By Erik Whitlock, Spencer Crawford White and Myriam Ayada
Mobile site deployment issues and consequences
The challenges for regulatory authorities in the governance of network deployment are everywhere, but especially relevant in much of the MENA region recently. In a high demand environment, it is imperative that the MNO has the ability to rollout networks quickly and efficiently, but at the same time complies with the appropriate standards for construction, zoning, sharing, health & safety and requirements to mitigate other public interest concerns.
Figure 4. Mobile Broadband Penetration in MENA (2015, Q4)
Experience has shown that in the context of heavy demand, regulatory vetting and planning processes for site deployment are often fast-tracked, circumvented or inadequately implemented leading to missed opportunities for infrastructure sharing, sub-optimal siting and issues for public health and safety.
In a typical scenario, after gaining the initial approval for roll-out, the MNOs focus on rapid deployment of network infrastructure in order to grab market share as quickly as possible and/or must meet legal obligations to achieve national coverage within an accelerated timeframe. Regulatory authorities have often not developed or, if so, not updated regulation concerning mobile infrastructure deployment. Permitting powers are also often diffused or in the wrong hands altogether. Regulatory authorities are therefore overwhelmed and struggle with suitable standards and compliance enforcement.
In the absence of clear process and local guidelines, the MNO may use other jurisdiction’s regulations as a benchmark. It may also try to rollout standard site designs through “managed services partners”, which is very usual practice in the Middle Eastern region, and therewith lose control and visibility of the standards, creating an environment.
Worse still, in the early years of competition, the perceived benefits of site-sharing are low, and new entrants often replicate siting very near locations of the incumbent.
As a consequence, we find a number of deployment problems such as:
Without safeguards and remedial actions the risks of these problems arising are also likely to be magnified in the future as the densification of the networks increases driven by increase data demand and new technologies. To avoid or minimize these issues, greater effort regulatory effort is required to optimise cell siting and enforce aesthetic, safety and environmental requirements.
Government regulators should, and often do, play a critical role in ensuring problems with mobile radio access deployment are avoided or minimised. The regulatory intervention in some cases is carried out ex-ante (before the problem happens) and in some cases ex-post (where the problem already occurred and a correction is necessary). In both cases there are number of key functions that regulators can fulfil, such as:
Be a single point for managing mobile site approvals (for permitting new and legalising existing sites). In many cases the approval processes involving different bodies such as municipalities, civil aviation authority, security agencies, environmental protection bodies, etc. can be frustrating and costly for operators to manage due to the different procedures, timescales and approaches used by each stakeholder. Such circumstances frequently result in operators not completing the necessary processes, gaining some but not all the authorizations required and deploying sites with no or partial approval. Sector regulators may have a role to play as a coordination body streamlining the processes and supporting the operators through the authorization cycle. Sector regulators could also advise and potentially troubleshoot or facilitate amendment of problematic processes in their peer government bodies – a role which would be difficult for any private entity to play. In these instances, the result is likely to be win-win, justifying the additional investment by the regulator in resources and processes and additional fees that operators would be willing to pay for the service.
Mandating and supporting site sharing arrangements. The case for increased tower sharing should be clear due to cost efficiencies (fewer towers to manage, sharing the cost of building and maintaining, etc.) and increasingly so due to the current densification required for capacity increase through more dense site builds). However, even if these justifications appear evident, in practice operators often do not appreciate the commercial opportunities for colocation, are incapable organizationally of such cooperation and/or have entrenched hostile positions towards working with their competitors. The regulator can often act as a neutral party promoting cooperation by developing a centralised data base that provides clear view of all the radio sites in the country (some of which might be non-telecom owned) and also creating certain rules of engagement between the operators involved. The regulatory remit could extend to a more interventionist level where the regulator could decide whether the application for the new tower is justified in light of existing shareable deployments and effectively “force” the operator to use a nearby tower that could co-host new equipment.
Creating and enforcing clear technical standards for mobile radio access structures. Many countries still lack clear structural, functional, aesthetic and operational standards for mobile site deployment. Of all those that do have the standards, fewer have developed verification and policing functions to ensure that the actual as-built structure (as opposed to as planned to be built) complies and continues to comply with the standards in the future (especially as new equipment and antennas are added/modified). Again, it may well be that the entity best place to define the comprehensive standards, making sure they are implemented and ensuring they are updated when new technology comes into force is the sector regulator.
To illustrate the kinds of regulatory intervention in the areas we have just covered we give three examples (two from European and one from Middle Eastern country) where our team has been involved in the recent years.
