Wales were living in postal districts where at least one operator reports at least 75% 3G area coverage [2]. Therefore, the mobile operators are an established sector in Wales and have demonstrated their commitment to invest.
2. Geography and population density
As acknowledged in the Ofcom Mobile Citizens, Mobile Consumers consultation, providing coverage in areas of mountainous and hilly terrain can incur higher costs for operators than in other areas. If population densities in these challenging environments are low (and as a result there is a low demand for mobile communications services) it may not be commercially viable for operators to build radio base stations and extend coverage to these areas.
In addition, radio signals can be affected by hills, trees, and tall buildings and because they are low powered the radio waves cover a limited area - no more than 2-5kms for larger "macro" base stations and only a few hundred metres for the smaller sites. Due to the topography of Wales, with its hills, mountains and valleys, there are many radio engineering challenges to address in order to build good quality mobile networks.
This is why operators have initially concentrated their efforts on those areas with the highest population density and therefore the highest levels of mobile phone usage. Mobile phone base stations need to be located relatively near to where people want to use their phones, handsets and other devices. This is why the networks are currently concentrated in urban areas and main transport routes.
3. Planning system
To continue to enable the deployment of radio base station sites, it is vital that the planning system in Wales continues to enable efficient and cost effective delivery of communications services to communities across the country.
The current telecommunications planning system in Wales, as in England, provides three categories of development - full planning, prior approval and permitted development.
Full planning
Full planning permission is required for masts more than 15 metres high and the operator is expected to provide a range of supporting documentation to justify the application.
The local authority is expected to deal with the application within 56 days and applications can be refused on a number of grounds including siting and appearance or loss of amenity.
Full planning permission is required for any mast, of whatever height, in National Parks, Areas of Outstanding Natural Beauty, Conservation Areas and other designated areas.
General Permitted Development Order (GPDO) - Prior Approval
GPDO covers ground-based structures up to 15 metres at the base of the antenna and antennas on rooftops that exceed the height of the building by more than four metres.
Operators are required to submit an application for prior approval which, as with full planning applications, must be accompanied by supporting documentation.
The local authority can refuse permission on grounds of siting and appearance but they must let the operator know within 56 days, or approval is deemed to have been granted.
Permitted Development
This category includes installations that have little impact on the environment in areas which are environmentally non-sensitive. This would include, for example, rooftop antennas less than four metres high or ancillary developments like cabling or small dish antennas. Operators inform local authorities one calendar month before installing the equipment. The local authority can comment on siting and design but they cannot refuse permission.
Code of Best Practice
In addition to the statutory planning regime, the operators have, since 2000, put in place a system of voluntary pre-application consultation, called the Ten Commitments to Best Siting Practice. The Ten Commitments is established in Wales as part of the Welsh Assembly Government's Code of Best Practice on Mobile Phone Network Development. The key aim of the Code is to ensure that local communities are consulted on proposals for new base station sites and are provided with information on issues related to network deployment ahead of the submission of a formal planning (or prior approval) application.
The operators approach is to try to ensure that networks are deployed in the most appropriate manner with as little disruption to local communities as possible. However, it is important to remember that base stations must be located close to where people wish to use their mobile phones and other mobile devices.
We believe that the current planning system in Wales offers the flexibility required to enable the mobile operators to respond speedily to increases in demand for mobile network coverage, capacity and services, while providing the correct controls on development that has the highest visual impact. It is vital that the planning system retains its current flexibility and that additional and unnecessary restrictions are not put in place that would affect the ability of the operators to continue to improve mobile coverage and capacity in Wales. Any further restrictions on permitted development rights for telecoms operators in Wales would be a disincentive to invest and could put Wales at a competitive disadvantage to the rest of the UK.
The ways in which commercial and non-governmental organisations contribute to digital inclusion in Wales
The rapid growth of mobile telecommunications usage across the country has made a significant contribution to digital inclusion Wales. With the deployment of the 3G networks has come a significant increase in the number of services that can be provided through the mobile networks. The clearest example of innovation in the mobile networks is the provision of 3G wireless broadband access.
Mobile broadband internet is a broadband-speed internet connection accessed via the 3G mobile networks offered. It enables users to access the internet via a laptop or desktop computer anywhere there is 3G network coverage.
This means that users do not need to have access to copper telephone wires or fibre optic cable used in most home internet connections and means that it is not necessary to pay line rental in additional to a broadband internet package. It also means that it is not necessary to install expensive telephone or cable lines into the home or office to access the internet.
Access is provided through a mobile broadband USB modem - providing a wire free way to connect to the internet at home, in the office and on the move.
As the recent Ofcom Mobile Sector Assessment notes: "a new wave of data-based services, including mobile broadband, promises to bring together two of the most significant features of modern communications: the flexibility of the internet and ease and immediacy of mobility." By continuing to innovate, the mobile network operators are making a significant contribution to digital inclusion in Wales.
It should be remembered that all of this is only possible through the provision of the infrastructure that supports mobile services. This infrastructure can only be easily deployed if the planning system does not put in place unnecessary barriers to development. Any assessment of the telecoms planning regime should take account of the economic and social benefits of high quality communications services in Wales. While the mobile operators cannot guarantee network coverage in areas of low (or even no) profitability, the planning system should not act as a disincentive to investment.
Anecdotal evidence provided to the MOA from the annual conference of One Voice Wales in 2008 suggested that in many parts of Wales, not only was there no mobile phone signal but that BT phone boxes were also being taken away. This left some communities at risk from lack of means to call for help in emergencies, and was damaging to local businesses that needed the accessibility provided by mobile phones. Councillors at the conference pointed out that the lack of broadband coverage in rural areas is hampering local and small businesses. Lack of communications links is a barrier to maintaining sustainable communities.
Examples of innovation in the mobile sector - enabling digital inclusion
There are many examples of the ways in which access to mobile communications enables an increase in digital inclusion across the UK (including Wales), while improving the efficiency and performance of many public services.
For example, through access to the mobile networks, ambulance services across the UK have been able to equip front-line crews with reliable connections to their central control unit and other emergency agencies. Mobile web-based links have helped to greatly increase ambulance crews' ability to access information instantly, without having to call back the central command centre. Mobile communications are helping to enable rapid response vehicles to coordinate emergency operations far more effectively.
January 2009
[1] Paragraph 3.101, Mobile citizen, mobile consumers, adapting regulation for a mobile wireless world [2] Ofcom Communications Market Report 2008 |