Disclaimer
The opinions and discussion contained in this document are for intended for the benefit of the
Ministry only and reflect the evaluation undertaken of the NESTF. Please seek specific legal
advice from a qualified professional person before undertaking any action based on the
contents of this publication. The contents of this discussion document must not be construed
as legal advice. The Government does not accept any responsibility or liability whatsoever for
any action taken as a result of reading, or reliance placed because of having read any part, or
all, of the information in this discussion document, or for any error, inadequacy, deficiency,
flaw in or omission from this document.
This report may be cited as:
Ministry for the Environment. 2015. Report of the Outcome Evaluation of the National
Environmental Standards for Telecommunication Facilities. Wellington: Ministry for the
Environment.
Published in March 2015 by the
Ministry for the Environment
Manatū Mō Te Taiao
PO Box 10362, Wellington 6143, New Zealand
ISBN: 978-0-478-41266-6
Publication number: ME 1176
© Crown copyright New Zealand 2015
This document is available on the Ministry for the Environment’s website:
www.mfe.govt.nz
Contents
Executive summary
5
1
Introduction
1.1 Background to the NESTF
1.2 What the NESTF does
7
7
8
2
Evaluation purpose and objectives
2.1 Purpose
2.2 Objectives
9
9
9
3
Methodology
10
4
Analysis and discussion: Has the NESTF met its stated objectives?
4.1 Objective 1: Assist in network and equipment design and equipment
sourcing for roll-outs
4.2 Objective 2: Create a reduction in compliance costs and timeframes for
service providers
4.3 Objective 3: Reduce the timeframe and lower the costs for the availability
of new services to consumers
4.4 Objective 4: Contribute to a reduced workload for councils in processing
and determining consent applications
4.5 Objective 5: Set an appropriate balance between local participation in
community planning and cost-effective national infrastructure investment
11
5
Radio-frequency
5.1 Standards
5.2 Data gaps
17
17
18
6
How real were the risks identified with the introduction of the NESTF?
6.1 Risks as a result of the NESTF
6.2 The dual role of council, the NESTF and the Code of Practice for Utility
Operators’ Access to Transport Corridors
20
20
Issues with the NESTF
7.1 Issues requiring more guidance
7.2 Issues that may require changes to the NESTF but are still within its current
scope
7.3 Wish list of expansions of the NESTF
23
23
Conclusions
8.1 Has the NESTF met its objectives?
8.2 Is the NESTF still fit for purpose?
27
27
28
7
8
11
12
13
14
14
20
24
26
Appendix 1: Participants in the evaluation
29
Appendix 2: Council survey
30
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
3
Appendix 3: Council survey results
34
Appendix 4: Discussion guide for the Telecommunications Forum
37
Appendix 5: Details of issues
39
Appendix 6: Measurement issues
41
Tables
Table S1:
A summary of the NESTF evaluation
5
Table 1:
A summary of the NESTF evaluation
11
Table 2:
Number of new installations (cabinets and mobile infrastructure) attracting
complaints since 2008
15
Table 3:
Risks as a result of the NESTF
20
Table A5.1:
Issues with the current NESTF
39
Figures
Figure 1:
Relationship between district plans, the NESTF and the Utilities Access Code
Figure A6.1: Effect of down tilt on exposure plumes (based on an actual site)
4
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
21
41
Executive summary
The Resource Management (National Environmental Standards for Telecommunication
Facilities) Regulations 2008 (NESTF) came into force in 2008. As part of its regulatory
maintenance programme, the Ministry has conducted an evaluation of the NESTF to assess
whether, after five years, it is achieving its objectives. This report presents the findings of
that evaluation.
The regulations were developed to provide a nationally consistent planning framework for the
radio-frequency fields of all telecommunication facilities operated by a network operator
licensed under the Telecommunications Act 2001, and some telecommunications
infrastructure on road reserves that have low environmental impact.
To carry out the evaluation, the Ministry contacted the organisations the NESTF immediately
affects. All 61 territorial authorities received an online survey, to which 25 responded.
Information was also received from telecommunications industry representatives and an
expert in radio-frequency fields.
The table below summarises the evaluation results by indicating whether each of the
objectives described in the Cabinet paper has been met. A detailed analysis of each objective is
provided in section 4 of this report.
Table S1:
A summary of the NESTF evaluation
Objective
Was it met?
Assist in network and equipment design and equipment sourcing for rollouts
Yes
Create a reduction in compliance costs and timeframes for service providers
Mobile operators: yes
Reduce the timeframe and lower the costs for the availability of new
services to consumers
Fixed-line: a mixed experience
Contribute to a reduced workload for councils in processing and
determining consent applications
Yes
Set an appropriate balance between local participation in community
planning and cost-effective national infrastructure investment.
Industry: Yes
Councils: 56% of survey
respondents said yes
As well as assessing whether the objectives have been met, we looked at whether the NESTF is
still fit for purpose. The NESTF requires all telecommunications infrastructure to comply with
two sets of standards for radio-frequency fields. One of these standards, NZS 6609:2:1990, has
been superseded, and the Ministry has already recommended that this be updated in the
NESTF. Councils do not monitor for compliance with these standards, but Vodafone and
2degrees have a voluntary monitoring programme, which shows their facilities comply with
these standards.
When looking at the wider regulatory environment for telecommunications, an issue was
raised with the code mandated by the Utilities Access Act 2010. The National Code of Practice
for Utility Operators’ Access to Transport Corridors (Utilities Access Code) sets out processes
and procedures for network operators and corridor managers1 to interact with each other.
Potential conflicts between the NESTF and the ‘reasonable conditions’ set by councils under
1
Usually the local council, sometimes the New Zealand Transport Agency or the Department of Conservation.
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
5
section 135 of the Telecommunications Act 2001 were raised, but this is not seen as having a
major impact because national industries design to NESTF specifications rather than local
conditions.
Both councils and industry representatives were asked for their views on the NESTF and what
changes they would like to see. A comprehensive list of the issues raised is provided in
appendix 5ranging from concerns about the interpretation of certain clauses, which may result
in inconsistency in implementation around the country, to issues that would require changes
to the NESTF to resolve. While many of these changes could be within the current scope of the
NESTF’s objectives, industry representatives also provided a list of changes they would like to
see that would widen this scope.
Overall, the evaluation determined that the NESTF has achieved its objectives. However, the
telecommunications landscape is evolving rapidly. There is always a risk that regulations will
lose their fitness for purpose in such a rapidly evolving landscape, and this risk is evidenced by
the issues pointed out by the councils and industry. To ensure the NESTF remains up to date,
consideration should be given to a review in the near future.
6
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
1
Introduction
The Resource Management (National Environmental Standards for Telecommunication
Facilities) Regulations 2008 (NESTF) came into force on 9 October 2008. The NESTF represents
the first regulations developed under the Resource Management Act 1991 (RMA) that
explicitly manage land-use activities.
As part of the Ministry’s approach to maintaining regulatory tools, evaluations of regulations
on a roughly five-yearly basis will be conducted. This NESTF has now been in force for five
years and this is its first evaluation. The Ministry conducted an implementation evaluation of
the NESTF in 2009, which this report refers to as the ‘2009 stocktake’.
1.1
Background to the NESTF
1.1.1 What are national environmental standards?
National environmental standards (NES) are regulations made in accordance with sections
43 and 44 of the RMA, and they apply nationally. They can prescribe technical standards,
methods, or other requirements relating to specific environmental matters. Each local
authority has the responsibility for enforcing the standard in its jurisdiction. A local authority
rule may prevail over a NES where the standard expressly allows this, but it cannot be
more lenient.
NES not only protect people and the environment, they also secure a consistent approach and
decision-making process throughout the whole country.
1.1.2 The Telecommunication Facilities National
Environmental Standards
The NESTF was created during a period of rapid expansion of the telecommunications industry.
This expansion supported Government aims for expanding access to broadband and
information technology, increasing competition among suppliers through local loop
unbundling, improving general industry productivity, and achieving economic transformation.
However, there was also a backdrop of local regulatory inconsistency and uncertainty.
Resource consent requirements varied widely, in terms of whether or not consent was
required, and also the nature and extent of conditions that were attached to resource
consents. Variability in consenting requirements creates uncertainties, resulting in costs and
time delays. The telecommunications industry reported that lack of national consistency added
costs to their provision of services and slowed the roll-out of new capacity across the country.
From a local government perspective, not all district plans had specific plan rules relating to
telecommunications infrastructure. This could cause time delays and uncertainty if an activity
was applied for that did not clearly fit within current plan provisions, and there was no close
precedent to draw on.
In July 2005 a reference group was convened, with representatives from Telecom, Vodafone,
TelstraClear, Local Government New Zealand, the Ministry for the Environment, the
Ministry of Health and the Ministry of Economic Development. After considering several
options, the reference group proposed a package of NES for radio-frequency exposure and
specific telecommunications facilities. In February 2008, Cabinet decided that the National
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
7
Environmental Standards for Telecommunication Facilities should proceed, and they came into
force on 9 October 2008.
The intent of the NESTF was to provide certainty about the levels of permitted development
within the RMA. Infrastructure would need to comply with specific criteria, designed to
minimise impacts on the environment, in order to be installed without resource consent.
The NESTF would also make compliance with the New Zealand standard for radio-frequency
fields mandatory.
The NESTF was intended to contribute to the economic transformation priority of the
government of the day. Faster and more cost-effective delivery of telecommunications
facilities was required for New Zealand to become a “world leader in using information and
technology to realise its economic, social, environmental, and cultural goals”.2
The Business Growth Agenda describes the current government’s approach to building a more
productive, more competitive economy. Infrastructure is one of the key inputs to the Agenda,
and of these, the major telecommunications initiatives are the Ultra-Fast Broadband roll-out
and the Rural Broadband Initiative. Services facilitated by these programmes will “increasingly
support New Zealand’s position as a competitive business location and improve living
standards”.3 The NESTF has an important role to play in their delivery.
1.2
What the NESTF does
In summary, the NESTF provides for the following:

