EME & mobile base station compliance | ACMA

EME & mobile base station compliance

Regulation of electromagnetic energy

Mobile communications devices, such as mobile phones, wireless modems and base stations (including mobile phone towers) produce electromagnetic energy (EME) in order to transmit a signal. Enforceable standards are in place which require that EME emissions do not exceed levels which the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) has recommended as being safe.

Human exposure to EME from base station transmitters (such as mobile phone towers) is regulated by making compliance with ACMA standards a condition of apparatus and spectrum licences. General information about mobile phone towers and EME is available on the following ACMA page. More detailed information about these arrangements can be found in the supplier section of the ACMA’s EME hub. Mobile and portable devices are subject to separate EME requirements that apply at the point of supply to the market.

ARPANSA’s role—recommending standards

ARPANSA uses its scientific expertise to recommend safe limits for human exposure to radiofrequency (RF) fields in the frequency range 3 kHz to 300 GHz. The recommended limits are designed to ensure that known adverse health effects do not arise from exposure to RF fields. These limits include a significant safety factor. That is, the limits are set well below the level at which all known adverse health effects occur.

The limits set by ARPANSA are published in the Radiation Protection Standard - Maximum Exposure Levels to Radiofrequency Fields - 3 kHz to 300 GHz (the ARPANSA Standard).

EME and mobile base stations

The ACMA regulatory regime for EME from mobile base stations

The ACMA regulates EME from mobile base stations by imposing conditions on the radiocommunications licences it issues to mobile telecommunications carriers.  A licensee must satisfy all conditions of the licence, including those relating to EME. The ACMA imposes these licence conditions through the Radiocommunications Licence Conditions (Apparatus Licence) Determination 2015 (the LCD).

The EME licence conditions apply to transmitters that operate under both apparatus and spectrum licences. The LCD stipulates that the level of emissions from a transmitter must not exceed the limits for the general public exposure category of the ARPANSA Standard at places accessible to a member of the general public.

Examples of places accessible to a member of the general public include:

  • private residences
  • public parks
  • roof tops with a transmitter antenna located on the roof top, where access is not restricted by the site manager or operator.

Find out more detailed information about what suppliers must do to comply with EME exposure requirements.

The ACMA’s compliance program

In general, the ACMA prioritises its compliance work based on the risk of harmful interference, high risk to spectrum utility and risk to public safety or public interest. The ACMA’s EME base station compliance program focused exclusively on compliance by mobile phone carriers with the EME exposure licence conditions. This in turn ensures that base stations are not producing emissions greater than the public safety health limit as recommended by ARPANSA and enforced by the ACMA.

The ACMA conducted this compliance program from May 2013 to February 2014 in response to public enquiries, complaints and consultation about exposure to EME from mobile base stations. The compliance program involved inspections which were conducted in order to test, in a resource efficient way, the level of compliance by mobile carriers with the requirements of the LCD. 

Compliance program methodology

ARPANSA coordinates a survey of environmental EME levels arising from mobile phone base station antennas. The purpose of this survey is to confirm that the highest levels of measured RF EME due to these antennas is within the limits set by the ARPANSA radiofrequency exposure standard and consistent with the predictions made in the Environmental EME Report relevant to that installation. The survey, conducted to the highest confidence level of testing by assessors accredited by the National Association of Testing Authorities (NATA), has consistently returned results that confirm predictive modelling produces a worst case scenario when compared with empirical measurements.  

The ACMA accepts that predictive modelling is a sound basis for making an EME assessment and that the testing performed through the ARPANSA coordinated survey provides sufficient supporting empirical testing evidence. A program based on random site selection is therefore not the most efficient predictor or method for detecting non-compliance.

The program was designed firstly to identify mobile base station sites where the potential for increased exposure to EME existed due to the proximity of mobile base station panels to areas of general public access (such as residences, shopping centres and schools). Compliance was then assessed from available compliance data and, in cases where compliance could not be verified  with a high level of confidence, the site was subject to a comprehensive compliance audit.

