Guidelines for the management of …...7.2. Installation & management codes 13 7.2.1....

Guidelines for the Management of Telecommunications Carrier Infrastructure & Radiofrequency Electromagnetic Energy in Office Buildings owned and managed by the Department of Housing and Public Works.

Guidelines for the Management of Telco Infrastructure & RF Electromagnetic Energy (EME) in HPW office buildings

Feb 2019. Page 2 of 34

Guidelines for the Management of Telecommunications Carrier Infrastructure & Radiofrequency Electromagnetic Energy in Office Buildings managed by the Queensland Department of Housing and Public Works. © 2018 Queensland Government, Department of Housing and Public Works

February 2019

Authors: siteXcell, Consultant Mr Roger Smith, Queensland Department of Housing and Public Works

For further information, visit www.hpw.qld.gov.au

Enquiries should be directed to: The Director Property Management Group Building Policy and Asset Management Department of Housing and Public Works GPO Box 2457 Brisbane Qld 4001 Email [email protected] Web www.hpw.qld.gov.au

mailto:[email protected]

http://www.hpw.qld.gov.au/



Contents 1. Purpose 5

2. Scope 5

3. Introduction 5

4. Definitions 7

5. WHO advice on mobile phones and health 8

6. Industry Roles & Responsibilities 9

7. Regulatory Framework and Standards 10

7.1. Current electromagnetic energy standards 10

7.1.1. AS 2772.2 –2016 11

7.1.2. ARPANSA Radiation Protection Standard Series 3 11

7.1.3. ACMA Required Electric Field Limits 11

7.1.4. ACMA Radio Communications Licence Condition Determination 12

7.2. Installation & management codes 13

7.2.1. Telecommunications Code of Practice 2018 13

7.2.2. Communications Alliance Deployment Code 13

7.2.3 ABCB Digital Building Telecommunications Access 13

8. Outline of RF EME Management processes 14

8.1. Carrier Roles and Responsibilities 14

8.2. Building Owner/Asset Manager Roles & Responsibilities. 15

8.2.1. Assessment of Carrier Proposals 15

8.2.2. Quality of the plans 16

8.2.3. Compliance with the Low Impact Determination 16

8.2.4. Carrier’s proposals to minimise the visual impact 16

8.2.5. Connectivity 17

8.2.6. Labelling of equipment/ warning signage 17

8.2.7. Power 17

8.2.8. Heating, Ventilation and Air Conditioning 17

8.2.9. Building penetrations 17

8.2.10. Dilapidation survey 17

8.2.11. Pre-construction and post-construction photo surveys 17

8.2.12. Revised EMEG 17

8.2.13. Electricity metering 17

8.3. Facility Managers and Operational Requirements 18

8.4. Site Management Strategies 20



8.5. Risk Management Strategies 20

8.6. Installation and Maintenance 20

8.7. Site specific facilities access management 20

8.8. Independent testing 21

8.8.1. EME testing during design and commissioning stages. 22

8.8.2. Testing Authorities and Scenarios requiring RF testing 22

9. Dispute process & timeline 23

9.1. Carrier installations and compliance objections 23

9.2. The Land Access Authority Notice Process 24

9.3. Liaising with the Carrier 25

9.4. Escalation within the carrier organisation (Non-LAAN Issues) 25

9.5. Reporting the carrier to the TIO, ACMA and/or the Minister 26

9.5.1. TIO 26

9.5.2. ACMA 26

9.5.3. Minister for Telecommunications (“Minister”) 26

10. Further information 27

Appendix 1 - Carrier Submission Checklist for Mobile Installations 28

Appendix 2 - Assessment of Maintenance Accessibility Impacts on Sites 30

Appendix 3 - Carrier Site Construction Checklist 31

Appendix 4 - EME Management process flow chart 32

Appendix 5 - LAAN Process and Timing 33

Appendix 6 - Web links 34



1. Purpose The purpose of this guideline is to ensure that a safe consistent, informed and effective approach is taken regarding management of Radio Frequency Electromagnetic Energy (EME) from telecommunications carrier installed infrastructure installed within buildings managed and owned by the Queensland Department of Housing and Public Works (HPW).

2. Scope These guidelines aim to provide support for DHPW Asset/Property Managers, Lease Managers, Owners and maintenance support staff as to the recommended processes and level of documentation required to allow the department to better manage risks associated with Telecommunications Carriers’ requests to install, repair and/or maintain telecommunication mobile phone infrastructure at HPW owned buildings. Use of the guideline may also be beneficial for lease mangers responsible for major leased buildings which have a Distributed Antenna System (DAS) installed internally within the building.

The objective of these guidelines is to ensure that the ongoing operation of the building and occupants is not compromised by these installations. The installations may include:

Mobile base stations – external coverage

• Base station equipment racks

• Power equipment and batteries

• Antennas mounted externally to the building

• Cables from the antennas to the base stations

• Fibre optic cabling into the building

• Equipment shelter or in-built equipment room

Distributed Antenna Systems – internal coverage

• Base station equipment racks

• Power equipment and batteries

• Antennas mounted internally in coverage areas

• Cables from the antennas to the base stations

• Fibre optic cabling into the building

• Equipment shelter or equipment room

3. Introduction These guidelines outline the regulatory framework for EME Regulation and recommended best practice procedures that should be adopted in EME Management and Safe Work near EME fields. The recommendations and strategies outlined within this guideline are expected to support HPW to meet its Workplace Health and Safety obligations to staff, occupants, workers and the public, including processes for dealing with Telecommunications Carriers in the current regulatory environment.



The guideline structure is set out in detail to provide advice with regard to;

• an overview of the various industries and their respective roles and responsibilities who have input into mobile phone telecommunication infrastructure regulations, standards, policy and safety frameworks.

• an overview of the regulatory framework, standards, codes of practice and ACMA licence conditions on which telecommunication are required to adhere to.

• an outline of the radio frequency EME management processes and responsibilities that should be adopted by the Telecommunications Carrier, building owner, Asset Manager & Facility Manager when assessing applications for installation, maintenance & on charging.

• an overview of the regulatory dispute process • recommended check lists to support review of telecommunications carrier applications with

regard to design documentation, maintenance impacts & installation. Chart 1 –RF EME Guideline Overview

While the mobile carriers are generally the most prolific users of radio transmitters in the built environment, there are several other civil and commercial operators of radio services that should be considered in managing EME on any site.

Telecommunications Carrier RF EME

ManagementGuideline Overview

LegislationTelecommications Act Telecommunications

(Low- Impact Facilities)Determination

Telecommunications Code of Practice

ACMARegulator for

broadcasting, the internet,

radiocommunicastions & telecommunications

Industy BodiesCommunications Alliance

Australian Mobile Telecommunications Association

AMTAThe Mobile Carriers Forum MCF

ARPANSAAuthority for

EME protection & safety

Dispute resolution process

CarrierTIO

ACMAMinister

Carrier License

ConditionsACMA LCD - RF Management &

Compliance

Standards, Codes, Industry Guides.