an activity (such as a mobile phone transmitter) that emits radio-frequency fields is a
permitted activity provided it complies with the existing New Zealand standard (NZS
2772.1:1999 Radio-frequency Fields Part 1: Maximum Exposure Levels 3 kHz to 300 GHz)

the installation of telecommunications equipment cabinets along roads or in the road
reserve is a permitted activity, subject to specified limitations on their size and location

noise from telecommunications equipment cabinets located alongside roads or in the road
reserve is a permitted activity, subject to specified noise limits

the installation of masts and antennas on existing structures alongside roads or in the
road reserve is a permitted activity, subject to specified limitations to height and size.
Activities that do not qualify as permitted activities under the NESTF continue to be managed
by local authorities through the existing rules in their district plans.
2
The Digital Strategy 2005.
3
The Business Growth Agenda progress report November 2012 – Infrastructure.
8
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
2
Evaluation purpose and objectives
2.1
Purpose
The purpose of this project is to carry out an outcome evaluation of the National
Environmental Standards for Telecommunication Facilities (NESTF) to determine whether its
objectives have been met, five years after its introduction.
2.2
Objectives
The evaluation will investigate whether the regulations are achieving their intended purpose in
terms of the policy objectives of the NESTF. It will also, where possible:

assess whether implementation issues identified in the 2009 stocktake have been
addressed

identify emerging issues

ascertain whether key risks associated with the NESTF have been realised.
The original policy objective in the industry reference group report4 was:
To provide for consistent and certain regulatory planning provisions that apply on a national
basis, to assist in network and equipment design and equipment sourcing for roll-outs, and a
reduction in compliance costs and timeframes.
The regulations were developed along these lines to provide for a nationally consistent
planning framework for radio-frequency fields of all telecommunication facilities and lowimpact5 telecommunications infrastructure on road reserves, in order to:

assist in network and equipment design and equipment sourcing for roll-outs

create a reduction in compliance costs and timeframes for service providers

reduce the timeframe and lower the costs for the availability of new services to
consumers

contribute to a reduced workload for councils in processing and determining consent
applications

set an appropriate balance between local participation in community planning and costeffective national infrastructure investment.
Whether these objectives have been met forms the basis of this evaluation.
4
Telecommunications Industry Reference Group. 2006. Proposed National Environmental Standard for Radiofrequency Exposure and Low Impact Telecommunications Structures in Road Reserves: An Industry Perspective.
5
Being a regulation under the RMA, ‘low impact’ refers to the effect of an activity.
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
9
3
Methodology
There were five phases in the project:
Phase 1:
Informal discussions were held with a large territorial authority and a
telecommunications industry representative to obtain a feel for the responses
we might receive from stakeholders. The survey developed for territorial
authorities was piloted with the authority that had been consulted.
Phase 2:
The formal territorial authority survey was sent out online to appropriate
managers of all territorial authorities. Responses were gathered over a period of
six weeks. Territorial authorities were asked about:

their workload

consent activity

community participation

implementation of the National Environmental Standards for
Telecommunication Facilities (NESTF).
The survey and a summary of the responses are attached as appendices 2 and 3.
Phase 3:
The New Zealand Telecommunications Forum6 was approached to take part
in the evaluation. Telecommunications industry representatives were asked
about:

the overall impact of the NESTF

whether the NESTF had met its objectives

working with the NESTF

working with councils

community concerns with radio-frequency fields

whether the industry would like to see any changes made to the NESTF.
Phase 4:
Discussions were held with the Ministry of Business, Innovation and Employment
(Radio Spectrum Management Communications Team and Information
Technology Policy Team) and the Commerce Commission. Discussions were also
held with a New Zealand expert on the topic of radio-frequency fields, Mr Martin
Gledhill.
Phase 5:
Phase 5 was the ‘snowball’ discussion phase with the New Zealand Contractors’
Federation and the New Zealand Utilities Advisory Group, which involved
following up issues identified in the previous phases. Follow-up discussions
were held with the Telecommunications Forum and Auckland Council, along
with phone conversations with other councils who had made substantive
comments in their survey responses. Discussions were held with Bronwyn Howell
(Victoria University of Wellington) to gain an overview of the economics of
telecommunications.
6
The Telecommunications Carriers Forum (now known as the Telecommunications Forum) was established in
2002. Its objective is to actively foster cooperation among the telecommunications industry’s participants to
enable the efficient provision of regulated and non-regulated telecommunications services. It works with
industry and government to resolve regulatory, technical and policy issues.
10 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
4 Analysis and discussion: Has the
NESTF met its stated objectives?
The National Environmental Standards for Telecommunication Facilities (NESTF) was intended
to create a nationally consistent planning framework for radio-frequency fields and for lowimpact telecommunications infrastructure on road reserves installed by network operators
licensed under the Telecommunications Act 2001. Whether the five policy objectives were met
is summarised below. The evidence is discussed in the remainder of this section.
Table 1:
A summary of the NESTF evaluation
Objective
Was it met?
1. Assist in network and equipment design and equipment
sourcing for roll-outs
Yes
2. Create a reduction in compliance costs and timeframes for
service providers
Mobile operators: yes
3. Reduce the timeframe and lower the costs for the
availability of new services to consumers
Fixed-line: a mixed experience
4. Contribute to a reduced workload for councils in
processing and determining consent applications
Yes
5. Set an appropriate balance between local participation in
community planning and cost-effective national
infrastructure investment
Industry: yes
Councils: 56% of survey respondents said yes
4.1 Objective 1: Assist in network and equipment
design and equipment sourcing for roll-outs
According to industry feedback, equipment is designed to comply with the size and noise
specifications stated in the NESTF. This is particularly the case for cabinets. Although New
Zealand has little influence on international telecommunications equipment development,
operators do use the specifications of the NESTF as assessment criteria when sourcing
equipment from overseas.
Technology is continually evolving in telecommunications, and the NESTF was deliberately
designed to be as ‘future proof’ as possible. For example, rather than specifying the
dimensions of panel antennas, the NESTF describes dimensions within which the antenna
must fit.
These future-proof dimensions are now out of date for some technology, as follows:

Antennas required for the 4G roll-out do not meet the permitted NESTF size envelope
described in Regulation 7. These antennas have a 600 mm diameter, whereas the NESTF
allows for a maximum 500 mm diameter.

Currently telecommunications operate in frequencies above 880 MHz, but the reallocation
of the 700 MHz band from analogue to digital television broadcasting means that
frequencies above 700 MHz will be freed up. While the technology required to
accommodate this lower frequency is still being developed overseas, it is likely that its
dimensions will exceed the NESTF envelope.
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 11

New antennas accommodate multiple frequencies and tend to be larger than their singleband predecessors.
Regulation 7 would need to be revisited if the NESTF were to accommodate the new lowerfrequency and multi-band technology.
4.2 Objective 2: Create a reduction in compliance costs
and timeframes for service providers
Industry reports definite reductions in Resource Management Act 1991 (RMA) processing
timeframes, and attendant lower compliance costs. Because a proportion of cabinets and
antennas located within the road reserve are now permitted activities, these have contributed
to reduced assessment timeframes. Previously many applications had a controlled or
discretionary activity status, which is inherently more complex and expensive to process
because it requires resource consent.
In 2009, the RMA was amended to give local authorities the explicit power to issue certificates
of compliance in instances where activities comply with the provisions of a national
environmental standard (NES). Operators do not have to seek a certificate of compliance,
especially when a proposal is clearly a permitted activity under the NESTF. In general, mobile
operators will seek a certificate of compliance for a new facility, but they are less likely to do so
for matters such as minor upgrades. Generally, the lines companies will not apply for
certificates of compliance for cabinets for the Ultra-Fast Broadband (UFB) roll-out, but this has
changed over the life of the NESTF and is discussed later in this section.
The majority of straightforward telecommunications applications, and, in particular, NESTF
applications requiring resource consent, are processed within a 20-working-day statutory
period. There are rarely ongoing compliance costs for equipment allowed as a permitted
activity within the road reserve. For example, the standardisation of noise performance
standards for cabinets located in roads has greatly reduced the need for individual acoustic
reports to support RMA applications and post-construction compliance testing.7 The NESTF
specifies standardised noise levels and the point of measurement in all regions.
Regulation 4 of the NESTF requires radio-frequency reports demonstrating compliance with
NZS 2772.1:1999 to be provided to councils before new or upgraded wireless
telecommunications facilities become operative. This is now reported to be a
“straightforward” and nationally consistent process, which has removed local variation.
Evidence at planning hearings is now more focused, thereby reducing hearing timeframes and
removing reliance on expert witnesses.
That said, issues were raised about various aspects of field exposure prediction and
measurement, and these are discussed in detail in appendix 6. These issues range from the
need for more guidance on how to handle certain parameters when modelling exposures, to
how to predict exposures from sites that are staged incrementally and what to do when there
is difficult access to sites where measurements need to be taken.
In terms of the magnitude of benefits arising from the regulation, the telecommunications
industry estimates that $3.2 million has been saved in direct costs,8 and that over $10 million
may be saved over the duration of the 4G roll-out. One mobile operator estimates that
savings per site range from $3,000 to $30,000. The former figure is the saving under the
7
Note that cabinets for the UFB do not generate noise.
8
Industry data is indicative only, and estimates for a given process may vary among operators.
12 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
NESTF compared with a simple RMA process (ie, no notifications, no requests for further
information), while the latter compares the situation under the NESTF with a complex
process that requires a hearing and increased monitoring.
Chorus’s experience presents a more complex picture.9 The NESTF has not delivered any direct
financial benefit to them in terms of cabinet deployment costs, for the following reasons:

