Joint response by GSMA, ETNO, Small Cell Forum, Digital Europe and GSA
1 April 2020
Our organizations welcome the European Commission proposal to give effect to the SAWAP (Small Area Wireless Access Points) provisions of the EECC to allow harmonized light deployment regimes leveraging simple criteria such as volume, emission power and compliance of SAWAP installation with the applicable European Standards (EN50401 and EN62232). We welcome Recital 16 that allows Member States to adopt less restrictive approaches, noting that many Member States already permit larger volumes or higher powers than those defined in the proposed SAWAP regulation or provide for no restrictions at all indoor as opposed to the proposed SAWAP regulation.
Our objective is that the criteria defined in this Implementing Regulation (IR) support the fast deployment of SAWAPs to meet the criteria of broadband objectives of the European Commission. Therefore, we propose changes to strengthen the effectiveness of the proposed measures.
1. The current SAWAPs deployed outdoor or indoor in larger areas such as museums, stadiums, convention centres, airports, metro-transport stations, railway stations, or shopping centres, have an emission power of 10 W or more as defined in 3GPP specifications and as such belong to classes E100 or sometimes E+. Therefore, the criteria for applicability of the IR should be 10 W emission power so that it applies to a wide range of installations.
2. Installation classes E10 and below are generally dedicated to indoor applications and deployed very close to where people work and live. Therefore, limiting the applicability of the draft IR to class E10, corresponding to emission power 0.5 W, which is similar to a mobile phone, means that it will have very limited potential benefit for stakeholders in real world deployments.
3. The proposed volume of 20 litres applies to limited functionality SAWAP that can serve a single mobile radio access technology in a single sector, potentially across multiple bands, excluding the auxiliary equipment (for example, the power supply) that is not part of the 20 litres.
4. A minimum volume of 50 litres is required to support multi-technology or multi-operator SAWAP. Unless this is permitted, we will see a negative business impact on small cells deployment (and future synergetic usage of co-located technologies like cellular vehicle-to-everything) and an overall risk of Europe falling behind other regions.
5. The proposed IR will have to be updated shortly after the update of EN62232 in order to incorporate the simple deployment criteria for active antenna systems (AAS) for example those using millimetre waves. We recommend to review the provisions of the IR six months after publication of the updated EN62232.
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