AS2772.2ARPANSA RPS3

ACIF C564 "Deployment of Mobile Phone Network

Infrastructure", ACIF G571 Building Access

Operations & Installation.ABCB "Digital Building

Telecommunications Access"MCF Distributed Antenna

Systems

RF EME Site Management

Installation & Maintenance

Access, Signage,LeasingPower & Air ConditioningSafe Work Procedures

Testing



4. Definitions ACCC Australian Competition and Consumer Commission

ACMA Australian Communications and Media Authority

Act Telecommunications Act 1997 (cth)

AMTA Australian Mobile Telecommunications Association

ARPANSA Australian Radiation Protection and Nuclear Safety Agency

CA Communications Alliance (formerly ACIF)

Carrier “Carrier” as defined in the Telecommunications Act 1997 (cth)

Code Telecommunications Code of Practice 2018 (cth)

EME Electromagnetic Energy

EMEG Electromagnetic Energy Guide (formerly known as the RCSMB)

FM Facility Manager

ICNIRP International Commission on Non-Ionizing Radiation Protection

LAAN Land Access Activity Notice

LCD License Condition Determination

MCF Mobile Carriers Forum

Minister Federal Minister for Communications and the Arts

NATA National Association of Testing Authorities

PPE Personal Protective Equipment

RF Radio Frequency - is the frequency range used in radio, extending from around 20 kHz to 300 GHz

RFNSA The MCF Radio Frequency National Site Archive

RPS 3 Radiation Protection Standard No 3– The ARPANSA Protection Standard for Maximum Exposure Levels to Radiofrequency Fields - 3 kHz to 300 GHz (2002)

RRL ACMA Register of Radio Licenses

Telecommunications carriers - Mobile, radio, wireless broadband and other licensed carriers, as defined by the Telecommunications Act

SWMS Safe Work Method Statement

SWP Safe Work Procedures

TIO The Telecommunications Industry Ombudsman

WHO World Health Organisation



5. WHO advice on mobile phones and health The World Health Organisation (WHO) have classified radio frequency EME as “Possibly Carcinogenic” and the WHO Website states in its Electromagnetic fields and public health: mobile phones: 8 October 2014 Key facts:

” Exposure levels-

Mobile phones are low-powered radiofrequency transmitters, operating at frequencies between 450 and 2700 MHz with peak powers in the range of 0.1 to 2 watts. The handset only transmits power when it is turned on. The power (and hence the radiofrequency exposure to a user) falls off rapidly with increasing distance from the handset. A person using a mobile phone 30–40 cm away from their body – for example when text messaging, accessing the Internet, or using a “hands free” device – will therefore have a much lower exposure to radiofrequency fields than someone holding the handset against their head.”

The Standard for EME Exposure is measured in milliwatts per square metre (mw/m2) and the environmental exposures from base stations located at a distance from a person are significantly below the standard. The Australian Radiation Protection and Nuclear Safety Agency (APRANSA) conducted a program of environmental measurements concluding that mobile phone base station environmental levels were at a very low percentage of the APRANSA RPS3 exposure standard.

The WHO website outlines its current recommendations on EME and health from mobile phone use. See http://www.who.int/news-room/fact-sheets/detail/electromagnetic-fields-and-public-health-mobile-phones.

The Australian Standard, ARPANSA RPS3 adopts the international standards for exposure limits to Non-Ionizing Radiation (NIR) that are provided by the International Commission on Non-Ionizing Radiation Protection (ICNIRP) in the "Guidelines for limiting exposure to time-varying electric, magnetic and electromagnetic fields (up to 300 GHz)", 2009.

See https://www.icnirp.org/cms/upload/publications/ICNIRPemfgdl.pdf

http://www.who.int/news-room/fact-sheets/detail/electromagnetic-fields-and-public-health-mobile-phones

https://www.icnirp.org/cms/upload/publications/ICNIRPemfgdl.pdf



6. Industry Roles & Responsibilities A number of industry bodies are responsible for management of Radio Frequency EME for both consumer devices and telecommunications facilities which are summarised in Table 1 below.

Table 1.

Industry Body Role & Responsibility Relationship

Australian Communications and Media Authority (ACMA)

Federal statutory authority and Australia’s regulator for broadcasting, the internet, radio communications and telecommunications.

Roles delivered through regulated licensing of radio frequency spectrum, licence conditions practises & standards, providing community information, products & services, provision of advice to government and representing Australia’s communications interests internationally.

Regulates RF EME exposure limits for consumer devices and telecommunications facilities by adopting the safe working limits outlined with the ARPANSA standard RPS3.

Manages the Telecommunications Register of Radio Licenses including licensee’s compliance records.

Manages the central register of industry codes, standards, requests, notices and directions as required under the Telecommunications Act

The Australian Radiation Protection and Nuclear Safety Agency (ARPANSA)

The Australian Government's primary authority on radiation protection and nuclear safety. ARPANSA protects the Australian people and the environment from the harmful effects of radiation through understanding risks, best practice regulation, research, policy, services, partnerships and engaging with the community.

Develop and maintains the Radiation Protection Series 3 (RPS 3) which sets limits for human exposures within the range of 3kHz to 300GHz as the applicable EME standard for Mobile sites.

Communications Alliance (CA)

CA provides a forum for the industry to contribute to policy development and debate & acts on behalf of the industry and its members with a specific focus in the areas of competition, innovation and industry development

Provides a range of standards and codes fostering business ethics and behaviour through industry self- governance and technical guidelines for the industry (e.g. cabling products, wiring rules, signage, & building access).

Telecommunications Industry Ombudsman (TIO)

Industry-based Ombudsman which is fully funded by industry fees and charges and not owned by the industry. Empowered to receive and investigate complaints about telephone and internet services, including by collecting any documents or information relevant to the complaint

Authority to decide the resolution of a complaint (the telecommunications company is legally obliged to implement) up to $50,000 and make recommendations up to $100,000. The TIO publishes position statements outlining its approach to handling particular types of complaints on subjects including but not limited to billing and contracts, connection and disconnection of services, credit management, service complaints and infrastructure.

The Australian Mobile Telecommunications Association (AMTA)

Peak national body representing Australia's mobile telecommunications industry which aims to promote an environmentally, socially and economically responsible, successful and sustainable mobile telecommunications industry in Australia.

Industry body that aims to generate consensus on whole-of-industry issues, improve the level of trust between the industry, related industries, key stakeholders and the wider community


Feb 2019. Page 10 of 34

The Mobile Carriers Forum (MCF)

A division of the AMTA and acts as an industry group representing the four mobile phone carriers deploying networks in Australia. Developed a range of initiatives, research programs and technical standards such as Safety Compliance Program, Design and Innovation Program, Information for Stakeholders, Working with Local Government, EME Information and Management & Community Consultation.

MCF manages the RFNSA database which holds consultation and EME information for all mobile sites in Australia. Issued Distributed Antenna Systems (DAS) specification for the in-building cabling, distribution and radiating elements (antennas &/or small cells) required for enhanced In-Building Coverage (IBC) for wireless services such as mobile phone services. This specification outlines design and acceptance into service requirements for a DAS by a Lead Carrier for the site.

As our reliance on mobile phones and radio systems increases and the allocation for spectrum to support these services is continually changing, the significance of correctly designed and certified Distributed Antenna System (DAS) is becoming more and more important.

The MCF, in consultation with the tier one mobile phone carriers (i.e. those who possess a network which they are the sole operator) have developed a DAS specification and a set of guidelines which outlines the design standards and acceptance criteria for such a system.