The program consisted of three graduated phases each of which comprised increasing levels of auditing and analysis:

  1. Site inspections
  2. Compliance verification   
  3. Compliance records audits

Site inspections

A site inspection is a resource efficient way to initially assess the potential for EME exposure without the need to take EME measurements.  In conjunction with information about the transmitter obtained from the ACMA’s radiocommunications licensing database, an inspection provides a measure of confidence that the installation is not operating in a way that is inconsistent with the licence conditions.  Therefore, an Inspector will assess site accessibility and controls, signage, antenna and tower installation practices with respect to the proximity of public places. 

ACMA field staff inspected a total of 949 mobile phone tower sites around Australia. This is about five per cent of all mobile phone towers in Australia. Field staff assessed the sites against a set of criteria based on the known performance characteristics of mobile base stations and against compliance documentation for each mobile base station, which is available on the Radio Frequency National Site Archive (RFNSA) website.  A site inspection is a way of determining whether there are any specific environmental factors that may increase the potential for EME exposure in excess of the permitted levels as a first step in the compliance process.

EME site assessment criteria

The criteria for assessing whether there was a risk of elevated EME exposure included mobile base station panels in proximity to areas of general public access. The program also considered site density, this allowed the inspection program to cover a multitude of different types of sites, including:

  • single carrier sites
  • multi carrier sites
  • mobile base stations co-located with other transmitting services
  • sites with diverse technologies (i.e. 2G/GSM, 3G/UMTS and 4G/LTE sites).

Any other specific characteristics of the environment or site, including a lack of access controls that might give rise to a potential risk that elevated EME exposure levels could be present were also considered.

Of the 949 sites inspected, 121 proceeded to additional compliance verification.

Compliance verification and risk assessment

This process involved examining the compliance records available on the RFNSA website for those sites identified as having a potential for elevated EME exposure. The RFNSA website holds EME environmental reports and EME compliance information produced by mobile carriers for each mobile base station in Australia. The ACMA is able to access all compliance information including the results of modelling and testing stored on this site. Members of the public are able to access EME environmental reports which set out the EME exposure levels in the vicinity of mobile phone base stations.  The ACMA verified compliance of 83 sites of the 121 through this process.

Compliance records audits

Where the ACMA conducted a risk assessment and found that there was insufficient information to be sure that a potential risk of elevated exposure had been mitigated, the ACMA conducted a comprehensive compliance audit.  

The ACMA conducted compliance audits of 38 sites. These audits assessed compliance against the limits in the ARPANSA Standard and required the carriers to provide a comprehensive suite of compliance documentation comprising:

  • a declaration of conformity, for the transmitter
  • the name and qualifications of any person who has assessed the transmitter for compliance
  • the dates of any assessments
  • the results of any assessments obtained by measuring or calculating RF fields in accordance with the standard AS/NZS 2772.2
  • details of the transmitter including its power level, gain, size, tilt, manufacturer, model number and emission designator 
  • evidence (including measurements or predictive modelling) that the specific EME concern raised during the inspections had been effectively mitigated.

Details of risks identified and audit result

The issues identified with the 38 mobile sites audited included:

  • new apartment buildings constructed within 10 metres of transmitting antennae situated on a neighbouring building
  • potential for members of the public to access antennae
  • EME issues identified where dwellings were directly underneath antennae
  • discrepancies with RFNSA data, or lack of RFNSA data for particular sites.

The following table provides an overview of the number of inspections conducted by state/territory, the number of these inspections that raised potential concerns and those that proceeded to a comprehensive audit.


Inspections conducted

Potential EME concerns

Audits conducted

New South Wales




Northern Territory








South Australia












Western Australia








In all cases, mobile carriers were able to demonstrate, at audit, that the issues identified as potentially leading to a risk of elevated EME exposure had been mitigated and that respective transmitters were fully compliant with the EME conditions contained in the LCD. Carriers relied on a combination of both predicative modelling and testing methodologies to demonstrate compliance.

In summary

As a result of the compliance program, the ACMA is confident that mobile carriers:

  • have established a high level of compliance with the EME licence conditions
  • have a clear understanding about EME compliance obligations and associated record keeping requirements
  • have processes in place to ensure that compliance assessments accurately reflect current environmental and site conditions
  • are appropriately addressing the underlying risk of EME exposure from mobile phone base stations.

See also ARPANSA Base Station Survey 2007–2013

Last updated: 25 January 2017