Memorandum submitted by Orange
Why do so many more base stations (masts) still
need to be erected?
Orange must continue to erect more base stations
throughout the UK for reasons of both "coverage" and
"capacity". Although geographical coverage is available
over a large part of the country, broadly providing mobile services
in areas where 99 per cent of the population live, gaps in coverage
(commonly known as blackspots) still occur, primarily as a result
of local topography.
Greater coverage gaps exist in rural areas,
outside the main population centres, but close to smaller towns
and villages where consumers still demand access to mobile services.
These gaps will mean that calls either cannot be made or will
be dropped or will not be of sufficiently clear quality. As a
result the service offered to consumers will be adversely affected,
which is why Orange is continuously filling these gaps to provide
the highest level of service.
More base stations are also needed to meet the
phenomenal demand for Orange mobile phone services. At the start
of 2001, Orange had 10 million customers (one in six of the entire
UK population), which is more than double the customer base just
one year earlier. In the final quarter of 2000, Orange gained
an additional 1.56 million customers, which is approximately the
same number of customers gained in its first three and a half
years of trading between 1994 and 1997.
The physics of mobile technology means that
each base station can only handle a limited number of calls at
any point in time and therefore the only way to meet this huge
surge in demand is by erecting more base stations. As more consumers
continue to demand access to mobile services, the number of base
stations must continue to rise in direct proportion and as a direct
Why will the extended use of full planning not
resolve current concerns?
Orange has no doubt that the extended use of
the full planning system, in place of prior approval will not
resolve the issue primarily because it will not achieve the aims
of many of those who propose it. Full planning will not address
any of the three main areas, which lie at the heart of the problem.
Firstly, it will not give the local community
any input into the site selection process, which is the most critical
flaw. Nowhere does the full planning process involve any direct
consultation between the community and the operator. It simply
allows residents to write letters of objection to planning officers
after the site has been chosen by the operator. Any effective
solution must involve direct consultation between the local community
(typically represented by the local authority) before the site
has been chosen, which is why all of the operators have recommended
that pre-application consultation between the operator and the
local authority be made obligatory on both parties.
Secondly, full planning will not give local
planning authorities the power of veto which some people appear
to believe it will deliver, as a result of a general misunderstanding
of the powers it involves. For example, it will not allow them
to introduce arbitrary exclusion zones around base stations. It
will not allow them to introduce moratoria over base stations
in particular areas. It will not allow them to force operators
onto a particular site of their choosing. It will not allow them
an automatic right of veto in areas where there is a high level
of public concern. As the perception is that these powers will
be available, Orange believes a sense of disillusionment and disappointment
will inevitably follow its introduction.
Thirdly, full planning will not provide any
answer to the health concerns which are fundamental to why the
public wants to be able to have an influence over radio base station
location. It is very difficult to resolve fears which are not
based on established scientific evidence and the planning system
is totally unable and indeed, not designed to solve this problem.
Simply changing a planning process will never get to the root
of the problem, if people do not currently accept the balance
of worldwide scientific evidence before them. Further research,
public information and education are the best tools available
to address this problem and some of the operators' commitments
suggest a way forward. The public must be given the ability to
place these risks in context and in comparison with the benefits
which mobile communications brings.
What will be the effect of this kind of increased
An increase in base station development regulation
will have three principal effects which might not always be readily
Firstly, it will result in a significant delay
to network rollout, primarily as a result of the removal of the
defined timescale and presumption in favour of development contained
in the prior approval system, which means applications may remain
undermined indefinitely. This in turn will result in more refusals
and therefore more appeals with the associated delay. In addition,
full planning applications take longer to process than prior approval
applications and so each individual application will take longer,
which will lead to an ever growing backlog and increasing delay.
Secondly, full planning regulation could lead
to severe capacity problems on current second generation networks
because it will become very difficult for Orange to address the
huge demand and consequent need for further base stations (as
outlined above), if every new application is subject to delay.
Even with current prior approval rights, the operators are finding
it difficult to erect enough radio base stations to meet current
demand and these delays will make this task even harder. There
is a very real risk that delay will begin to cause severe congestion
to the networks which will become increasingly noticeable and
frustrating to consumers wanting to make calls.