As outlined within the guidelines RF EME Management processes, it is strongly recommended that building briefs include the requirement that carriers are consulted and endorse the DAS during the design, implementation and testing stages before the system is handed over to the owner to mitigate potential issues with mobile phone spectrum assignments and technologies, lack of consultation with building owner contractors, poor workmanship, warrantees and carrier costs to fix and future proof the system.

For a copy of the current standard and associated guidelines see:

http://www.mcf.amta.org.au/Technical.Documents

7. Regulatory Framework and Standards 7.1. Current electromagnetic energy standards The ACMA and ARPANSA are the regulators of EME Exposure standards in Australia and these standards reflect international standards. The Global EME exposure standards are under regular review through the ICNIRP with EME measurement standards also developed by the IEC, IEEE, CENELEC, and the International Telecommunications Union (ITU).

These review forums are conducted internationally with significant participation from Australian government and industry and Standards bodies. The Australian EME Standards are normally harmonised with international standards as they evolve with the changing telecommunications landscape which are listed below:

• AS 2772.2 – 2016 – Radiofrequency fields, Part 2 Principals and methods of measurement and computation

• ARPANSA RPS3 • ACMA Required Electric Field Limits • ACMA Radio communications Licence Condition Determination.

http://www.mcf.amta.org.au/Technical.Documents


Feb 2019. Page 11 of 34

7.1.1. AS 2772.2 –2016

Australian/New Zealand Standard AS/NZS 2772.2 – 2016 Radiofrequency fields, Part 2: Principles and methods of measurement and computation—3 kHz to 300 GHz. This standard follows the international ICNIRP Guidelines and prescribes the requirements for evaluation of Radio Frequency fields.

7.1.2. ARPANSA Radiation Protection Standard Series 3

The Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) standard, Radiation Protection Series 3 (RPS 3) sets limits for human exposures within the range of 3kHz to 300GHz. As part of a range of radiation protection series documents these standards are focused on describing the limits for exposure levels experienced by a person working near radiating antennas. The standard outlines the following:

o mandatory basic restrictions for both occupational and general public exposures involving all or part of the human body

o indicative reference levels for measurable quantities derived from the basic restrictions

o approaches for verification of compliance with the Standard o requirements for management of risk in occupational exposure and measures for

protection of the general public.

A precautionary approach is included in these standards to ensure public safety and the RPS 3 Standard States: …

”In relation to the general public, the Standard, nevertheless, states the principle of minimising, as appropriate, radiofrequency exposure which is unnecessary or incidental to achievement of service objectives or process requirements, provided this can be readily achieved at reasonable expense. Any such precautionary measures should follow good engineering practice and relevant codes of practice. The incorporation of arbitrary additional safety factors beyond the exposure limits of the Standard is not supported.”

The standard also recommends protection measures for occupational and general public with generally held risk management protocols of Elimination, Substitution, Engineering Controls, Administrative Controls and PPE.

See https://www.arpansa.gov.au/sites/g/files/net3086/f/legacy/pubs/rps/rps3.pdf

For Explanatory notes also see:https://www.arpansa.gov.au/sites/g/files/net3086/f/legacy/pubs/rps/rps3_qa.pdf.

RPS3 is currently being reviewed to ensure coverage for the expanded Cellular Frequency bands being used by 4G and 5G services in the future.

7.1.3. ACMA Required Electric Field Limits

The ACMA has mandated that license holders must be able to demonstrate compliance with the ARPANSA Standard, RPS3. The standard outlines detailed basic restrictions for Electrical and Magnetic Fields (E&H fields) for exposure to radiofrequencies of 3kHz to 300GHz. These mandatory basic restrictions that are often difficult and impractical to measure and therefore reference levels of exposure are provided as a simpler means of demonstrating compliance with the standard.

The ARPANSA Standard RPS3 2016 specifies the mandatory exposure limits in terms of • Power Density 50 W/m2 (General Public) • E and H Field Densities (V/m and A/m) which are frequency dependent.

https://www.arpansa.gov.au/sites/g/files/net3086/f/legacy/pubs/rps/rps3.pdf

https://www.arpansa.gov.au/sites/g/files/net3086/f/legacy/pubs/rps/rps3_qa.pdf


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The most easily interpretable value is the percentage of the General Public Limit expressed in Watts/kg. The ARPANSA RPS3 Standard outlines basic restrictions for Whole Body SAR (Specific Absorption Rate) and Spatial Peak SAR. The table below outlines the Occupational and General Public Limits in W/Kg.

Exposure Category

Frequency Range Whole Body SAR (W/kg)

Spatial peak SAR in the Head & torso (W/kg)

Spatial peak SAR in the limbs (W/kg)

Occupational 100kHz-6GHz 0.4 10 20

General Public 100kHz-6GHz 0.08 2 4

To support licence holder’s obligations to demonstrate compliance to the RPS3 standard exposure limits the ACMA has developed a booklet “Human Exposure to Radio Frequency Electromagnetic Energy – Information for Licensees (October 2013)” which states:

“If you require the highest level of confidence that your transmitter complies with the ACMA's EME exposure limits, the ACMA recommends using an organisation accredited by the National Association of Testing Authorities (NATA) to assess radiofrequency field strengths”

In summary, EME exposure limits in Australia are regulated by the ACMA in Legislation by use of the ARPANSA RPS3 Standard. EME compliance is achieved by:

• keeping of records of transmitter details • modelling or measurement by a competent person – A NATA accredited person is

recommended. • provision of compliance documentation to be updated when significant changes to the

EME levels or locations are made

The ACMA EME compliance strategy can be viewed at: https://www.acma.gov.au/Citizen/Spectrum/About-spectrum/EME-hub/the-acmas-eme-compliance-strategy

In the case of mobile communications installations worst case modelling is used for all sites and this approach has been accepted by ARPANSA and the ACMA. The assessments do not expire, rather they require updating when an installation is upgraded and the EME levels or exclusion zones change. The ACMA and ARPAMSA do not require field measurements to validate the modelling by NATA Accredited Laboratories.

7.1.4. ACMA Radio Communications Licence Condition Determination

The ACMA Radiocommunications (Cellular Mobile Telecommunications Devices) Class Licence 2014 (LCD) has been implemented under the Radiocommunications Act 1992. This determination outlines the requirements of a license holder with respect to management of RF fields and the requirement to ensure that public exposures are within standards as prescribed including the ARPANSA RPS3 and methods of compliance though measurement or calculation. The LCD also specifies a requirement for license holders to keep records of conformity and compliance documentation.

The radiocommunications (Cellular Mobile Telecommunications Devices) class licence 2014 is available at: https://www.legislation.gov.au/Details/F2014L01794/Download.

https://www.acma.gov.au/Citizen/Spectrum/About-spectrum/EME-hub/the-acmas-eme-compliance-strategy

https://www.legislation.gov.au/Details/F2014L01794/Download


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7.2. Installation & management codes 7.2.1. Telecommunications Code of Practice 2018

The 2018 revision of the Telecommunications Code of Practice 1997 (‘Code’) aims to simplify and update the requirements on carriers relating to access for inspection, deployment and maintenance of telecommunications facilities on land.

The code of practice outlines the general requirements on carriers entering land for the purposes of implementing a licensed service. The Telecommunications Code of Practice 2018 is made under subclause 15(1) of Schedule 3 to the Telecommunications Act 1997 (‘Act’) and subsection 33(3) of the Acts Interpretation Act 1901 and is available at: https://www.legislation.gov.au/Details/F2018L00171/Download

7.2.2. Communications Alliance Deployment Code

The Communications Alliance Code “C564:2011 Mobile Phone Base Station Deployment” (CAC) is a binding set of requirements on carriers for engagement with the community on the deployment and management of mobile base station facilities. A major focus of the CAC is the requirements around community consultation.