RMA costs were higher under the Fibre To The Node (FTTN) project because of the level of
engagement with council officers and the numbers of site visits. In those early days of the
NESTF, Chorus organised a caravan to visit every council.
The need for more site visits arose as more resource consents were required, because the
NESTF is more stringent in its requirements relating to size and noise than the district plan
rules it replaced.10 Before the 2009 RMA amendment that authorised councils to issue
certificates of compliance under an NES, field trips were arranged to every installation.

Even with cabinet design specifications being guided by the NESTF, resource consents are
often still required because of the separation rules in Regulation 8.
Chorus provided information about cabinet installation to every council until recently, when
Auckland Council indicated that this was no longer required. This reporting can be inefficient
because it duplicates the information required for the corridor access request, which initiates
the installation phase of the facility. Chorus has suggested that as councils and the industry
become more confident working with the NESTF, the need for information will reduce, as will
costs. Chorus’s experience is consistent with anecdotal evidence that parties that engage early
during the implementation of an NES incur extra transaction costs, which creates an
unfortunate incentive structure.
Chorus also notes that increased consistency of rules and interpretation of those rules, and the
increased confidence this inspires, all have worthwhile, intangible benefits.
Chorus incurs compliance costs when working around street trees. Currently they incur
$4 million per year in arborists’ fees to undertake work within the drip line of trees in
Auckland. Regulation 6 allows provisions in district plans for work within the drip line of a tree
or other vegetation to be more stringent than those in the NESTF. Chorus has suggestions as
to how this cost could be reduced, such as a certification scheme for contractors to undertake
this type of work (see section 7.3, suggestion 2).
4.3 Objective 3: Reduce the timeframe and lower the
costs for the availability of new services to consumers
The industry considers that overall network programme planning has been enhanced because
there is now greater certainty of the likely timeframes for obtaining consents for specific sites
within the road reserve. There is clarity over what is a permitted activity and, when resource
consent is required, the NESTF has set up the permitted baseline, which has made assessments
more predictable. At this level, timeframes are generally reduced.
The majority of cabinets are located in the road reserve. As discussed in the previous section,
although savings were not realised for the FTTN, the RMA process for cabinets under the
9
Chorus was split off from Telecom in 2011. It builds and maintains networks and is responsible for deploying
70 per cent of the UFB network, and it works with Vodafone with the Rural Broadband Initiative. It does not
provide mobile infrastructure.
10
The NES is more stringent than 82 per cent of district plans (as at 2008) and 51 per cent of noise requirements.
See: Incite. 2006. Assessment of Plans: Telecommunications Facilities. Wellington: Ministry for the Environment.
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 13
NESTF has been progressively streamlined. However, for a mobile cellular network only a
minority (approximately 15 per cent) of the sites are located in road reserves, and so the
impact of the NESTF has been harder to estimate. Those minority sites are generally in the
suburbs or residential fringe areas, where it has been hard to establish facilities, and industry
has valued the role of the NESTF in these circumstances.
The industry considers the NESTF had a role in facilitating the initial establishment of the
2degrees network in some key areas due to the NESTF being released at the same time as the
first phases of the 2degrees network roll-out. This has increased competition in that sector.
The initial mobile networks of Telecom and Vodafone, as well as the introduction of 3G
services, were substantially established before the advent of the NESTF.
4.4 Objective 4: Contribute to a reduced
workload for councils in processing and determining
consent applications
The industry’s perspective is clear; dealings with councils have become more efficient as a
result of the NESTF. The councils’ perspective was collected via the online survey sent to all of
the 61 territorial authorities that administer the NESTF, to which 25 (or 41 per cent)
responded.11 Their perspective is a little more complex, but a summary is provided below:

There is a lot of variation across councils in terms of the volume of telecommunications
infrastructure-related activities they handle. The greatest volume is found in the largest
cities and provincial centres where roll-outs have occurred, while the smaller rural
councils (which account for the majority of territorial authorities in the country) – deal
with only a few.

The workload is generally, but not always, less for a permitted activity compared with one
that requires resource consent. Councils may still have to process certificates of
compliance, administer radio-frequency reports and handle any correspondence arising
from an installation.

Total workload is perhaps a more relevant measure for councils, and the introduction of
the NESTF has not changed total workload in a predictable way. There are many factors
that influence total workload, such as the ‘lumpiness’ of the work, the type of
infrastructure being installed, where it is being installed, and the reaction of the
community to the installation.
Further details of the council survey and responses made can be found in appendices 2 and 3.
4.5 Objective 5: Set an appropriate balance between
local participation in community planning and costeffective national infrastructure investment
The industry considers that an appropriate balance has been reached. Regulation 6 of the
NESTF provides that a plan’s rules need to be complied with if consent is already required
under the relevant district plan for works within the drip line of a tree, or where the adjacent
11
The response was higher for city councils than for district councils: 7 of the 11 city councils responded
(64 per cent), compared with 18 of the 50 district councils (36 per cent). Councils contributed on the basis
of anonymity, so in this report no council is identified with any particular survey response.
14 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
site is accorded specific protection. The provisions in a district plan are the result of a public
process which provides for community input.
Of the 25 councils that responded, a majority (56 per cent) consider that an appropriate
balance has been struck. About a third of respondents were uncertain, and three councils
thought that a balance had not been stuck. Of those three, two were concerned about the
impact of the NESTF on infrastructure siting.
One council stated that infrastructure was sometimes not installed in the most appropriate
place because the council did not have an effective say in this. Another council in the process
of the UFB roll-out reported an increase in street clutter, which they ascribed to a lack of
effective engagement of industry with the council’s corridor managers:
“Telcos, in particular the UFB project, designed their new facilities with the size and activity
planned to avoid any effective participation when planning with the corridor manager. There
is currently a proliferation of new telco facilities occupying pavement space that is reducing
the pedestrian usage they were designed for.”
The other council thought there was no balance because councils, and the public they
represent, were effectively excluded from decision-making:
“The restrictions on what we can consider (when considering telecommunications consents)
are very narrow when we have a chance. In almost all cases the residents have no input and
will vent frustrations with us. We will explain the rules and what they can expect. This does
not serve to allay all of the concerns we get to hear about.”
In contrast, councils that did think a balance had been struck were more accepting of
the provisions of the NESTF. What is allowed as a permitted activity in an NES is out of
council hands.
Not all of the opposition has been resolved, rather they now know under the NES it is
permitted and outside the control of the council.
People have had to accept permitted activity standards regarding radio-frequency.
Councils do not have to get embroiled in disputes, because such disputes are seen as a
matter for central government, as the regulation maker. This appeared to be a benefit for
some councils.
To gauge the level of community opposition to telecommunications facilities, councils were
asked for the total number of new installations since 2008 that had attracted complaints. Table
2 indicates that no more than 10 installations have received complaints since 2008 within any
of the councils that responded to the question. About one-third of the district councils had not
received any complaints, and some of these councils included towns of considerable size.
Table 2:
Number of new installations (cabinets and mobile infrastructure) attracting
complaints since 2008
Number of installations attracting
complaints
*
Council type
City
District
Total
0
0
6
6
1–10
5
11
16
11–100
0
0
0
Don’t know
1
1
2
Total
6*
18
24
Auckland was excluded from the total because the new council was formed in 2010, but their experience since then has been
consistent with the above findings.
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 15
Complaints arise from neighbouring land owners and are based on concerns about the health
effects of radio-frequency fields, impacts on property values, aesthetics, footpath clutter,
traffic safety, and interference with personal radio equipment.
In 2009, the Telecommunications Forum developed a set of Community Engagement
Guidelines for Wireless Telecommunications Facilities to help wireless network operators
standardise their approach to community consultation. Vodafone and Telecom reported in a
recent review of these guidelines that there was a decrease in escalation of public issues and
the guidelines were working well. Much of their upgrade work involves existing infrastructure.
2degrees has been gradually developing its own network while it continues to use the
Vodafone network on a roaming basis for areas outside of its network, so it has encountered
more community opposition. However, in a recent Taranaki roll-out, only two of 15 sites
received opposition. Some councils commented favourably on this company’s approach to
working with communities.
Currently, if a new facility is being installed adjacent to or near a residential area, or where
there is at least one public facility12 adjacent or nearby, the guidelines state that the operator
should:
9.2.1 Undertake any engagement or consultation required by the relevant Council under the
Council District Plan; or required pursuant to the conditions of any Resource Consent.
9.2.2 Ensure that the occupiers of those dwellings immediately adjacent to the proposed
location, and the management of the Public Facility near the proposed location, are
sent a letter by the relevant Wireless Network Operator prior to the lodgement of any
Resource Consent application or National Environmental Standard application required
by the relevant Council regarding the proposed Wireless Telecommunications Facility.
One council suggested that operators should follow a process whereby residents are notified
before they approach the council so issues can get sorted out before RMA processes
are embarked on. This suggestion is almost identical to the one given in the guidelines, which
suggests that the guidelines may need more promotion so that councils are more aware
of them.
The Ministry for the Environment and the Ministry of Health track the number of letters sent
to their Ministers from members of the public on the topic of telecommunications facilities.
This provides an indication of how much community concern is being escalated to the central
government level. Prior to the NESTF, the Ministry for the Environment received, on average,
just over one ministerial letter per year, and the Ministry of Health less than one. Since 2008
the number of letters received each year has varied considerably, from 1 to 45 (the latter
number reflects the level of community concern over the erection of a cellphone tower in
Nelson during 2009/10). The majority of the Ministry for the Environment ministerial letters
are about the health effects of radio-frequency fields.
12
A public facility is defined as “a physical premise which has a primary purpose of providing care, welfare or
educational services to members of the community”. The guidelines are published at
www.tcf.org.nz/content/6efda0e0-d74d-4a95-95d2-0769696c53d6.html (accessed 3 June 2013).
16 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
5
Radio-frequency
5.1
Standards
Radio-frequency emissions are addressed by the National Environmental Standards for
Telecommunication Facilities (NESTF) in Regulation 4, which mandates compliance with two
New Zealand standards:

