Regulatory arrangements

EMC Electromagnetic compatibility

Placement of mobile phone towers

The Industry Code C564:2011 Mobile Phone Base Station Deployment, developed by Communications Alliance, covers the steps telecommunications carriers must take when deciding where to place a telecommunications facility such as a mobile phone base station.

This fact sheet explains what is and what is not covered by the code. It also gives advice on what to do if you have a complaint about something that is covered by the code.

Why is there a code?

Mobile phone network infrastructure is being built at a rapid rate to deliver new telecommunications services to an increasingly large customer base. The aim of the code is to have carriers apply a precautionary approach to the design, operation and selection of sites for communications facilities. The code also allows the community and councils greater participation in decisions made by carriers.

The code recognises that, while the current scientific consensus suggests there are no health effects associated with exposure to radio emissions at low levels from mobile phone base stations, some members of the community still have concerns.

Under the code, carriers are required to consider 'community sensitive' locations such as schools and hospitals and balance this with other factors, such as coverage objectives and engineering requirements, when deciding on placement for a site.

Who does the code apply to?

The code applies to all carriers who intend to install, are installing, are operating, or are contracting or arranging for the installation of fixed radiocommunications infrastructure used to provide a public mobile telecommunications service. The code applies to mobile phone carriers and some wireless broadband network carriers, including Telstra, Optus and Vodafone Hutchison Australia.

Only wireless broadband facilities that have a similar functionality to mobile phones, such that the customer is able to continuously use the service while moving from the reception area of a facility to another with no disruption to the service will be covered by the code. The code's consultation requirements only apply to certain telecommunications infrastructure operated by carriers and covered by the Telecommunications Act 1997. The code is not binding on other providers of radiocommunications infrastructure, such as broadcasters or operators of land mobile communications.

What is the role of local councils under the code?

The code does not place any requirements on councils. However, it does provide them with an increased opportunity to become involved in the deployment of communications facilities.

What does the code do?

The code places obligations on telecommunications carriers with respect to radiocommunications infrastructure except for:

  • infrastructure that is used to supply services on a property at the request of the occupier (and which is not for re-transmission by radiocommunications to another property)
  • radiocommunications infrastructure used for defence purposes
  • radiocommunications infrastructure used for the provision of emergency services
  • radiocommunications infrastructure used in a non-public network within an organisation
  • specified low power infrastructure.

Code obligations relating to all radiocommunications infrastructure (with the exceptions listed above) include:

  • design and operate radiocommunications infrastructure to minimise electromagnetic energy (EME) exposure
  • provide certain information to the public on request about EME for specific sites
  • develop consultation plans for certain installations at new sites
  • provide information to councils on network forward planning for the region if requested
  • turn off transmitters that are out of service
  • document their decision-making process
  • a written procedure for dealing with complaints.

Why do some installations have consultation requirements?

In general, the installation of most telecommunications facilities is approved under local council planning schemes. The consultation requirements in the code do not apply to infrastructure that requires development approval because consultation is usually part of councils' development application processes.

However, there are some installations that are exempt from development approval, the most common being low-impact facilities, which may make use of small antennas such as radiocommunications dishes erected on existing towers or buildings and designed to be unobtrusive. In practice, this means that it will mostly be low-impact facilities that will require the consultation process under the code.

What are low-impact facilities?

Low-impact facilities are generally small antennae and radiocommunications dishes erected on existing towers or buildings, which are designed to be visually unobtrusive.

The Telecommunications (Low-impact Facilities) Determination 1997 and its amendment No 1 of 1999 specifies the list of low-impact telecommunications facilities regulated by the Telecommunications Act. Under the Act, the maximum height of a low-impact facility is 6.5 metres. The most commonly installed facility is 5.8 metres high. By contrast, mobile phone towers are generally 25-30 metres high.

The determination defines where low-impact facilities may be installed based on zoning considerations. For example, a facility that is deemed low impact in an area zoned rural or industrial may not be low impact if it is installed in a residential area. A facility in an area of environmental significance, such as a World Heritage area or an area on the Register of the National Estate, cannot be designated as a low-impact facility.

The colour of a low-impact facility is often matched to its background or is one that is agreed to by the carrier and the relevant local authority.

Table 1 shows some of the most commonly installed types of low-impact facilities. The first four are radiocommunications facilities covered by the Mobile Phone Base Station Deployment Code, but the last three are not radiocommunications facilities and are not covered by the code.