In relation to EME on a new site or upgrade, Section 4.1 “Site Selection” calls out the following:

For new sites, once the preferred option has been selected, the carrier must make available to the public on request the summary of the sites considered and the reasons for the selection of the preferred option.

4.1.4 The carrier must comply with its procedures.

4.1.5 The procedures must require, as a minimum, that for each site the carrier have regard to:

(a) the reasonable service objectives of the carrier including:

(I) the area the planned service must cover;

(ii) power levels needed to provide quality of service;

(iii) the amount of usage the planned service must handle;

(b) minimisation of EMR exposure to the public

The CAC can be found at www.commsalliance.com.au

On this basis, it is reasonable that the carrier provides the following information with its site access request:

• design drawings to a commonly acceptable standard • general details of EME exclusion zones, controlled areas and signage • EME safe work and maintenance methodologies around exclusion zones • operations contacts.

7.2.3 ABCB Digital Building Telecommunications Access

The Australian Building Codes Boards has published a non-mandatory Handbook which fosters fundamental issues related to the management of access to multi-tenanted buildings by multiple carriers, carriage services providers and other involved in the provision of telecommunications services to tenants in buildings.

This handbook provides a guide to the types of issues that could be addressed in any building access agreement and sets out some optional terms and conditions for parties to decide in any agreement.

https://www.legislation.gov.au/Details/F2018L00171/Download


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8. Outline of RF EME Management processes 8.1. Carrier Roles and Responsibilities Management of RF EME is focused on ensuring currency of information on systems on a site and provision of clear documentation on the approachability of the regions around a transmitting antenna that exceed the limits prescribed in the mandated Radio Frequency Exposure Standard (RPS3).

All carrier requests to install and upgrade radio facilities on a site will need to have accurate documentation to be provided by the carrier for all aspects of the proposal and the current status of existing transmitters on the site. The carrier applications must include drawings, EME reports, procedures and specifications that outline the installation and continued operation of the carrier facilities. Further detail on how a carrier application should be presented is detailed in the following section Refer also check list “Appendix 4 - EME management processes flow chart “.

Most risks for exposure to transmitters can be easily managed through design of the transmitter installations to eliminate or minimise impact on other workers on the site. Generally, good design principles would involve height separation from the usual accessible spaces, use of signage and access restrictions where EME exclusion zones exist.

In order to manage these exposure limits a number of actions must occur. These include identification of:

• the RF exposure limits (or boundaries) by modelling or measurement • assessment of the approachability of the exposure limits

Management of exposures around transmitting antennas should follow the recommendations of RPS3 and include:

• access restriction to exposure limits • EME signage warning of the hazard outside of these limits • documentation to identify the location of the exclusion zones through documentation such as

EME guide reports • change management procedures to ensure changes to a transmitter do not exceed exposure

limits, and • safe work procedures for work near the transmitters including contact details (included in EME

Guide). Where in-building Distributed Antenna Systems (DAS) are installed to support wireless services such as mobile phones and public safety radio use, carrier endorsement of the design, implementation and testing stages of the DAS (in line with MCF technical specifications) is highly recommended to mitigate potential known issues relating to changes in mobile phone spectrum assignments and technologies, lack of consultation with building owner contractors, poor workmanship, warrantees and carrier costs to fix and future proof the system. Government building design briefs should therefore ensure that the mobile carrier and public safety radio requirements for in-building coverage provision are in line with the MCF technical specifications and the State Assessment Code with a specific requirement that the DAS be also endorsed by the carriers from the early design stages through to implementation and testing stages prior to building handover to the owner.

For a copy of the current standard and associated guidelines see: http://www.mcf.amta.org.au/Technical.Documents


Feb 2019. Page 15 of 34

8.2. Building Owner/Asset Manager Roles & Responsibilities. Regardless of whether the installation proceeds pursuant to a Land Access Activity Notice (LAAN) or by commercial arrangement, a key consideration is whether the Telecommunications Carrier’s installation or upgrade proposal complies with industry ‘best practice’ principles. In providing some substance to the concept of “best practice”, reference may be made to the Telecommunications Code of Practice “Part 3 Additional carrier conditions” that references the use of industry codes such as the Communications Alliance Mobile Phone Base Station Deployment Code. In clause 2.11, the code states:

2.11 Best practice In engaging in a land entry activity, a Carrier must ensure that the design, planning and installation of facilities (the Carrier’s facilities) is in accordance with best practice. For subsection (1), best practice is conduct of the Carrier complying with:

an industry code, registered by the ACMA under Part 6 of the Act, applying to the activity; or a standard, made by the ACMA under Part 6 of the Act, applying to the activity.

However, if there is no code or standard in force for the activity, best practice is conduct regarded by people constructing facilities substantially similar to the Carrier’s facilities as using the best available design, planning and location practices to minimise the potential degradation of the environment and the visual amenity associated with the facilities.

8.2.1. Assessment of Carrier Proposals

In assessing a carrier request for access to install radio equipment on a site the Facility Manager would be required to undertake the following three activities:

1. assessment of carrier proposal designs 2. development of lease agreements 3. development of FM management guidelines for service contractors and staff.

In undertaking an assessment of a proposal received from a carrier, central considerations include reviewing and assessing the:

a. Quality of the submitted documentation such as i. schematic diagram outlining the proposal ii. plans of the building areas showing proposals iii. elevation drawings of the roof areas and internal areas to be used iv. positions and type of EME and exclusion zone warning signage v. ensuring that the installation correctly falls under the definition of Low Impact-

such as the height of antennas (bottom not being higher than 3 metres and total height not exceeding 5.8 metres).

b. actions to minimise the visual impact c. connectivity details requirements for fibre optic cables etc d. power requirements and implementation strategy e. building penetrations and fire protection treatment where required f. equipment labelling scheme g. dilapidation survey h. site photographic survey pre-construction and post-construction. i. provision of a revised EME Guide post construction (or access to it through the RFNSA

website j. review of the safety management plans and high-risk activity.

These requirements are further detailed in the following sub sections. Some of the above considerations may be resisted by a carrier, particularly in the case under a LAAN arrangement, as the carrier may hold the view that the Act and the Code do not specifically or expressly refer to the requirements or stipulations referred to above.


Feb 2019. Page 16 of 34

This view may however be countered by the proposition that a reasonable and responsible landowner or Facility Manager should strongly consider the matters referred to above, as well as the fact that many of these points are listed in the Communications Alliance “G571 Building Access Installation and Operations Guidelines 2002” that has been approved or endorsed by all major carriers. These guidelines cover activities in buildings including:

• installation practices • pre and post installation surveys • working with owners on access arrangements

Refer also “Appendix 1- Carrier Submission Checklist for Mobile Installations “ for the recommended requirements to be included with a carrier submission.