Thirdly, the delays resulting from full planning
will severely threaten the UK's leading position in telecoms and
related technology, particularly in relation to rollout of third
generation mobile networks. A mobile communications infrastructure
is central to remaining at the forefront of technology and the
congestion caused to the current networks together with the delays
and congestion caused to third generation networks will severely
threaten that position. The delays will mean that other countries
will be able to deliver third generation services to business
and consumers well in advance of the UK and the benefits gained
by being the first to issue third generation licences will be
Why will mast sharing not resolve current concerns?
In common with other operators Orange is obliged
to consider the use of existing masts, buildings and other structures
before erecting a new mast. If an application for a new mast is
to succeed, it must satisfy the local planning authority that
no existing structure is technically suitable. In addition, it
is often in Orange's economic interests to share existing structures
with other operators, particularly in more rural and remote areas
where the costs of power supply, installation and maintenance
can be shared.
However, mast sharing is not always the most
appropriate option for two reasons. Firstly the existing building
or other operator's mast must be in a technically suitable location
for the second operator. As each network is necessarily planned
independently, the location of an existing mast belonging to another
operator, may well not be positioned in the area in which Orange
has a gap in coverage. If Orange shares sites which cover only
part of the target area, other base stations will have to be erected
to cover the rest of the target area, which will lead to greater
Secondly, if a second operator shares another
operator's existing mast, the mast will invariably have to be
taller (usually 5 metres) and wider, to allow the second operator's
antenna equipment to be housed. In rural and more environmentally
sensitive locations, the local planning authority may not feel
a larger mast is the best option and it may decide two smaller
masts would be less visually intrusive.
Why will national roaming and satellite technology
not resolve current concerns?
It would be technically possible for a mobile
customer in the UK to roam between the existing four networks
(Orange, Vodafone, BTCellnet and One2One) using the network of
whichever operator has coverage in a particular area, in the same
way as happens when customers use their handsets abroad.
However, this would be tantamount to the nationalisation
of the mobile telephony industry, because it would effectively
create a single network available to all customers. This would
be extremely detrimental to the consumer by removing virtually
all competition in the industry, which currently incentivises
all of the operators to provide the best coverage and thereby
gain the most customers. National roaming would mean no operator
had any incentive to extend its coverage, because it would gain
no commercial advantage from doing so.
National roaming will have no effect in large
parts of the country where base stations are erected due to high
capacity demands because the same number of base stations will
still be needed to handle the high number of calls being made.
Calls will always be dropped, when a customer attempts to move
from one network to another. Many services will be unavailable
to customers when they move off their home network and they will
not know why. Call charges will increase, as customers will have
to pay roaming charges and inter-operator tariff confusion will
Orange is a licensed operator to provide mobile
telephony services on a certain part of the radio spectrum. It
is not licensed to provide satellite services. The difficulties
faced by others in providing mobile telephony services via satellite
have centred around the prohibitively high costs of both the handsets
and the calls; the large and bulky nature of the handsets; and
the fact that satellite signals cannot be received in buildings.
So far, it seems that satellite telephony has no commercial application
for the vast majority of users wanting to make calls in inhabited
parts of the world.
Why does Orange not participate in more pre-application
consultation with local communities?
Orange regularly writes to all local authorities
throughout the UK with details of its future rollout plans and
offering to give presentations to local authority officers and
members. Unfortunately, there has always been a very low response
rate and an even lower take-up of the offer of a presentation
and consultation meeting. This makes the task of early consultation
extremely difficult, but Orange is committed to continuing to
make such offers before every major rollout phase.
Orange has recently recruited community liaison
staff based throughout the country to meet and establish ongoing
relationships with local residents groups expressing concerns
about Orange base stations in their area. In conjunction with
the rest of the industry, Orange is in the process of implementing
a new consultation process, designed to complement whatever changes
to legislation the Government brings forward. The new process
will only work with optimum efficiency if local authorities are
prepared to provide input by indicating what type of consultation
is appropriate in individual cases.
However, Orange continues to face ongoing difficulties
in trying to conduct meaningful pre-application discussion before
sites are chosen and applications are submitted. Local communities
are often not interested in providing input and attending meetings
at an early stage in the process before it is known whether the
base station will be close to particular residences. Interest
is only aroused when the site is chosen and the application submitted,
which makes locating the best site at the outset very difficult.