NZS 2772.1:1999 Radiofrequency Fields Part 1: Maximum Exposure Levels – 3 kHz to
300 GHz

NZS 6609.2:1990 Radiofrequency Radiation: Principles and Methods of Measurement –
300 kHz to 300 GHz.
The two questions addressed here are whether the standards are still relevant, and if so,
whether they are being complied with.
Relevance was ascertained through two sources. The first was the minutes of the Interagency
Committee on the Health Effects of Non-Ionising Fields. This committee keeps a watching brief
over international research on these matters and has been meeting every six months since
2001.13 The second source was the expert advice of Mr Martin Gledhill.14
5.1.1 NZS 2772.1:1999
Expert advice suggests that this standard is still relevant. NZS 2772.1:1999 is based on
guidelines published by the International Commission on Non-Ionising Radiation Protection
(ICNIRP),15 and these guidelines were reconfirmed in 2009.16, 17 However, the fact that the
guidance was published 14 years ago has attracted criticism from some community members
that they are out of date, despite the reconfirmation.
In 2011, the International Agency for Research on Cancer (IARC) classified radio-frequency
fields as a class 2B ‘possible carcinogen’. The evidence for this is largely based on studies of
mobile phone use that suggest that higher levels of use are associated with some types of
brain tumour. However, it has been acknowledged that the apparent risk could be due to
biases in the data. Laboratory research does not suggest that radio-frequency radiation could
affect cancer development. The IARC has noted that typical ‘environmental’ exposures are
considerably lower than those the head is exposed to when using a mobile phone.
13
The committee was first formed in 1989, and its terms of reference of reviewing possible health effects from
exposures to extremely low electric and magnetic fields were expanded in 2001 to include radio-frequency
fields.
14
Mr Gledhill has worked at the National Radiation Laboratory of the New Zealand Ministry of Health for over
20 years and now runs EMF Services. He has a Master of Arts in Natural Sciences (Physics) from Cambridge and
a Master of Science in Medical Physics from the University of Otago. He is a member of the International
Committee on Electromagnetic Safety, the Australian Radiation Protection Society, the Bioelectromagnetics
Society, and the Interagency Committee.
15
International Commission on Non-Ionising Radiation Protection. 1998. Guidelines for limiting exposure to timevarying electric, magnetic, and electromagnetic fields (up to 300 GHz). Health Physics 74(4): 494–522.
16
International Commission on Non-Ionising Radiation Protection. 2009. Statement on the “Guidelines for limiting
exposure to time-varying electric, magnetic, and electromagnetic fields (up to 300 GHz)”. Health Physics 97(3):
257–258.
17
The ICNIRP published additional guidelines for low-frequency radiation (1 Hz to100 kHz) in 2010, but none of
the network operators licensed under the Telecommunications Act 2001 operate in this band.
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 17
Scientific reviews published since 2011 have generally concluded that, overall, the evidence
does not support there being a causal link between radio-frequency fields and cancer.
However, this fails to address the fears of some sectors of the community.
5.1.2 NZS 6609.2:1990
NZS 6609:2:1990 has been superseded by AS/NZS 2772.2:2011: Radiofrequency Fields Part 2:
Principles and Methods of Computation – 3 kHz to 300 GHz. The Ministry has advised that NZS
6609.2:1990 should be replaced by AS/NZS 2772.2:2011 in Regulation 4 of the National
Environmental Standards . The updated standard provides more practical guidance than its
predecessor and is more rigorous in its requirements, and as such follows developments in
similar standards overseas.
5.1.3 Are the standards being complied with?
The evidence to hand suggests that NZS 2772.1:1999 is being complied with. Councils do not
undertake monitoring and compliance work for permitted activities, mainly because there is
no mechanism for them to recover costs.18 This does not mean that no monitoring is
undertaken. Vodafone has a radio-frequency field-monitoring programme at a sample of their
cell sites. Since 2004, the National Radiation Laboratory (NRL) has measured radio-frequency
fields around a random sample of 10 Vodafone sites (of a total of approximately 200), which
the NRL chooses independently of Vodafone. In their 2011/12 report19 the maximum radiofrequency exposures in public areas were all less than 1 per cent of the public limit.
The NRL undertook a round of monitoring of 2degrees’ sites in 2010, with similar results. Until
recently Telecom (now Spark) has had an environmental audit programme, but this is currently
under review.
Network operators supply a radio-frequency report to the council for each radio-frequencyemitting device they install. These reports specify where the device is to be installed and
whether radio-frequency field exposures in areas reasonably accessible to the public comply
with NZS 2772.1:1999.20
Regulation 4(5) states that when a device’s field is predicted to reach or exceed 25 per cent of
the maximum level, then ‘post-build’ measurements must be done within three months of the
facility becoming operational. There are some methodological issues with this approach, which
is known as the ‘25% Rule’, and these are described in section 7.2.3.1 and discussed fully in
appendix 6.
All of the councils that responded to the evaluation survey indicated they had a system for
retaining radio-frequency reports.
5.2
Data gaps
Evidence suggests that radio-frequency fields from individual devices (or clusters of devices, as
measurements must take adjacent devices into account) have been well below maximum
18
Monitoring may be a condition for those activities that require resource consent. Measuring electromagnetic
frequency fields is a highly specialised field.
19
National Radiation Laboratory. 2012. Measurements of Exposures Around Vodafone New Zealand Limited
Cellsites from March 2011 to May 2012. Christchurch: Institute of Environmental Science & Research Limited.
20
As well as the general public, who may not be aware they are being exposed to radio-frequency fields, the
standard also details exposure limits for industry workers who may be occupationally exposed.
18 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
exposure limits. However, there is a data gap in that there are no time series on exposures to
radio-frequency fields in New Zealand that allow an analysis of change in exposure over time.
Mr Gledhill advises that the most likely change to have occurred since the introduction of the
NESTF is that, because the number of cell sites has increased, the average exposure in urban
and suburban areas will have increased slightly. Maximum exposures would not have changed
even when sites are located close together because of the limits set by NZS 2772.1:1999.
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 19
6 How real were the risks identified
with the introduction of the NESTF?
6.1
Risks as a result of the NESTF
Some risks to the success of the National Environmental Standards for Telecommunication
Facilities (NESTF) were identified during its development and early implementation phase.
Whether these risks have been realised after five years is summarised below. Of the seven
identified risks, there is evidence of three being realised to some extent.
Table 3:
Risks as a result of the NESTF
Risk
Was it realised?
Lack of consistency in how the NESTF is being applied
across the country
Not a widespread issue, but examples exist due to:
 varying interpretation of regulations (see sections
7.1.1–7.1.2)
 use of Regulation 6 (see section 7.2.2).
Councils being unaware of the NESTF and so not
applying the NESTF at all
No reports from industry of this
External factors affecting application of the NESTF,
such as the Christchurch rebuild
No reports from industry of this
The NESTF being used as a maximum allowable limit
(ie, if facilities do not comply with the NESTF they are
not allowed at all, rather than having them revert back
to plan rules)
No reports from industry of this