8.2.2. Quality of the plans

The Facility Manager will require the plans to be presented by the carrier in an acceptable standard with full, clear and complete details of the proposed installation including all notes, specifications (e.g.: dimensions, number, types and sizes of equipment), engineering plans, certifications (including structural) signage and/or physical barriers for exclusion zones. The schematics should clearly and fully show the extent of the proposed installation, including the location of all equipment, structures and cabling (if for instance in risers) and how any cabling is to be supported, including attachments of all equipment to the roof. The elevation drawings of the building roof should also clearly and accurately depict the locations / heights of panels, masts etc to ensure that they comply with regulatory requirements for low impact and any WH&S issues with plant on the roof, such as access. In addition, the elevation drawings should clearly show the intended use of any internal areas of the building including risers’ equipment rooms and other spaces to be used for equipment. The general arrangement of equipment must also be clearly shown along with any licensed areas by dimensions and heights from existing features.

8.2.3. Compliance with the Low Impact Determination

It is important to review the primary points of the Low Impact Determination 2018 when reviewing the proposal from a carrier. As carriers are moving to increase the height of their installations for coverage benefits, it is recommended to ensure for instance that the length of the antennas does not exceed a total of 2.8 metres, and to the bottom of the antennas does not exceed 3 metres protrusion from the structure.

Also important is that certain heritage buildings are not considered low impact candidates, and carriers cannot serve a LAAN in that situation and would have to get council approval for a rooftop installation.

For further details, see the following link:

https://www.legislation.gov.au/Details/F2018L00170

8.2.4. Carrier’s proposals to minimise the visual impact The visual impact of the installation could break the outline of the building and affect its appearance. Solutions to minimise visual impact could include relocation of equipment and antennas away from prominent areas, screening can be used, colour-matching and painting the installation to camouflage the installation.

https://www.legislation.gov.au/Details/F2018L00170


Feb 2019. Page 17 of 34

8.2.5. Connectivity Connectivity of the equipment to the carriers wider network may require a number of radio link dishes and fibre optic cables. The proposal must include connectivity (known as backhaul) provisions such as fibre to the equipment (either new fibre lead-in or from existing wall panel or rack).

8.2.6. Labelling of equipment/ warning signage The carrier should outline the labelling guidelines to be applied to all equipment proposed to be installed. Also, a plan showing the type and location of EME warning signage should be included.

8.2.7. Power The carrier must detail the power supply method whether a separately metered or shared. Details of the type and location all power supply equipment is to be provided along with proposed building entry method, wiring layout and switchboard locations. Proposed earthing and lightning protection systems and connection to existing systems must also be detailed for the proposed installation. Any proposed use of the existing in-house power, reticulation, metering and cost sharing must be clearly outlined.

8.2.8. Heating, Ventilation and Air Conditioning

Carriers must provide any heat load to the existing building ventilation and air conditioning systems. Details should also be provided on the fire rating of equipment rooms and doors to meet fire standards.

8.2.9. Building penetrations All proposed building penetrations are required to be documented at the design stage. Full details regarding the penetration size, locations, structural certification and water/fire proofing certifications been provided and approved prior to installation. Also, the ACM register will need to be reviewed by the FM as part of the design stage, following regulatory protocols.

8.2.10. Dilapidation survey Prior to any commencement on site the carrier must undertake a dilapidation survey which includes photographic evidence of the status and condition of all areas to be impacted affected by the proposed installation and associated works.

8.2.11. Pre-construction and post-construction photo surveys Has the carrier provided a pre-construction photo survey and agreed to provide a post-construction photo survey in 30 days after construction is complete with both required as evidence of existing conditions and completion/reinstatement of works.

8.2.12. Revised EMEG

At the completion and commissioning of the installation by the carrier, the carrier Is required to provide an Electromagnetic Energy Guide (EMEG) for the works undertaken, whether a new or upgraded installation. Alternatively, carriers are providing access to the RFNSA database for the owners use in receiving the information relevant to the management of the site.

8.2.13. Electricity metering

It recommended that all carriers be required to install their own separate meters and have direct arrangements with power suppliers for the payment of their power usage.


Feb 2019. Page 18 of 34

There may be isolated times when this is not possible, and if the carrier provides a valid reason why it cannot connect directly to mains power via a separate meter, an alternative for an owner is to have the carrier install a check meter, with all their usage reimbursed to the owner. This approach incurs management administration time to read the meter and invoice, as well as track and collect the funds, so this option should be only used as a backup solution. It is important to remember that whenever a carrier is installing or occupying the space under their statutory access powers, for instance through a Land Access and Activity Notice, any financial losses incurred by the owner (such as power charges) should be invoiced to and reimbursed by the carrier, per Schedule 3, Clause 42 of the Telecommunications Act 1997 (cth).

8.3. Facility Managers and Operational Requirements Operationally a common issue is the continuity of focus from Facility Managers which stems from a lack of awareness of EME issues and management. Site inductions should include a comprehensive focus on the management of work near EME sources on or near the site as would be done for other hazards such as High Voltage, Work at Heights or Legionnaires disease. It is also important for site owners to ensure there is continuous operational management of EME Safe Work on site particularly when the Facility Management staff or outsourced Facility Management partner is changed. An integral part of all site inductions by the Facility Manager is the use of the EME Guide which is to be provided by the carriers as mentioned above. An RFNSA login should be provided to the Facility Manager by the carriers on site to download the most current version of the document. The EME Guide is developed using conservative power levels to ensure that it the document only requires an update when the equipment is upgraded and the EME zones have changed. As operational procedures for Safe Work around RF Transmitters are a compulsory requirement of National and State Workplace Health and Safety legislation employers must make themselves aware of all hazards and ensure controls and ensure that appropriate training is in place. Facility Managers must also develop appropriate inductions to ensure that all workers are aware of all hazards and the appropriate controls once the information and intentions for the incoming party is known.

In assessing a carrier request for access to install radio equipment on a site the Facility Manager would be required to undertake the following three activities being:

1. assessment of carrier proposal designs 2. development of lease agreements & 3. development of FM guidelines for service contractors and staff including:

• EME awareness briefings and training • Interpretation of EME signage • Records of access near EME zones • Use of personal RF monitors.


Feb 2019. Page 19 of 34

The key steps for working safely near antennas are:

1. CHECK

Check for Transmitters on or near the site • Visual Check, RFNSA Database and ACMA Register of Radio Licenses • Consult the Facility Manager or Carrier on Site

2. PLAN

• Plan – Prepare a Safe Work Method Statement • Ensure Training and Inductions are undertaken

3. ASK

• Ask the Facility Manager or Carrier for Help 4. LOOK

• Observe Safety Signs (see examples below) 5. BE SAFE

• Safety for all activities • Stop if there is uncertainty and seek assistance

This information is available on the MCF RFNSA Safety page and in the RadioWorkSafe.com.au mobile app.

Examples of RF safety signs:

The most commonly used sign Example from field inspection

Other examples from field inspection. Restraining chain and warning sign


Feb 2019. Page 20 of 34

8.4. Site Management Strategies

Site management of radio frequency telecommunication facilities can be implemented from the initial design and siting throughout the lifecycle of the tenancy. The Asset Manager/Owner and the Facility Manager should review the initial carrier design to ensure minimised effects on day to day operations such as window cleaning and maintenance of roof spaces, air conditioning, MDU operation, building signage etc.

8.5. Risk Management Strategies

As mentioned above, the application of safety in design principles will greatly enhance the ongoing operational management of EME sources on a site.