Table 1: Types of low-impact facilities







Panel, yagi or other like antenna

  • ≤ 2.8m long with ≤ 3m mounting arm
  • colour matched or agreed

Low impact

Low impact

Low impact

Low impact

Array of antenna

  • ≤ 4.5m long with ≤ 2m mounting arm omnidirectional only
  • ≤ 5m apart

Not low impact

Not low impact

Low impact

Low impact

Radiocommunications dish

  • ≤ 1.8m diameter with ≤ 2m protrusion
  • attached to supporting structure
  • colour-matched or agreed

Low impact

Low impact

Low impact

Low impact

Extension to tower

  • ≤ 5m
  • max. of one extension

Not low impact

Not low impact

Low impact

Low impact

Underground housing

  • Pit surface ≤ 2 sqm OR
  • Manhole surface area ≤ 2 sqm OR
  • Underground equip shelter/housing surface area ≤ 2 sqm

Low impact

Low impact

Low impact

Low impact

Underground cabling

  • Trench, direct burial, bore or directional drill hole
  • New trench, bore or directional drill hole subject to dimensional and access to property requirements
  • May utilise pre-existing trench

Low impact

Low impact

Low impact

Low impact

Public payphones

  • Solely for carriage and content services

Low impact

Low impact

Low impact

Low impact

This is a guide only. Please refer to the Low-impact Facilities Determination and seek your own legal advice regarding compliance.

What is a community sensitive location?

While not specifically defining community sensitive locations, the code provides examples of sites that have sometimes been considered sensitive. Examples include child care centres, schools, aged care centres and hospitals.

Does that mean there can't be a site near a community sensitive location?

While carriers must consider the implications of community sensitive locations, they may still place infrastructure at such sites or nearby. The code does not specify a distance at which infrastructure must be sited from community sensitive locations.

All mobile phone base stations must comply with the mandatory regulations for EME. In some instances, locating the infrastructure away from a sensitive area can mean that it has to operate at greater power to meet service requirements, which may result in higher exposure levels in the sensitive location.

I don't like where a carrier has decided to place a mobile base station. Can I complain to the ACMA?

A complaint to the ACMA will only be valid if a carrier has not met its obligations under the code.

Under the code, a carrier must consider many factors when deciding on a site including:

  • minimising public exposure to EME
  • whether it could be a community-sensitive location
  • the outcome of consultation with councils and communities
  • service objectives
  • physical characteristics of the site, such as height and terrain
  • ability to connect with the rest of the network
  • cost factors.

No one factor is considered more important than the others and it is up to the carrier to balance their importance in site selection. Upon request, carriers must provide written procedures to the public to show what they consider when selecting a site. While documents that relate to decisions for selecting individual sites do not have to be made public, they do have to be made available to the ACMA on request.

I don't think a carrier has followed the code. How can I complain?

If you think a carrier has not met its mandatory obligations under the code, the first step is to contact the carrier and express your concerns. You will need to do this in writing. Under the code, if you need assistance to place your complaint in writing it is the duty of the carrier to provide assistance. If you are not happy with the carrier's response, you can contact the ACMA. You must show the ACMA the written complaint as well as the written response from the carrier before it can investigate.

The ACMA may investigate the complaint and will advise you about its course of action. Complaints to the ACMA should be made in writing to:

Radiocommunications Licensing and Assignments Section
Operations Branch
Australian Communications and Media Authority
PO Box 78, Belconnen ACT 2616


If the ACMA finds that the carrier has contravened the code, it may decide to write to a carrier directing it to comply with the code. However, even if a complaint is upheld by the ACMA, the site for the facility may not necessarily change.

When did the code come into effect?

The code (Mobile Phone Base Station Deployment) was registered by the ACMA and came into effect on 1 July 2012. This code was developed by Communications Alliance Ltd , following a review of the previous code (Deployment of Mobile Phone Network Infrastructure).

Mobile phone service carriers-contact details

Consultation Strategy Manager
Tel: 1300 368 387

Mobile Network Deployment Group
SingTel Optus Pty Ltd
PO Box 888, North Ryde NSW 1670

Vodafone Hutchison Australia
Community Relations Manager
Vodafone Hutchison Australia
Tel: 1300 302 703

More information

The Mobile Phone Base Station Deployment Code is accessible from the ACMA website and on the Communications Alliance website.

For more information visit the EME hub on the ACMA website or the Mobile Carriers Forum website.

You can also contact the ACMA's Radiocommunications Licensing and Assignments Section.

The ACMA has fact sheets on a range of topics.

Please note: this document is intended as a guide only and should not be relied on as legal advice or regarded as a substitute for legal advice in individual cases.

Last updated: 19 July 2016

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