Why will Orange not adopt a precautionary approach
and agree not to site base stations (masts) within a certain distance
of residential areas?
The uses and benefits of current and future
mobile telephony services are universally accepted and obviously
base stations must be erected in order for those services to be
available. Therefore it is crucial to have clear guidelines governing
where base stations can and cannot be erected. Orange believes
that these guidelines must be set by central Government, in the
overall national best interest and can only be based on substantiated
scientific knowledge, rather than arbitrary and unjustifiable
As a matter of precaution, the Stewart Report
recommended the adoption of the more stringent International Commission
on Non-Ionising Protection (ICNIRP) guidelines for public exposure
in place of the NRPB guidelines. The Government and industry accepted
this specific scientific precautionary recommendation, but do
not accept a general precautionary principle which sets no definite
limits and can be applied differently in every situation, to the
point at which it becomes meaningless.
Similarly, any guidelines set purely on the
basis of distance are equally meaningless and unjustified because
the only important consideration is power density, which will
vary enormously between a microcell and television transmitter,
which both emit similar types of electromagnetic radiation. Therefore
to state that both types of installation must be the same distance
from residential properties is entirely misguided and scientifically
What will be the effect of moratoria introduced
by local authorities?
Some local authorities have introduced official
moratoria not allowing any base stations to be erected on buildings
or land which they own. Some local authorities are operating unofficial
moratoria and are automatically refusing all telecoms base station
applications which they receive. This second type of moratorium
is clearly not permitted under the legislation.
Orange understands that local authorities feel
that they must respond to community concerns, which is why some
have decided not to allow base stations on their own land. However,
such policies do nothing to reduce the need for further base stations
to be erected, which results from the huge demand for mobile telephony.
They simply deny the operators a wider choice of sites and therefore
make the task of finding the most environmentally suitable site,
which satisfies the local community, even more difficult.
For example a piece of land or a building might
exist which meets the operators coverage requirements and is sufficiently
far from residential property to allay local concerns. However,
if the land belongs to a local authority, which will not accept
a base station, the operator will be forced to investigate other
less suitable sites. This could result in a taller more visually
intrusive structure elsewhere, or more than one base station to
cover the same target area or an installation closer to residential
properties. The local community would rightly object if an environmentally
less suitable solution had to be pursued purely as a result of
a local authority's blanket ban on use of its own land for telecoms
development. This would clearly not be in the interests of best
siting of telecoms infrastructure.
What new services will be available as a result
of further telecoms development?
Second generation enhancements and third generation
technology will significantly increase the type of services available
via mobile handsets. Handsets offering face to face video phones
calls, mobile video conferencing and e-mails sent with video attachments,
combining with all of the functions of an electronic personal
organiser will become the norm. Numerous kinds of location specific
information will be available as users move about, which is likely
to be the key attraction of the mobile internet.
There will also be a vast range of e-commerce
possibilities available via the handset (becoming known as "m"
or mobilecommerce) both from established websites and a
new range of sites which will be designed specifically to address
WAP capabilities. Media convergence will enable the download of
a vast array of different material from the internet directly
to the handset, including e-mails, music, film clips, news reports
and any other form of data.
Mobile phones will soon incorporate Bluetooth
technology, which via a very small low powered radio chip, will
allow any electronic device to communicate with any other device
up to a few metres away. Cables around the home and office will
become largely redundant and connectivity will become the key
as many devices become linked to each other and the mobile network.
As a result they will be controllable via WAP, text message, PDA/internet
or voice activation, whilst in the home/office or miles away.
What are the social and economic benefits of mobile
The development of new mobile phone tariffs
and services has been continuous in the last couple of years,
but the introduction of pre-pay packages has revolutionised the
market, opening it up to a whole range of people who had not previously
thought of themselves as potential mobile phone users. Pre-pay
tariffs are ideal for those on lower incomes and have been extremely
popular amongst consumers who had previously been concerned about
the open-ended nature of monthly charges of a mobile phone.
OFTEL has stated that the mobile market is characterised
by falling prices and that low usage customers on pre-pay schemes
have seen the biggest price reductions. Mobile phone operators
are reacting to the wishes of consumers by providing competitive
tariffs demanded by those who aren't high users. More people on
low incomes are deciding to swap their fixed phones for the cheaper
mobile alternative. The low cost and higher familiarity associated
with mobile handsets compared with PCs, may well mean that they
become the chosen method of broadband access for some people on
lower incomes, especially in rural areas where fixed broadband
access may not be available.
