DigitalES appreciate the opportunity to provide feedback to the Commissions initiative regarding the light deployment regime for small-area wireless access points and consider from an industry perspective that having harmonised rules applicable at European level and national level with simpler and consistent rules should create more transparent processes, increase the predictability of the deployments and reduce the administrative approval times. From a regulatory and administrative perspective this should lead towards scalable, repeatable, and streamlined planning and approval processes for the deployment of small-area wireless access points.
We therefore suggest that the regulatory frameworks to be defined to support the deployment of small cells must consider small cells similar to Wi-Fi access and thereby:
Adopt declarations of compliance instead of local/regional permits based on standardized size and installation requirements.
Benefit from simplified national infrastructure policies and design guidelines for
installation requirements and radio characteristics where categories of equipment can be declared and certified generically at national level
Follow the internationally harmonised small cell power classes when developing regulations related to compliance with radiofrequency exposure limits and accept declarations of compliance and do not require routine post installation measurement
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