The safety in design processes employed by the mobile carriers to include modelling of the EME exclusion zones and assessment of the impact on spaces accessible by the general public and workers to ensure that the risk to exposure above the standard is minimised. The outcome of this pre-construction assessment is that the placement of antennas and transmitters will remove the need for other administrative controls and limits on maintenance of building facilities. A design proposal should be reviewed by the Facility Owner or Manager for any operational impacts, human and environmental to review the design prior to acceptance.

8.6. Installation and Maintenance

Risk minimisation through design is essential to ensure that building maintenance is not unduly impacted. See “Appendix 2 - Assessment of Maintenance Accessibility Impacts on Sites “, for a checklist of issues to consider when reviewing the carrier proposal or LAAN.

Workers undertaking construction and maintenance near any radio frequency source will require training in EME awareness and how to use the EME site safety documents provided by the MCF or other transmitter operators.

Additional strategies that can be applied include:

• ensure a well-documented and communicated contractor access protocol • regular check in with carriers and radio service operators occupying a site to ensure that

business hours and emergency contact details are current • site audits to ensure safety and access restrictions and signage are in good working order • clearly documented and agreed process for maintenance and upgrade activities • EME emission survey conducted by a NATA accredited body.

8.7. Site specific facilities access management As a general rule, the Facility Manager should ensure that all work on site is undertaken in a controlled and structured manner. To manage operations on site, the Facility Manager or Site Manager should ensure the following is incorporated into building operational procedures relating to telecommunication services:

● Securing of all accesses to the roof to ensure no unauthorised access occurs ● Warning signage of the presence of EME equipment at all entry points to the roof ● Hazard register ● Tenant details ● Emergency contacts of all attendees, as well as and photo ID ● Register of access and activity on site- including drawings and descriptions ● Training requirements and for specific hazards for contractors ● Hazardous materials handling ● Personal protective equipment ● Work at Heights – accreditation, anchor points, scaffold, EWPs, and access plant


Feb 2019. Page 21 of 34

● SWMS requirements ● Traffic management ● Waste management and disposal ● Insurance certifications. ● Review of the Building Management Plan for asbestos containing material and or lead paint

risks.

There are many commercial and on-line systems that can support these requirements for contractor compliance.

Also see “Appendix 3 - Carrier Site Construction Checklist “ which is recommended to be used when a carrier or their agent requests access to maintain or install per the agreements reached by commercial agreement and a licence, or the LAAN process.

8.8. Independent testing The following are approaches that an owner can take if it is believed or there are concerns that an area may have an issue with EME exposure.

As mentioned elsewhere in the report, independent EME testing is not required by an Owner as a matter of course, however if there are EME concerns in the workplace, then the suggested steps to resolve suspected EME issues are listed below:

1. Typically, a complaint or a visual perceived EME threat or issue is reported to management by a visitor, staff or a maintenance contractor.

2. As instructed by management, the FM or responsible department should review and investigate the details of the perceived EME threat by visiting the area, whilst adhering to the safety protocols contained in this report.

3. If the issue can be physically sighted, the FM (or other responsible party) should identify the carrier involved. If a carrier or the issue cannot be identified, refer to the building specific EME Guide to investigate further.

4. If the carrier cannot be identified via the EME Guide, then a check of the ACMA register is required to identify all carriers on the site creating the issue.

5. Once the carrier has been identified, contact the person identified in the EME Guide, or forward a letter to the General Counsel of the carrier describing the situation. If the carrier cannot be identified, write to the General Counsels of all carriers on the site, describing the issue and requesting immediate rectification of any noncompliance EME issues. Attach photos and provide details as necessary in the correspondence. A suggested timeframe for the carrier to be requested to respond is 10 business days.

6. If the carriers do not respond or deny that their systems are involved with the issue, the most prudent approach is to contact and commission an independent NATA approved testing lab as described in this report. If there are noncompliance issues noted in the testing report, formally inform the offending carrier (via the General Counsel) that they are to immediately rectify the violations. Once the results of the testing are known and any carrier rectification works are completed, inform any party that made the original complaint of the results of the project to address their concerns.


Feb 2019. Page 22 of 34

8.8.1. EME testing during design and commissioning stages.

EME testing is commonly undertaken to evaluate and understand the EME around new radio equipment installations and high-power broadcast services. The precautionary approach to modelling and assessment of EME fields is to use the maximum output power and gain from the antenna to cover all circumstances. The carriers rely on NATA Accredited modelling assessments for their sites as a rule and will only measure where there are high powered broadcast services that impact the carrier’s equipment. A reassessment is required where changes are made to the site that change the EME zones. High powered services such as an FM radio broadcast may require measurements to define the EME exclusion zones where modelling is not practical for technical reasons (such as frequencies lower than 100MHz) A NATA accredited measurement agency is recommended in these circumstances.

8.8.2. Testing Authorities and Scenarios requiring RF testing

ARPANSA have undertaken field measurements to verify that the higher levels of measured radio frequency EME due from mobile base stations was within the public exposure limits set by the ARPANSA radiofrequency exposure standard RPS3. These measurements were also compared to the predictions made in the Environmental EME Reports relevant to the sites measured.

All licensed radio communication carriers including the mobile carriers are compelled by the License Condition Determination to design their services to ensure the general public exposures remain within the ARPANSA regulated limits. As noted above, many instances of in-building RF level measurements have identified the closest transmitters as the major source of RF levels but again well below regulated standards.


Feb 2019. Page 23 of 34

As a rule, broadcast services require a height greater than surrounding structures, buildings and topography to service a coverage area and while mobile services are generally lower in built up areas, they cannot provide coverage to the target area if the antennas are directed into a nearby building, and as a result in building levels from nearby sites are generally low.

Unlicensed cCarriers using the Wi-Fi and ISM Band equipment (e.g. Cordless Phone systems) are power limited and generally no RF Hazard exists with this equipment.

Where the department or the Facility Manager has been requested to take measurements as a result of a Health and Safety enquiry, it is recommended that a NATA Accredited Test Laboratory be engaged to undertake these tests. Typically, these tests involve the measurement of EME Levels in publicly accessible spaces in buildings and external to validate the levels meet the RPS3 standard. A test report is the usual verification evidence provided by the agency.

Non-Carrier Transmitters could also be assessed in the same way and a site owner may mandate that process for all of its RF producing tenants that are not licensed Mobile Carriers. Operators of radio-based internet services and security systems should be requested to outline the EME from their equipment.

The ARPANSA Standard nominates field measurement and calculation modelling as an acceptable means of demonstrating compliance to RPS3. The yellow exclusion zone used as part of the EME Guide is the modelled maximum extent to the area exceeding the general public exposure limit and therefore there are no other areas that require further validation.

9. Dispute process & timeline 9.1. Carrier installations and compliance objections

In ensuring that all installations and upgrades on site are documented, the Facility Manager should require that all works proposed by a carrier are fully set out in plans in a written work request. The form that the work request should take will vary depending on the nature of the work proposed. Similarly, the processes to be worked through and ultimately any objection or escalation avenues available will vary depending on the nature of the proposed works.

In general, work requests may be categorised as:

1. Installation works – subject to the nature of which, may require the carrier to either:

Serve a Land Access and Activity Notice (“LAAN”) in the case of low-impact installations – governed by the Telecommunications Act 1997 (Cath) (“Act”) and the Telecommunications Code of Practice 2018 (“Code”), or preferably;

By submitting a proposal – to be subject to commercial agreement being reached between the carrier and HPW and typically documented in formalised tenure documentation between the parties (Preferred approach). The departments Legal Services unit has a suite of documents suitable for leasing or licensing arrangements (or permits) that should be used for any proposed low-impact facilities (and tower installations) to ensure that the departments risks, and interests are adequately addressed.