Ireland - An Bord Pleanála (Ireland Planning Authority) & ComReg
The authorities in Ireland decided long ago to pool resources and enforce a process for any telecoms siting and planning application. The regime ensures no site is built unless it is designed as multiple-operator, and that all existing site share options have been exhausted prior to approval. This principle has created a landscape with fewer structures and a set of arrangements that facilitates further technology improvement, achieves environmental benefits, improves aesthetics and reduces public concerns. Although the role of the sector regulator, ComReg, in this area is limited to ensuring that operators meet ICNIRP requirements in their licence conditions, it publishes site information on all sites that facilitates planning and sharing. Our support to the Irish market has involved the provision of both standards and structure designs for multiple operator solutions with detailed justification of coverage plots, population coverage and detailed montage planning drawings to support applications and solutions for the operators, in line with the planning requirements.
Figure 3. Ardfield Cynergy, Ireland Planning Stealth Wind Combination
United Kingdom – Local Authority Planning Councils & Ofcom
The UK has adopted a two type process to planning and zoning. Under the “licence notification” type single operator structures receive a 2 week application process for installations up to 15m (self-standing structures) or less than 2m above (rooftops). The second type is full GPDO Planning, which is roughly a 6 month cycle, including notifications to the local and public authorities, appeal procedure and community consultation to justify the requirement, explain the sharing arrangements and addressing public concerns. Ofcom itself plays no role in the regulation of mobile radio access sites, but acts as a clearing house of advice on planning and requirements. Our support to the UK market involves providing technical planning and management solutions for siting and zoning by way of structure selection, planning and detailing of drawings and application support with attendance of community consultation.
Figure 4. Build Survey Pearse = Stealth Solutions UK
Kingdom of Bahrain – TRA (Telecoms Regulation Authority)
In Bahrain there was a breakdown in the process of permitting and persistent lack of site sharing. Operators built new infrastructure outside of governance processes leading to instances of poor quality construction, health and safety concerns, redundant infrastructure and unsightly deployments. The solution our team provided included an initial consultation to bring the best of international practice, an audit of the existing infrastructure, design of a set of standards and documentation for technical and legal management, and the development of an organisation for annual planning, one-stop-shop permitting and public engagement. The new regime promises to solve legacy site permitting, safety and compliance, whilst incorporating an efficient functional structure and process for the future applications considering technology and MNO requirements.
The combined solutions of Salience and Delmec include the initial consultation and commercial assessment, technical audit and guidance, development, detailing and revision of both technical standards and regulation whilst also providing the supporting data tools and management facilities for a true end-to-end packaged or managed solution for the governance of radio access site deployment. The specific areas of expertise provided are:
Design of the regulatory framework:
Creation of a single or coordinated platform for supervising mobile site deployment:
Implementation and on-going compliance monitoring:
Outcome & Benefits
The key benefits of a governance solution include the following positive features of a site deployment regime.
Reduced MNO costs through increased site sharing and colocation
The design of effective regulation combined with the implementation of a unique data management support system are key factors to encourage and increase sharing among operators. Indeed, regulation can go so far as to mandate preliminary vetting of planned deployments for sharing potential exploiting the data management system as an enabler of sharing as well as approval, compliance tracking and reviewing (see figure below):
Figure 5. Governance process overview
Increase in value of tower infrastructure as a whole
By mandating proper documentation and standards compliance, the regulator can assist the industry in raising the value of its radio access infrastructure. This would be particularly beneficial should the industry be considering or preparing for the introduction of a common TowerCo.
Reduced safety concerns through more stable infrastructure, safer access to sites, RF compliant site design and implementation
Setting and enforcing standards is the primary public policy benefit. The regulatory regime must go beyond simple standards drafting and include monitoring and enforcement processes.
Improved aesthetics, reduction of visual presences of sites
Regulation can also enforce standards beyond purely engineering requirements. Implementation can be designed for the rectification of existing mobile towers as well as for sites going forward. The Salience and Delmec solution proposes the design of a GIS zoning that differentiates tourist, residential, commercial, rural and industrial areas. Based on this zoning, regulation can enforce sharing, optimal placement and camouflaging to improve the look of sites and differentiated by zone type. Examples of structural solutions are presented in the figure below:
Figure 6. New look of facilities possible with active regulatory intervention
The implementation of mobile site regulation is the best guarantee that radio access sites are compliant with technical standards and align with land-use requirements for any given jurisdiction. The Salience and Delmec solution incorporates the provision of audits to ensure that the sites are compliant with any build and maintenance requirement and the development of a fees system to cover the cost of the approval and enforcement regime as well as to incentivise operators to be compliant.
 For example, Ericsson anticipates a 45% CAGR over the 2016-2022 period. See https://www.ericsson.com/assets/local/mobility-report/documents/2016/ericsson-mobility-report-november-2016.pdf
 ANFR - L'observatoire 2G, 3G, 4G. http://www.anfr.fr/en/gestion-des-frequences-sites/lobservatoire-2g-3g-4g
 Antennes Mobiles. https://www.antennesmobiles.fr/index.php?geo&show
 GSMA Intelligence. https://www.gsmaintelligence.com/