The NESTF could create a permitted baseline for other
activities in the road reserve
Unknown
Unintended consequences, such as councils having the
ability to require radio-frequency reports for activities
that previously would not have needed them
May be occurring. Some councils may be requiring
radio-frequency reports for devices that emit weak
fields, such as femto-cells and smart meters.
The industry incurring costs because of the dual role of
council as consenting authority and corridor manager
of the road reserve
Yes. Further investigation is needed to determine the
magnitude of the issue.
6.2 The dual role of council, the NESTF and the
Code of Practice for Utility Operators’ Access to
Transport Corridors
Section 135 of the Telecommunications Act 2001 grants network operators the right of access
to undertake works in the road reserve as long as they comply with any “reasonable conditions
that the local authority (or other person who has jurisdiction over that road) requires”.
The National Code of Practice for Utility Operators’ Access to Transport Corridors (Utilities
Access Code) came into force in November 2011 and sets out processes and procedures for
network operators and local authorities (or ‘corridor managers’) to interact with each other.
The Code was mandated by the Utilities Access Act 2010.
20 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
One of the purposes of the Code is to create a model set of ‘reasonable conditions’ that apply
to a road-opening notice, because previously there was an unwarranted level of local variation
to those conditions. The Code aims to reduce the set of local conditions to those that are
justified by local geography.
However, the new Code still accommodates local conditions as insertions within the body of
the Code, and some of these conditions are still idiosyncratic. For instance, Wellington City
Council has a set of cabinet size conditions that are inconsistent with the NESTF. The Code is
being reviewed in late 2013 and may address the issue of local conditions.
Conversations with national industry players suggest that the presence of NESTF inconsistent
local rules is not necessarily a problem. As discussed in section 4.1.1, national operators use
the specifications of the NESTF to source their equipment, not the specifications of local rules.
Officials from the Ministry of Business, Innovation and Employment and the Commerce
Commission expressed concern about a potential conflict between the Code and the NESTF,
but we could not identify instances where serious difficulty arose due to the ‘reasonable
conditions’ of the corridor manager being inconsistent with the NESTF.
Figure 1 illustrates the relationship between district plans, the NESTF and the Utilities Access
Code. The RMA comes into play at the planning stage of development, and precedes the
implementation stage, when the Code comes into play.
Figure 1:
*
Relationship between district plans, the NESTF and the Utilities Access Code
NESTF rules prevail over those in a district plan, except where the NESTF specifies that rules in a district plan may be more
stringent.
** For state highways this is the New Zealand Transport Agency.
Planning permission to install is granted under the RMA (either through the NESTF or a district
plan). This is a necessary step preceding the corridor management requirements of the
roadside reserve under the Utilities Access Code. The Code is given effect through the Utilities
Access Act 2010, and both this Act and the Resource Management Act 1991 (RMA) must be
complied with.
One council suggested that their corridor management would like more involvement with the
siting of infrastructure permitted under the NESTF, and cited an increase in footpath clutter
because of the Ultra-Fast Broadband roll-out. It was also clear that there is potential for
operators to incur transaction costs at the corridor manager interface and at the roadside. This
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 21
is not related to the NESTF. Feedback from industry suggests that their interaction with
corridor managers varies from council to council.
Some of the people we interviewed who were well versed in the Code had never heard of the
NESTF and were somewhat perplexed as to how the RMA fitted into the general scheme of
things. This is consistent with the role separation within councils, where familiarity with the
NESTF is the responsibility of consent teams. It may not have any practical implications, but
our scan of this area made it abundantly clear that telecommunications is an extraordinarily
complex area, with multiple silos, for which there is no single organisation with oversight.
22 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
7
Issues with the NESTF
Councils and industry were asked whether there were any changes they wanted to see made
to the National Environmental Standards for Telecommunication Facilities (NESTF). Of the 25
councils that responded to the survey, six suggested changes. Twelve councils didn’t think that
change was necessary, and seven responded ‘don’t know’.
Industry provided comprehensive lists of suggested changes and additions to the existing
NESTF. These suggestions have been classified into those that entail providing more guidance,
those that would require a change to current NESTF wording, and those that would require an
expansion in the scope of the NESTF. Changes that are considered to be the highest priority for
further investigation are discussed in the following section, while appendix 5 contains the full
list of suggestions.
7.1
Issues requiring more guidance
Interpretation issues have emerged early during the life of the NESTF and some have still not
been resolved. These have the potential to result in inconsistency in application of the NESTF.
7.1.1 Regulation 8, the definition of ‘site’ and the 30 m rule
This issue was identified in the 2009 stocktake and remains a concern. The drafting of
Regulation 8 has caused confusion for councils and industry. The cause of this confusion may
be due to interpretations of the word ‘site’, which is used in subclauses 2, 3 and 4. Regulation
8(3) states:
This condition applies ... if 2 or more cabinets are located at the same site in a road reserve,
next to land that a relevant district plan or proposed district plan does not classify as primarily
for residential activities.
Industry interprets ‘site’ as being equivalent to ‘property title’, as is the case in Chorus’s
response:
“We are generally comfortable with the 30 metre separation distance requirement between
cabinets in residential areas. However, in terms of Regulation 8(3) which applies to non
residential sites, in some situations a single site may be very large, and in some instances may
encompass an entire city block (eg, Auckland University covers some entire city blocks in a
single title). In this instance, cabinets even 30 metres apart may infringe the allowable
standards under this clause for the total footprint of cabinets located at the same ‘site’. This
could similarly apply to a large rural property or a reserve. We suggest consideration is given
to amending this regulation to enable more than one cabinet to be located within the same
site, subject to a minimum separation distances, as an alternative to the current control.”
One council suggested that the linear dimensions of a site could be defined.
7.1.2 Definition of ‘vicinity’
‘Vicinity’ is used in regulations 4(4)b(ii) and (iii), and 4(5)b. For example regulation 4(4)b(ii)
states:
The second condition is that the network operator ensures that the relevant local authority
received, before the telecommunications facility becomes operational, the following: A report
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 23
that takes into account exposures arising from the telecommunications facilities in the vicinity
of the facility.
It is not clear what distances classify as being ‘in the vicinity’. One council sought legal advice
soon after the NESTF was implemented. If other councils seek advice and that advice differs,
this creates a potential for inconsistent application until the body of case law develops.
7.1.3 Measurement issues
Further guidance is suggested to cover the following situations:

