Small Cells – PIIT Response to consultations
Polish Chamber of Information Technology and Telecommunications (PIIT) welcomes the Commission’s initiative regarding Light deployment regime for small cells. The initiative includes the establishment of uniform technical requirements, the fulfillment of which will allow for easy and widespread use of small cells throughout the whole EU. Taking into account that small cells will be crucial to achieving 5G goals, the initiative is very desirable. However, the benefits of this initiative can be seriously diminished if the parameters of such access points would differ in different countries depending on the EMF limit used in the particular country.
Against this background we are concerned with last sentence in the following statement:
Small cells have lower power levels and thus overall electromagnetic fields exposure (EMF) would be distributed more evenly. In regard to EMF limits, the EECC refers to Council Recommendation 1999/519/EC. In particular, Article 45.2(h) of the EECC calls for consistency and predictability throughout the Union regarding the way the use of radio spectrum is authorised in protecting public health on the basis of the above Recommendation. Article 58 also provides that Directive (EU) 2015/1535 shall apply as regards draft measures of the Member States that would impose different requirements than those provided in this Recommendation in regard to the deployment of small-area wireless access points. However, the light deployment regime for small-area wireless access points shall be without prejudice to the adoption of such national measures setting stricter EMF requirements.
Small area access points (small cells) should be standardized across whole EU in a similar way like Wi-Fi access points or mobile phones (or other terminals). Such access points, by definition, have low output power what allows to use them safely (with a high safety margin). Differentiation of parameters of small cells would be an additional burden for countries that already suffer from low EMF limits. In addition it would undermine the benefits of the European single market.
It is worth noting that the problem is also noticed by the ITU which states (Supplement 14 to the K-series Recommendations, https://www.itu.int/ITU-T/recommendations/rec.aspx?rec=13643):
‘The EMF exposure limits below INCIRP or IEEE guidelines (as shown in the case of Poland), do not in most cases allow mobile network operators to fully leverage these new technologies. (...) Deploying small cells in hot spot areas will not be feasible as the current EMF exposure limits prevent placing a large number of small cells due to the short distance between antenna and people’.
Therefore we strongly encourage the European Commission to ensure that actual common/ harmonized requirements for small area access points (small-cells) are established and harmonized approach to EMF limits is ensured.
Polish Chamber of Information Technology and Telecommunications (PIIT) is the largest Polish chamber grouping entities from telecommunications and IT sectors.
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