2. Maintenance/repair works – which may be instigated at the request of the carrier and/or

be a response to work, health and safety (“WH&S”) issues and/or shutdowns. If the equipment, the subject of the maintenance works, was installed pursuant to a LAAN, then any subsequent maintenance works may similarly only be undertaken pursuant to the service of a maintenance LAAN by the carrier.


Feb 2019. Page 24 of 34

Carriers or their agents accessing an owner’s property should utilise one or the other methods of formal documentation before entering an owner’s land. Failure to provide an adequate level of documentation may potentially expose the owner to increased liability risk as a result of the carriers initiated works. The process involved in the assessment, response and objection to each of the above formal documentation scenarios is set out below. Any failure on the part of the carrier to provide documentation in accordance with the matters referred to above under a LAAN scenario may be regarded by an owner as a failure by the carrier to comply with its obligations under the Act and treated accordingly. An overriding principle governing the above evaluation and assessment is referrable to one of the central objects of the Act which is “to provide appropriate community safeguards in relation to telecommunications activities and to regulate adequately participants in sections of the Australian telecommunications industry”. In doing so, the guiding principles are whether, in exercising a power, a carrier has complied with the following conditions:

• is the carrier / proposed works doing as little damage as practicable; • is the carrier acting in accordance with good engineering practice; and • is the carrier complying with recognised industry standards?

In the case of a commercial proposal, the above considerations should be adequately addressed in the proposal and plans submitted by the carrier. In the event of the carrier falling short on any of the above points with a LAAN, then the matter ought to progress in accordance with the LAAN process set out as follows and within the “Appendix 5 - LAAN Process and Timing ” flow chart. Critically however, in the case of a network failure or other emergency network access, the carrier must be granted access as soon as possible.

9.2. The Land Access Authority Notice Process Where a LAAN has been served by a carrier in respect of the installation of a low-impact facility or to maintain a facility, an objection to the installation of a low-impact facility may only be based on the following grounds:

• the use of the land for the installation; • the location of a facility on the land; • the date the carrier proposes to start the installation, engage in it or stop it; • the likely effect of the installation on the land; and • the carrier’s proposals to minimise detriment and inconvenience, and to do as little damage as

practicable to the land. In addition to falling under one of the categories referred to above, an objection must be made in writing to the carrier who must be given at least 5 business days before the carrier proposes to engage in the activity. The carrier must have given at least ten (10) business days’ notice of the proposed activity. On receipt of a written objection, the carrier must:

• make reasonable efforts to consult with the objector (within five working days after receiving the objection) to resolve the objection;

• respond to the objection in writing; and • attempt to resolve the objection and, where an objection cannot be resolved, refer the

objection to the Telecommunications Industry Ombudsman (TIO) when requested to do so by the Asset Owner/Manager.


Feb 2019. Page 25 of 34

If the objection is not resolved within twenty (20) business days after the objection was raised, the objector may request the carrier to refer the matter to the TIO. The carrier must comply with such a request. On a matter being referred to the TIO, the TIO may investigate the proposal and ultimately may issue a direction to the carrier about the installation. A direction issued by the TIO may relate to the way in which the carrier should engage in an activity, and where it issues such a direction the carrier must comply with that direction. If the carrier is proceeding pursuant to commercial arrangement, the nature and progression of the assessment and ultimate ‘objection’ options available are different and the regulatory timeframes and requirements referred to above do not apply.

9.3. Liaising with the Carrier To the extent that the carrier has failed to meet any of the requirements referred to above, either during the LAAN process or post installation, the carrier should be notified in writing of the failure, with any such notification clearly and succinctly and within the defined timeframe:

• identifying the perceived deficiency • specifying what is expected and/or required to address the deficiency • (other than in the case of a LAAN) nominating a reasonable timeframe within which the

carrier will be required to address the deficiency (that is, the timeframe within which the carrier will be required to produce the requisite documentation).

The first two bullet points above apply regardless of whether the proposal is a LAAN or a commercial proposition. In the ordinary course of the activity, subject to the nature and complexity of the deficiency (or deficiencies) identified, a reasonable timeframe within which to resolve objections would be regarded as being no more than twenty (20) business days from the date of the notification. This period may involve the carrier submitting revised documentation and being requested on one or more occasions to further revise or supplement the documentation produced. Although strictly speaking no timeframes apply to proposals proceeding by commercial arrangements, it is not unreasonable to expect a carrier to address issues raised within the above timeframe, depending on the carrier’s deployment timeframes. The timeframes that apply to the resolution of objections in the case of a LAAN are detailed above.

9.4. Escalation within the carrier organisation (Non-LAAN Issues) In the event that the period stipulated in the notification referred to above is not complied with and the liaising carrier representative has failed to give a reasonable explanation to resolving the issues, or that resolution is forthcoming, the issue may be referred and/or escalated to the attention of the carrier’s general legal counsel in writing. When escalating to the carrier’s general legal counsel the notification should clearly articulate the deficiencies that have been identified or remain and the action that has been taken to date to address the deficiencies. This notice should also nominate a date by when the carrier is required to address the deficiency/deficiencies and clearly indicate that matter will be referred to the ACMA should the carrier’s non-compliance persist. Generally, once the matter has been escalated to the carrier’s general legal counsel a matter tends to progress to a resolution with the carrier providing the documentation required and sought by the building owner, landlord and/or tenant. It is noted that escalation to the carrier’s general legal counsel would not apply in the case of a LAAN, but rather with an existing occupation due to non-compliance (tenure breach, non-payment of rent, WH&S, etc)


Feb 2019. Page 26 of 34

9.5. Reporting the carrier to the TIO, ACMA and/or the Minister In the event that liaising with the carrier representative and/or bringing the matter to the attention of the carrier’s general legal counsel does not elicit a prompt resolution by the carrier, then the matter may be referred to the TIO (in the case of a LAAN) or the carrier may be reported to the ACMA and/or a submission made to the Minister (in the case of non-compliance). The core functions of each, as relative to the processes referred to above are:

9.5.1. TIO

If in the case of a LAAN, the owner has objected to a carrier activity and it has not been resolved between the parties, the Act and Code provides for the TIO to review and provide their determination on the matter. The general manner in how a LAAN related complaint/objection that has not been resolved with the carrier is forwarded to the TIO, is as follows:

• If the owner objects to the activity and the carrier refuses to change the activity as described during the consultation period (after a total of up to 25 business days), and remains unresolved, within 5 business days after receiving the acknowledgement from the carrier that they are not changing the activity, the owner may request that the carrier refer the matter to the TIO for determination.

• The carrier is then required to forward the information to the TIO. The TIO will also generally request information from the owner to corroborate or dispute what the carrier has provided.

• Whilst the matter is with the TIO awaiting their determination, the carrier is not entitled to access the property to perform the activity.

• There is no timeframe for the carrier referring the matter to the TIO, or the TIO’s response, and it may take months for the matter to be determined by the TIO, which will be either the carrier can proceed as proposed, or they must make changes to the activity.