when measurements are required in a staged site implementation

how antenna down-tilt settings are chosen at a site

how multiple parameters should be handled when predicting exposures

how measurements should be undertaken at sites with difficult access.
These situations are described in detail in appendix 6.
7.2 Issues that may require changes to the NESTF
but are still within its current scope
7.2.1 Regulation 7: conditions controlling antennas and
utility structures
7.2.1.1 Aligning antenna and shroud length
Industry notes an inconsistency in that antenna sizes are currently limited to 2 m in length yet
they may be concealed within a shroud 3 m in length. Removing this inconsistency was a high
priority for Telecom, 2degrees and Vodafone.
7.2.1.2 Height/co-location
Three councils identified this issue as a necessary change, while Vodafone and 2degrees
considered it a high priority. One of the barriers to co-location is the height restriction of
Regulation 7. Adding an antenna to an existing utility structure (eg, a light pole/standard) is a
permitted activity under the NESTF if the height of the replacement utility structure is no more
than the original utility structure’s highest point, plus the lesser of 3m or 30 per cent (ie, if
original height is 10m then an extra 3m additional height is permitted – 30 percent would be
larger at 3.3m). In New Zealand the average light-pole height is 12m, which means the
maximum height allowed under the NESTF is 15 m. In Europe the average pole height is 18m.
Extra height could be used to co-locate infrastructure, which would result in fewer individual
structures. However, these would house more infrastructure and have a greater visual impact,
which is contrary to the intent of the NESTF, which is to allow ‘low-impact’ facilities. Here, ‘low
impact’ refers to low-impact effect. During the 2009 stocktake views were mixed among
council planners as to the effect of a smaller number of more visually intrusive structures
compared to a higher number of less visually intrusive structures.
Industry and some councils have expressed support for co-location, recognising that rules that
increase the efficiency and ability to share existing locations reduce the need for new
locations.
24 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
7.2.1.3 Technology outgrowing the envelope: the futility of ‘future proofing’
(subclause 4)
During development of the NESTFD, consideration was given to the rapid change in technology
in telecommunications, and attempts were made to ‘future proof’ this regulation. For instance,
an ‘envelope approach’ was used in subclause 4 rather than making specific reference to
panel antennas.21
The dimensions of that envelope have now been superseded by those required for the 4G
roll-out and for multi-band antennas. These antennas are larger than those used for a single
band, but fewer of them are required to cover a given area. Changes in the dimensions of
the envelope would need to be made (if considered appropriate) to accommodate this
new technology.
7.2.2 Regulation 6: conditions protecting trees and vegetation,
historical heritage values, visual amenity values and the coastal
marine area
This regulation was included to allow councils to identify new, more stringent exclusions to the
NESTF if they considered it appropriate. Soon after the introduction of the NESTF, Wellington
City Council instigated a plan change so that telecommunications infrastructure in reserves
adjacent to the coastline required resource consent.
More recently, Hamilton City Council, in its proposed district plan, identified extensive
areas of historical value and visual amenity value. A rule in the proposed plan makes all
telecommunications facilities in roads adjoining these areas a restricted discretionary activity
and over-rides the permitted activity status of the NESTF. Industry has expressed concern at
this. It considers that the scale of these exclusions is beyond the scope of what was intended
in the NESTF, which needs to be more tightly defined.
7.2.3 Regulation 4: telecommunications facilities generating radiofrequency fields: activity status
7.2.3.1 The 25 per cent threshold (subclause 5)
The problem is this, Regulation 4(5) states that if a facility is predicted to exceed 25 per cent of
NZS 2772.1:1999 in an area which the public might reasonably access, the facility must be
tested within three months of becoming operational. There are practical issues in conducting
such testing in areas such as CBD rooftops or other areas with difficult access. Also, operators
tend to be conservative in their modelling of exposures at some sites, so that sometimes
predicted exposures are greater than 25 per cent of the maximum limit when actual exposures
are less than 25 per cent.
In these instances, where application of the 25 per cent rule is unduly increasing compliance
costs, Martin Gledhill has proposed an alternative approach through the use of the new
measurement standard AS/NZS 2772.2:2011. One of the benefits of the new standard is that it
accommodates the uncertainty of measurement. Mr Gledhill suggests that, in certain
circumstances, it would be sufficient to demonstrate that the exposure limits mandated by the
NESTF are not exceeded when the level of uncertainty is taken into account. Post-build testing
would then not be required.
21
Section 32 report, (web reference) page 27.
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 25
This is discussed further in appendix 6. In summary, the new measurement standard AS/NZS
2772.2:2011 offers an alternative approach to the 25 per cent rule, which could warrant
further investigation.
7.3
Wish list of expansions of the NESTF
Industry has identified areas that would benefit from additional national consistency. These
are yet to be considered by the Government. Consideration would be given to these in a future
review of the NESTF.
Suggestion
Description
1. National rules for deploying aerial
telecommunications cabling in the road
where existing utility networks are already
deployed aerially
Industry has suggested that it should be a permitted activity
to establish a distribution network, extend existing overhead
networks, add additional overhead lines to existing support
structures, and provide new and upgraded existing
connections overhead to adjacent customers. It considers
that a maximum line diameter could be provided, which
would be consistent with the approach adopted in the
NESTF for telecommunications cabinets in order to alleviate
community concern about adverse visual amenity impacts.
This was a high priority addition for Chorus.
2. Nationally consistent provisions for
undertaking works by a utility operator
within the drip line of protected trees in
Auckland
This could be a permitted activity and could include all
scheduled or council-controlled trees on roadside reserves in
accordance with a council approval tree management plan.
(Chorus spends $4 million annually on arborists in Auckland.)
3. Expanded provisions to cover upgrades of
existing sites in all areas, to facilitate
technology developments
This was a high priority change for Vodafone.
4. National consistency in treatment of all
telecommunications infrastructure in district
plans, which would include all network lines
This was also suggested by one council.
5. Expand the NESTF to cover new stand-alone
sites on private land in low sensitivity
environmental areas
This could include industrial, commercial and rural land, with
appropriate exclusions for heritage, high amenity overlays.
6. National provisions that facilitate co-location
of telecommunications operators
This is a broader interpretation of co-location and could
include exchanges (eg, the multi-party use of designations).
7. Expand the NESTF to cover the installation
and operation of equipment inside existing
exchanges
Industry considers that the installation and operation of
equipment inside existing exchanges could be allowed as a
permitted activity.
26 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
8
Conclusions
The Resource Management (National Environmental Standards for Telecommunication
Facilities) Regulations 2008 is just one regulatory instrument in a wide range of regulatory
requirements controlling the installation and operation of telecommunications infrastructure.
This outcome evaluation suggests that it has largely achieved what it set out to do.
It is an example of circumstances where a national environmental standard can be effective. In
this case it has a very narrow scope, covering issues where there is little local variation to take
into account. Telecommunications technology is the same around the country as are radiofrequency effects.
The evaluation also highlighted the limitations of the tool. The regulations require
maintenance so they remain fit for purpose, and whether they require maintenance requires
an ongoing environmental scan.
8.1
Has the NESTF met its objectives?
The NESTF has met all five objectives, though some with more qualifications than others. The
NESTF has assisted industry in designing and sourcing equipment for roll-outs, with the proviso
that New Zealand does not set international design standards. Care needs to be taken that
NESTF rules do not stifle innovation. It has been instructive that one such rule, which had been
carefully drafted to be ‘future-proof’, may be stifling innovation and technological advances.
The NESTF has been successful in reducing timeframes, and compliance costs, for mobile
providers. Industry estimates that $3.2 million in direct costs have been saved, and that over
$10 million may be saved over the duration of the 4G roll-out. While it has created intangible
benefits for fixed-line operators (and these benefits are deemed to be worthwhile) tangible
benefits are only just starting to be realised.
The NESTF has been successful in reducing the timeframe, and lowering costs, for the
availability of new services to consumers in the mobile market. Industry considers that entry of
the third mobile provider, 2degrees, was accelerated because of the NESTF. This has increased
competition in the sector.
The impact of the NESTF on fixed-line services is unclear. It increased cabinet installation costs
for the 2009/10 Fibre To The Node project due to the need for more resource consents and
the need for information provision. However, costs are decreasing for Ultra-Fast Broadband
(UFB) cabinets as councils and operators become more confident with the NESTF provisions.
Resource Management Act 1991related processes will not have affected the speed or cost of
rolling out the fibre itself. This is a corridor management issue, which involves a complex
interaction of factors.
Generally, the NESTF has reduced workload for single processes such as permitting cabinets. In
terms of reducing overall workload (which was not the objective, but which may have been the
more relevant metric) the picture is mixed, and the change in council workload since the
NESTF was introduced varies. For many councils, telecommunications did not generate much
work either before or after the NESTF was introduced. At the other extreme, Auckland Council
has the critical mass for a specialist Major Infrastructure Unit, which augments the efficiencies
of the NESTF.
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 27
We found that total workload was a function of whether:

the roll-out was occurring in the council area

it was UFB or mobile (because the majority of mobile infrastructure is installed outside of
the road reserve)

the operator requests certificates of compliance (not all do, especially for cabinets)

the council requires information packs for permitted activities such as cabinet installation,
and how many radio-frequency reports and other correspondence they had to handle.
What was clear is that it is tricky for central government to predict the effect of even a minor
regulation such as this NESTF on individual councils.
Whether an appropriate balance has been reached between local participation in community
planning and cost-effective national infrastructure depends on one’s perspective. Industry
thinks that it has. Local interests are addressed by the provisions of Regulation 6 and, when an
activity is not permitted by the NESTF, by the rules in the district plan. These take local
interests into account.
The majority of councils also believe that a balance has been struck, although there is a
significant minority who don’t know. Two of the three councils who did not think that a
balance has been struck were concerned that there was not enough interaction with council,
so that sometimes facilities were not sited in the best place. Operators should engage with
their communities, whose concerns include fears that the infrastructure will block their view,
will affect their health (particularly their children’s health) and/or reduce property values.
This evaluation did not assess whether the NESTF has had an impact on property values. It
did explore whether the safety limits placed on radio-frequency emitting devices are still
relevant, and expert advice suggests they are. Further, an intergovernmental committee on
the health effects of non-ionising radiation meets every six months and has a watching brief to
appraise all new research in this area. For some community members, however,
these safeguards are insufficient, and the issue of health effects of radio-frequency is real
and pressing.
8.2
Is the NESTF still fit for purpose?
There are signs that a gap is emerging between the NESTF and technology developments in
telecommunications. New antennas required for the 4G roll-out do not comply with the NESTF
rules. There are some technical issues with the measurement of radio-frequency exposures for
some of the newer equipment, with one solution requiring a change to the NESTF to resolve
the issue.
The low-impact focus of the NESTF may be having the perverse consequence of adding to the
proliferation of antennas on towers because of height limits. The NESTF was designed to
permit only ‘low-impact’ facilities (eg, a single antenna on a height-limited “replacement utility
structure”). If replacement utility structures were made taller, they could house more
infrastructure, resulting in fewer individual structures. Some communities may prefer this
alternative, but at the moment it requires resource consent, while the NESTF creates the
incentive to take the lower-impact, single-antenna-on-pole approach.
28 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
Appendix 1: Participants in the evaluation
The following organisations and individuals contributed to the evaluation. The views expressed
were those of the individuals involved and may not reflect the position of the organisation.
Local government
Auckland Council
Timaru District Council
Christchurch City Council
Waipa District Council
Wellington City Council
Selwyn District Council
Dunedin City Council
Horowhenua District Council
Hutt City Council
Ashburton District Council
Whangarei District Council
Thames Coromandel District Council
Hastings District Council
Masterton District Council
New Plymouth District Council
Queenstown Lakes District Council
Rotorua District Council
Waitaki District Council
Invercargill City Council
Clutha District Council
Porirua City Council
Hurunui District Council
Westland District Council
Nelson City Council
South Wairarapa District Council
Telecommunications industry
Telecommunications Forum (comprising Telecom New Zealand, Chorus New Zealand,
Vodafone, Two Degrees and Vector).
Ministry of Business, Innovation and Employment (Radio Spectrum Management,
Communications and Information Technology Policy)
Commerce Commission
EMF Services (Martin Gledhill)
NZ Contractors Federation
New Zealand Utilities Advisory Group
Bronwyn Howell (Institute of Competition and Regulation)
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 29
Appendix 2: Council survey
Method
The survey was designed to address the council-specific objectives of the National
Environmental Standards for Telecommunication Facilities (NESTF) and to follow up on issues
identified in the six-month stocktake. It was also informed by discussions with a city council.
The same council undertook the pilot of the survey.
The survey was deliberately designed to be easy to complete. Indicative response ranges were
provided where numerical data was required to save council officials the trouble of having to
sort through files for exact figures.
The survey was distributed to all consent managers on 12 April 2013. A follow-up email was
sent out two weeks later. Before the survey went live, and as a safeguard against low
response, a minimum set of councils was selected in order to provide a range of population
density and growth characteristics, as this would affect the level of telecommunications
installation activity:

dense urban: Auckland Council, Wellington City Council, Christchurch City Council

high growth semi-rural: Selwyn, Ashburton, Waimakariri, Queenstown Lakes

medium growth: Porirua, Horowhenua, Nelson.
At the end of April any council in the above group that had not responded to the first follow up
received a phone call. An extra group of five city councils and larger district councils also
received follow-up phone calls to cover non-response in the core set. This resulted in a
response in all but two councils.
In mid-May 10 councils were chosen at random from those that did not respond (that were
not included in the above) to find out reasons for non-response. Contact was made with seven
of these. There were two main reasons for lack of response, either a small rural council dealt
with very few telecommunications installations, or the survey had been overlooked.
Any council that responded with significant text in the comment fields was phoned for a
follow-up conversation. Ministry officials also met with Auckland Council.
Cover letter
This was emailed to resource consent managers at all territorial authorities on 12 April 2013.
Dear All,
Evaluation of the National Environmental Standards for Telecommunication Facilities 2008 (NES-TF)
Please reply by Monday 29 April 2013
The NES-TF are now five years old and the Ministry for the Environment wants to understand the
practicalities local authorities face when implementing them. We also want to know whether the NES-TF
are delivering the intended benefits, or whether there are opportunities for improvement.
The enclosed survey offers local authorities the opportunity to comment on NES-TF operation and
outcomes. We seek information about:

day to day operation

levels of use
30 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities

current or foreseen challenges in implementing specific provisions of the NES-TF.
We invite you to complete an online survey following this link – [ ]
If you create an account when invited to do so, this will enable you to complete the survey over a
number of visits before you finally submit the survey response.
We will be using information from the survey to evaluate the effectiveness of the NES-TF and to provide
a report to the Minister for the Environment. A report of overall results (not those of individual councils)
will be made available on the Ministry for the Environment website.
If you have any questions, other than purely administrative questions, regarding this survey, please
contact MfE [names and numbers deleted].
First screen of online survey
The National Environmental Standards for Telecommunication Facilities
The Resource Management (National Environmental Standards for Telecommunication Facilities)
Regulations 2008 (the NES) came into effect in October 2008.
The Ministry for the Environment is conducting an evaluation into how well the objectives of the NES
have been met.
These objectives were to provide for a nationally consistent planning framework for low impact
telecommunications infrastructure on road reserves that would:

assist in network and equipment design and equipment sourcing for roll-outs

create a reduction in compliance costs and timeframes for service providers

reduce the timeframe and lower costs for the availability of new services to consumers

contribute to a reduced workload for councils in processing and determining consent applications

set an appropriate balance between local participation in community planning and cost effective
national infrastructure investment.
This survey has been sent to all territorial authorities and will gauge each council’s experience of the
NES. The evaluation will be completed by June 30th 2013 and the report will be posted on the Ministry’s
website. Any consequential amendments to the NES will follow the legislative process.
Responses are confidential and no individual council will be identifiable in the final report.
[link to survey]
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 31
Second screen
[Note: the formatting has been removed for the survey.]
The survey will take about 15 minutes to complete.
You do not have to fill it all in over one session.
As long as you are logged in you can save and exit as many times as you like.
When you have completed the survey select ‘submit’.
Please complete the consultation no later than 6 pm, Monday, 29th April.
Note: In this survey the term ‘telco facilities’ means telecommunications facilities installed by a licensed
network operator.
Compulsory questions are marked with a star (*)
Your details / Name of your council / Your email
Workload
Workload refers to the work involved in administering permitted activities, processing
resource consents, undertaking compliance monitoring and liaising with communities.
1. Thinking about your council’s workload in providing for telco facilities, whether covered by
the NES or not, how has this changed since 2008? *
It has increased / decreased / stayed the same / hard to say because it comes in waves /
don’t know
Please provide more detail
2. Without the NES, what would that workload have been?
Much greater / Much less / About the same / Can’t say
Please provide more detail
Resource consents
3. Does your council collect data on the number of resource consent applications for telco
facilities?
Yes / No / Don’t know
(If yes) In what year did the data collection commence?
4. In the past 12 months, approximately how many applications for telco facility resource
consents were received by your council? If your council does not collect specific data, please
estimate the band.
0/1–10 / 11–100 / more than 100 / don’t know
Administering the NES
5. How does your council deal with notifications and radio-frequency reports for permitted
activities under the NES, required under clause 4(4)(a) and (b)? (choose all that apply)
Filed in an electronic system / Filed in a paper system / Not retained / Don’t know
32 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
Community
6. Since 2008 how many new installations of telco facilities have received complaints from
members of the community? Please estimate the total number.
0/1–10 / 11–100 / more than 100 / don’t know
(if > 0 and not DK) What are the main reasons for the complaints? Who in the community is
making the complaints? Please summarise. How have the complaints been resolved?
7. One of the objectives of the NES is to set an appropriate balance between local
participation in community planning and cost-effective national infrastructure investment. Do
you think that an appropriate balance has been achieved?
Yes /no / don’t know. (If no) Please describe why you think this is the case ? What could be
done to rectify the balance?
Learning
8. How useful have you found the National Environmental Standards for Telecommunication
Facilities users’ guide?
Very useful / useful / not useful / not at all useful / don’t know, never used it
If you think the Guide requires any additions or corrections please list them below. *
9. Would your council like to see any changes made to the NES?
Yes / No / Don’t know. (If yes) Please describe the changes
10. Please add any other comments about the NES you would like to make.
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 33
Appendix 3: Council survey results
Q1a. Change in workload, by council type
City
District
Total
Increased
2
7
9
Decreased
2
2
4
Stayed same
2
6
8
Lumpy
0
3
3
Total
6
18
24
Note: Auckland not included: council has only existed since 2010
Q1b. Change in workload, by stringency of previous city/district plan
Less
As stringent or more so
Total
Increased
4
4
8
Decreased
3
2
5
Stayed same
5
3
8
Lumpy
2
1
3
14
10
24
Total
Note: Auckland not included: council has only existed since 2010. Stringency is based on April 2006 assessment of plans
undertaken for the Ministry by Incite, Christchurch.
Q2a: Without the NES what would the workload have been (by council type)?
City
District
Total
Increased
1
0
1
Decreased
0
3
3
Stayed same
5
14
19
Don’t know
0
1
1
Total
6
18
24
Note: Auckland not included: council has only existed since 2010.
Q2b: Without the NES what would the workload have been (by stringency of city/district
plan)?
Less
As stringent or more so
Total
Increased
0
1
1
Decreased
3
0
3
Stayed same
10
9
19
Don’t know
1
0
1
14
9
24
Total
Auckland not included: council has only existed since 2010.
34 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
Q3. Does your council collect number of telco resource consents?
City
District
Total
Yes
3
13
16
No
3
5
8
Don’t know
1
0
1
Total
7
18
25
Q4: Estimated* number of resource consent applications received in past 12 months
City
District
Total
None
1
1
2
1–10
3
15
18
11–100
3
1
4
More than 100
0
0
0
Don’t know
0
1
1
Total
7
18
25
* Note response to Q3: some large city councils do not collect data
Q5: How does your council deal with RF reports?
City
District
Total
Filed in electronic system
4
6
10
Filed in paper system
0
5
5
Combination of the above
3
6
9
Not retained
0
0
0
Don’t know
0
1
1
Total
7
18
25
Q6: In the past 12 months how many installations have received complaints?
City
District
Total
0
0
6
6
1–10
6
11
17
11–100
0
0
0
>100
0
0
0
Don’t know
1
1
2
Total
7
18
25
Reason for complaint: visual impact, health, property values, traffic hazard
Who made the complaint: adjacent land owners
How was the complaint addressed: information provision. Negotiation with operators. Public
meetings
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 35
Q7: Do you think that an appropriate balance has been achieved?
City
District
Total
Yes
4
10
14
No
1
2
3
Don’t know
2
6
8
Total
7
18
25
Why was a balance not achieved: results in appropriate siting. Not enough liaison with councils
and corridor managers leads to street clutter. Council’s say on matters is very restricted
Q8: Rating of Users’ Guide
City
District
Total
Very useful
1
2
3
Useful
4
9
13
Not useful
0
1
1
Not at all useful
0
0
0
Don’t know, never used it
2
6
8
Total
7
18
25
Possible additions to the Users’ Guide?: Co-location; make standards simpler, more user
friendly
Q9: Would your council like to see any changes made to NES?
City
District
Total
Yes
2
4
6
No
3
9
12
Don’t know
2
5
7
Total
7
18
25
What are those changes: co-location, notification of residents within 100 m radius before
council approached; fix interpretation of ‘site’; all new installations should be approved by
council; the NES should have replaced all of the rules in the city plan.
36 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
Appendix 4: Discussion guide for the
Telecommunications Forum
This was forwarded to the Telecommunications Forum as a guide for their responses.
Overall impact of the NES
How has the telecommunications ‘landscape’ changed over the past decade from an industry
and a consumer perspective?