By creating a high speed digital mobile network
to complement existing fixed networks, mobile operators create
a framework for future development and growth. This allows businesses
to communicate with each other wherever they are, whenever they
wish and enables new working practices, such as homeworking. Mobile
communications make traditional business more efficient, and create
the conditions in which new business can flourish. A lack of coverage
is a serious disincentive to a business locating in a certain
area. Many businesses would find it extremely difficult to operate
today, without mobile communications and as the type of available
services increases even more businesses will come to rely on mobile,
as a crucial form of communication.
How calls are made and received
In order to run a network offering mobile services,
each operator is granted a licence to broadcast at a particular
frequency range within the radio spectrum. All other users of
the radio spectrum must be allocated their own part of the spectrum
to prevent interference occurring.
Mobile phones work by converting voice into
electronic signals and then sending and receiving these signals
to and from antennae that are attached to radio transmitters,
or radio base stations. They do so by using a part of the allocated
frequency range, known as a radio channel.
Therefore, in order for a two way conversation
to be held without interference from other calls, each call must
be allocated a radio channel at which to transmit and a radio
channel at which to receive.
However, the allocated frequency range can only
be divided into a limited number of radio channels, which means
only a limited number of calls can be made at any particular time.
If all radio channels are being used no further calls can be made.
In order to increase the number of calls which
can be made, the operator must re-use the same radio channel many
times simultaneously. As long as the same radio channel is not
being used on more than one call within the same geographic area,
interference will not occur and many calls can use the same radio
channel without affecting each other.
Radio base stations transmit and receive signals
to and from the mobile handsets and allocate the radio channels
to the calls being made. The area over which a single radio base
station transmits and receives is generally referred to as "cell".
Each base station uses a certain number of all
the radio channels available to the mobile operator in its allocated
frequency range. If all the radio channels in a particular cell
are being used, greater capacity can be created enabling more
calls to be made, by erecting another base station within the
existing cell and creating two smaller cells.
Therefore the way in which radio channels are
reused is by increasing the number of radio base stations, which
will always have to be multiplied in line with the number of calls
made by new customers who buy mobile phones.
As long as the base stations in these adjoining
cells are not using the same radio channels, more calls can be
made in the same area without causing interference.
Building a Networkobtaining coverage
In order to ensure that a call remains continuous
as the user moves around, the cells overlap slightly. When a user
nears the edge of a cell and enters the overlap area with the
next cell, the network will hand over from one base station to
the next once the new base station is providing a stronger signal.
The operator's network therefore is made up
of many overlapping cells covering the entire geographical area
over which coverage must be achieved.
However, radio signals will suffer interference
from any obstacles such as buildings, trees, hills and valleys
and therefore wherever these obstacles exist a new base station
must be erected to provide coverage in the area where signals
from existing base stations cannot reach.
Building a Networktransferring a call
Once a call reaches a radio base station, it
must be transferred across the rest of the mobile operator's network
and into the fixed line network or to wherever the call is being
Depending on where the base station is located
the call will be passed either through underground fibre optic
cables or via "point to point" fixed links which transmit
a "torch like" beam from one base station to the next
and require a direct line of sight.
By a combination of these methods, the call
may travel between several base stations, before entering a main
switching centre and then being passed off the mobile operators
network through the public switch telephone network.
Mast Sharing and Roaming
Mast sharing and roaming are often referred
to as means by which to keep the number of base stations to the
necessary minimum, but the distinction is not always clearly understood.
Mast sharing simply involves two or more operators
both placing their antenna equipment on the same mast, building
or other structure, thereby reducing the need to erect a new structure
in the same area, but not reducing the total number of antennae
required, as each operator still has an entirely separate network.
Roaming involves the customers of one operator
making and receiving calls on the network of another operator,
which has a commercial/billing arrangement with the first operator.
In theory, only one base station is therefore needed in any area,
which will be utilised by customers of all networks. In practice,
the capacity demands outlined above will mean that several base
stations will still be required and so in most cases there will
be no reduction in the number of base stations in any particular
8 March 2001