9.5.2. ACMA

In matters where a carrier is refusing to comply with the Act (including WH&S issues), and the matter has been escalated to the carrier for resolution without satisfaction, the escalation procedure is typically to write to the ACMA. In reporting a matter to the ACMA (that is, making a complaint to the ACMA), the complaint must be made in writing and must specify against whom the complaint is made and the details of the complaint, as well as the rationale for the issuing of the complaint. A reason for instance, may be that the carrier is not complying with the terms of the Act. Receipt of a complaint will then instigate an investigation by the ACMA, with the ACMA thereafter dictating the progression of the investigation after that point, including any further submissions to be made by either party.

9.5.3. Minister for Telecommunications (“Minister”)

The Minister has responsibilities including those relating to broadcasting, the information and communications technology industry, the information economy and telecommunications generally within Australia. Some parties have been copying in the Minister’s office to ensure that all parties have visibility of carrier practices that appear to violate the current regulatory environment that is meant to protect the public and owners. Whilst the above are suggested steps to resolutions whereby a carrier has failed to act or remedy a situation, with all of these examples it is important to ensure that an owner has acted in good faith, and that an owner can demonstrate that they made a genuine effort to attempt to resolve the issue with a carrier. ACMA and the Minister’s office have the authority to enforce the Act and would forward their directions to the carrier that has been reported.


Feb 2019. Page 27 of 34

It is also important to understand that reporting a carrier to the ACMA is something that most carriers would strongly try to mitigate, so it must be clear that if any valid violations persist, that a carrier is formally warned that they will be subject to reporting to the ACMA by the Owner.

10. Further information Refer to Appendix 6 for web links referred to in the material contained in this Guideline.


Feb 2019. Page 28 of 34

Appendix 1 - Carrier Submission Checklist for Mobile Installations No Item Received

Yes/No Quality

High/Low Additional Requirement/Comment

1 Plans – Submission of detailed plans Location details Equipment room/shelter/rack layout Cable trays and supports Antenna mountings Ancillary equipment mounts Environmental Assessments – Visual, noise Specialised Reports (Heritage, CASA etc) Note: Heritage buildings are not Low

Impact Access controls – locked door, gates, fences etc

2 EME Documentation Environmental EME Report - % of Standard General environmental levels EME Exclusion areas around transmitters Diagrams showing access restriction

3 Installation Scheme – Full extent of proposed installations Traffic management As applicable Installation methodology and scheme Materials and Equipment delivery/storage Power and Water As application for construction Waste Management - water, waste & emissions

3 Floor/Roof Plans of each area requiring installation Plans of each level to be worked (To scale) Dimensions for install to existing features Identify areas affected by installation Identify any physical barriers to be installed

4 Elevation drawings Elevations from each side of the building Clearly shows the installation (including risers) Accurate dimensions showing heights of

equipment Rooftop installations only

5 Engineering Design and Certifications Assessment and design of all structures Electrical design including separate metering, or

check meter for reading by the Manager New installations

Earthing and Lightning Protection design Structural engineering certifications – slabs,

retaining structures, mounts, etc

For in-building distributed antenna systems. Seek confirmation of endorsement of design and installation in line with MCF technical specifications and soft copies of as built installation documentation.

6 Minimised Visual Impact Rooftop installations only Screening Painting

7 Connectivity – Fibre optic and radio links Cable route and containment including risers

and internal rooms

Antenna placement Link Path clearance from usual building uses Roof installations only

8 Power Connections Cable route and containment Switchboard installations/location Separate Meter Earthing scheme

9 Building/Roof penetrations Locations Size and number Fire stopping treatment details Treatment- including roof surfaces/penetrations Roof installations only

10 Labelling scheme for equipment and cabling Signage – Type and location of signs


Feb 2019. Page 29 of 34

Carrier Site Identification signs Safety signs EME Safety signs including exclusion zones

11 Photographic survey Pre-Construction Surveys Post Construction Surveys

12 Pre and Post Inspections and Surveys Coordinated with Site Facility Manager

13 Maintenance Plan Access requirements - Business /After Hours Parking, noise dust etc Carrier Contact details Cyclic Maintenance Procedures & Frequencies Fault Maintenance Procedures Safety Inspection Procedures & schedule


Feb 2019. Page 30 of 34

Appendix 2 - Assessment of Maintenance Accessibility Impacts on Sites

No Item Received Yes/No

Additional Requirement/Comment

1 Rooftop Access e.g. Locked Door – EME Induction required 2 Air Conditioning Plant e.g. Overhead RF Exclusion Zones – Induction 3 Lift Motor Room Access e.g. Overhead RF Exclusion Zones– Induction 4 Building Maintenance Unit (BMU) access e.g. Potential impact on BMU Operation? –

Design change 5

Window Cleaning – BMU or Rope Access E.g. RF Exclusion zones on walls or Parapet –

Design change to elevate antennas clear of accessible areas

6 Plant and Facade maintenance Arrange for shut downs where work is required close to the exclusion areas

7 After-hours access Agreed access arrangements


Feb 2019. Page 31 of 34

Appendix 3 - Carrier Site Construction Checklist No Item Received

Yes/No Quality

High/Low Additional Requirement/Comment

1 Approved Construction Plans 2 Project Plan – Full extent of approved installations Traffic management Installation methodology and scheme Materials and Equipment delivery/storage Power and Water Waste Management - water, waste & emissions

3 Safe Work Method Statement for all Installation work Staff and subcontract services Work at Heights, excavation, hot work etc Hazardous materials handling and storage Electrical Safety

4 Environmental protection 5 Confirmation of compliance with access protocols 6 Provision of current Insurance Certifications for General

Liability, and Workers Compensation

7 Provision of relevant certifications such as white cards, Working at Heights, EME management, etc

8 Program of Work 9 Site Works Contacts List

10 Emergency Management Plan 11 As-Built Drawings showing all plant

Dimensioned locations Dated Photos Location of concealed cables and antennas etc

12 Final EMEG once the construction is finalised Once available in the RFNSA and after commissioning


Feb 2019. Page 32 of 34

Appendix 4 - EME Management process flow chart The flow chart provides a summary view of processing mobile and wireless carrier access requests for maintenance/repairs or installations.


Feb 2019. Page 33 of 34

Appendix 5 - LAAN Process and Timing The flow chart sets out the overall steps, responsibilities and timing as stipulated in the Telecommunications Act 1997(cth) and the Telecommunications Code of Practice 2018 under a Land Activity & Access Notice (LAAN) arrangement.


Feb 2019. Page 34 of 34

Appendix 6 - Web links

ACCC www.accc.gov.au

ACMA www.acma.gov.au

AMTA www.amta.org.au

ARPANSA www.arpansa.gov.au

Communications Alliance www.commsalliance.com.au

ICNIRP www.icnirp.org

MCF www.mcf.amta.org.au

NATA www.nata.com.au

RFNSA www.rfnsa.com.au

RRL web.acma.gov.au/rrl/register_search.main_page (ACMA Register of Radio Licenses)

TIO www.tio.com.au

WHO www.who.in

http://www.accc.gov.au/

http://www.acma.gov.au/

http://www.amta.org.au/

http://www.arpansa.gov.au/

http://www.commsalliance.com.au/

http://www.icnirp.org/

http://www.mcf.amta.org.au/

http://www.nata.com.au/

http://www.rfnsa.com.au/

http://www.tio.com.au/

http://www.who.in/

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