How has the NES contributed to these changes?

Has the NES made things ‘easier’?

Has the NES met its objectives?
Are the regulations achieving their intended purpose in terms of:

sourcing infrastructure and engineering practices

shortening timeframes and lowering compliance costs

reducing timeframes and lowering costs for the availability of new services to consumers

providing an appropriate balance between community participation in planning and
telecommunications infrastructure investment?
Working with the NES
How useful is the users’ guide?
How useful is the householders’ brochure?
Is any further work required on either?
Is work required on additional communications?
Are there any residual problems with implementation?
Working with councils
Are roles and responsibilities clear between council and industry?
Is the expected national consistency being realised?

If not, why not?
Has the NES reduced the number of consents needed to install telecommunications facilities?

If yes, how have industry practices changed?

If not, why not?
Do you obtain codes of compliance for your installations that are permitted under the NES?

If yes, in what circumstances?

Are there any issues in obtaining them?

Are councils consistent in the way they issue them?
What monitoring and compliance work do you do?
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 37
Radio-frequency
What is your experience of working with the community over concerns with radio-frequency
fields?
Wish list
Would industry like to see any changes made to the NES?
38 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
Appendix 5: Details of issues
Table A5.1:
Issues with the current NESTF
Suggested issue
Relevant NESTF regulation
The problem
Possible solution
Definition of ‘vicinity’
4(4)b(ii), 4(5)b
See section 7.1.2
Definition of ‘site’, and the 30 m rule
8
See section 7.1.1
What constitutes a swap out
Regulation 7
Whether a replacement structure can be in a
slightly different location to the original pole (up
to 3 m, for example) to allow for the larger
foundation of the replacement pole and existing
services beneath the site. Some inconsistency in
interpretation across the country.
Guidance
Interaction between minor NESTF infringements and district
plan rules
Regulation 5
Currently a facility may not comply with the
NESTF for a minor technical infringement (such
as another cabinet 30 m away) and then there is
uncertainty as to which rules in the plan are
relevant. Industry considers that the assessment
criteria should be limited to the nature of the
non-compliance with the NESTF rules.
Guidance as to which district plan rules need
to be assessed with a non-NESTF-compliant
proposal.
Aligning antenna and shroud length
Regulation 7
See section 7.2.1.1
Height/co-location
Regulation 7
See section 7.2.1.2
Dimensions of the envelope for antennas
Regulation 7(4)
See section 7.2.1.3
Treatment of lightning rods and minor ancillary antenna
such as GPS in the allowable envelope (subclause 4)
Regulation 7(4)
While the treatment of ancillary equipment is
made clear on page 21 of the users’ guide, this is
not the case in the NESTF.
NESTF wording could be amended
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
39
Suggested issue
Relevant NESTF regulation
The problem
Scope of conditions protecting trees, heritage, visual
amenity and the coastal marine area
Regulation 6
See section 7.2.2
Radio-frequency and ‘small-scale solutions’
Regulation 4
Industry considers that ‘telecommunications
facility’ could be defined to exclude small-scale
solutions, such as metro sites and femto-cells,
which generate miniscule levels of radiofrequency, so that they do not need reports of
radio-frequency compliance
Guidance
Time taken to remove redundant cabinets
Regulation 8
Sometimes new cabinets are installed with the
old ones still in place until the new one is fully
connected and commissioned, to enable
continuity of service. The two cabinets could be
in place for up to 12 months, technically not
complying with the NESTF. Industry would like
some clarity around this transitional situation,
including an allowable timeframe for
commissioning a new cabinet and removing a
redundant cabinet
An NESTF amendment and/or clearer
guidance may help.
Police and other services that have networks of
communications equipment do not have to
comply with radio-frequency exposures if the
district plan covering the area they are working
in is silent on the matter.
Identified in 2009. Solutions offered at that
time were to include the Crown with
network operators or extend radiofrequency provisions to everyone.
New Zealand police and other emergency services not being
covered by the NESTF
Not applicable
40 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities
Possible solution
This problem was identified in 2009. Then a
‘temporary activity allowance’ was the
suggested solution.
Appendix 6: Measurement issues
Regulation 4(5) states that measurements are required when predictions indicate that a device
will produce radio-frequency levels that reach or exceed 25 per cent of the maximum allowed
in NZS 2772.1:1999. There are some practical issues with measurement, and Martin Gledhill
has provided advice on how they may be dealt with. Some issues could be addressed by
further guidance, while others may require amendments to the NESTF.
The various issues are described below. Examples are provided by Mr Gledhill.
Issue 1: Choice of settings at a site (eg, down tilt) and how to deal with
multiple parameters
Additional guidance would be helpful on the choice of certain settings for a site (eg, down tilts
(the angle) on antennas. Operators may calculate exposures for a range of down tilts to cover
worst-case scenarios. However, the value of the down tilt makes a big difference to where the
position of maximum exposure falls, and whether measurements are needed at all (ie,
whether the maximum will fall in an area where the public can be reasonably expected to be
present, according to NZS 277.2:1:1999).
Figure A6.1: Effect of down tilt on exposure plumes (based on an actual site)
10
25% of limit - 0 deg downtilt
25% of limit - 10 deg downtilt
Height above ground (m)
8
6
4
2
0
0
2
4
6
8
10
12
14
16
Distance from lamppost (m)
In the figure, the red line shows the 25 per cent exposure contour with a 0-degree down tilt
set, and the purple line shows the 25 per cent contour with a 10-degree down tilt set. With a
10-degree down tilt, the lowest part of the 25 per cent contour is only about 1.5 m above the
ground and measurements would be required, but with 0 degrees down tilt the lowest part of
the contour is 3 m above the ground, and measurements would not be needed.
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 41
Difficulties that might arise include the following.

If the operator makes worst-case calculations based on (in this case) a high value of down
tilt, but in operation a different value is used, then measurements may be made
unnecessarily.

If the operator makes calculations using one down tilt, but when measurements are made
a different down tilt is set, the measurements may not show what the worst-case
exposures might be.
Issue 2: Staged site implementation
Currently, cell sites may operate over three different frequency bands with three different
technologies. When the operator prepares a report for the site, they will tend to assume the
maximum configuration of the site (all three frequencies and technologies). However, the
installation may be staged, leading to two questions.
1.
2.
When should measurements be made? Should it be:

when the site first becomes operational (as required under regulation 4[5]), when
exposures will not exceed 25 per cent of the public limit, or

when the site is fully configured, and when the 25 per cent threshold may be
exceeded?
If certain technologies are to be added later, in some cases it is possible to extrapolate
before installation to estimate maximum exposure, but in some cases it is not.
The users’ guide could be updated to explain these two situations.
Issue 3: What to do when it is difficult to access an area to make measurements
This is an issue in city locations. Sometimes it can be very difficult to arrange access to where
exposure measurements may be needed; for instance, when a site on one commercial
property produces exposures that may exceed 25 per cent on the roof of an adjoining
commercial property.
This could be addressed with new guidance on what should be counted as a public area in a
commercial building.
Solutions
1.
Guidance. As already stated, each of the issues warrants extra guidance.
2.
An alternative to the 25 per cent threshold approach. This is an approach suggested by
Martin Gledhill, whereby the measurement does not assume that the radio-frequency
field is a single wave (as is currently the case). Instead, the interference pattern caused by
reflections of radio-frequency waves off the ground is taken into account. Guidance on
how to do this would need to be provided for measurement operators and councils alike,
but it would result in an estimate of exposure plus the level of uncertainty of that
measurement.
The new measurement standard AS/NZS 2772.2:2011 provides a method for how to compare a
measurement and its associated uncertainty against a limit.
If:

L = the maximum exposure allowed by NZ 2772.1:1999

X = the measured exposure
42 Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities

U = the measured uncertainty

U0 = a threshold value for the uncertainty (provided by the standard)
then a measurement X has a level of uncertainty of +/- U. The NESTF suggests that if the
uncertainty is greater than U0, the site complies if and only if X + (U–U0) < L.
This may be a suitable approach for staged sites or sites with difficult access, and is an
alternative to the 25 per cent threshold. Measurement operators would have to be trained in
the approach, but they need to come up to speed with the new AS/NZS 2772.2:2011 anyway.
Adopting this alternative would require an amendment to the NESTF.
Report of the Outcome Evaluation of the National Environmental Standards for Telecommunication Facilities 43