Risks of Deploying Telco Equipment on your rooftop. Chapter 1
This article shares the challenges in engaging the InfoComm Media Development Authority (IMDA) with the Telecommunication companies SingTel, StarHub, M1, and Simba (Telcos) since 2019 about COPIF2018 deployment consequences to rooftops.
It consists of these four chapters.
Chapter 1: MCSTs are forced to provide Mobile Installation Space (MIS) in their rooftops to the Telcos for free under IMDA’s COPIF2018.
Chapter 2: Rooftop Load design considerations when deploying Mobile Communication Equipment (MCE) on the rooftop.
Chapter 3: Engage an experienced Professional Engineer (PE) to check the Quality the reports submitted by Telcos for MCSTs approval. Errors might lead to difficulties in determining the root cause of damages, years later.
Chapter 4: The MCE deployment risk considerations not covered by COPIF2018, IMDA and Telcos. There are long term risks on the building maintenance covering water proofing, cable conduits, parapet wall durability, lightning protection, radiation, etc.
Information discussed are available in the public domain and individual persons are anonymized.
The author is an experienced Instrumentation System Engineer with published civil engineering conference papers and had developed Finite Element Analysis modelling software in the 70s.
Acronym used:-
CD : Collateral Damages
COP : Code of Practice
CT : Cable Trunking
CTP : Cable Trunking Plinths
IMDA: InfoComm Media Development Authority
MCE : Mobile Communication Equipment
MCST : Management Corporation Strata Title
MIS : Mobile Installation Space
PC : Public Consultation
PE : Professional Engineer
PE#1 : CH****** (2***)
PE#2 : YE****** (3***)
PE#3/AC#1 : LE****** (2***)
RD : Rooftop Damages
RFSS : RF Signal Strength
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Chapter 1: MCSTs are forced to provide Mobile Installation Space in their rooftops to the Telcos for free under IMDA’s COPIF2018.
1.0 There are many MCE installed in building rooftops in Singapore. Complying with COPIF2018 carries Collateral Damage (CD) risks, which are not considered in COPIF2018.
The COPIF2018's known risks are addressed by IMDA. When there are CD, MCST is left alone to deal with these CDs. Some of these CDs are waterproofing and cracks reliability problems, which will surface only after a few years of weathering, and more details are found in Chapter 4.
1.1 MCST had been engaging IMDA and Telcos since 2019 to remove the MCEs, which damaged the waterproofing membrane and rooftops. By August 2023 (picture below), all the MCEs were removed from the rooftops to prevent further CDs. The rooftop's authority and responsibility goes back to MCST.
1.2 From the satellite map view, the rooftops, with MCEs and Cable Trunking (CT), show dark green color due to algae and moss growth. While those, without MCEs and CT, show light green color. The MCE and Cable Trunking Plinths (CTP) hinder the flow of rainwater into the side drains. Over time, the water ponding caused the algae and moss growth. These were shown as evidence of damages, but IMDA chose to ignore these information, but could not offer any explain why there are such color differences.
The CTPs hinder the rainwater flow to the drains and cause water ponding which leads to CDs. These CTP deployments are wrongly treated as non-issues by both IMDA and Telcos as these are not COPIF2018 considerations.
1.3 Providing MIS under upon COPIF2018
In December 2018, Infocomm Media Development Authority (IMDA) introduced the Code of Practice for Info-Communication Facilities in Buildings (COPIF2018), where Telcos use the rooftop space to generate revenues, without having to pay for its rental and maintenance.
1.3.1 These rent-free MIS spaces are used to subsidize SingTel’s FY23 net profit of S$2.23 B and StarHub's FY22 net profit of S$938 M.
1.3.2 The Telcos claimed that these MCE are mainly for the benefit of the MCST residents. This is a FALSE claim, as MCST zone coverage do not require so many antennas, as 2 antennas are sufficient to cover the whole estate. Telcos must provide RF Signal Strength (RFSS) Geospatial reports, as evidence that the MCE covers mainly (90%) for MCST area.
In a Telco's RFSS plot (Green areas of -98 dBm) shows that the RFSS coverage extends well beyond the boundaries of MCST (shown as a red circle). Out of the total RFSS area of -98 dBm, 10% of the area covers MCST. A RFSS 10% coverage should never be claimed as mainly.
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1.4 In the zone, there are alternative MIS sites
A SingTel building is suitable for the StarHub, M1 and Simba MCEs. This shows that the Telcos use COPIF2018 to reduce their own operating cost at the expense of MCSTs.
1.5 COPIF2018 Public Consultation (PC) was carried out only with IMDA Industry Partners.
There are 4,593 MCSTs (data.gov.sg). No MCST owners were contacted on COPIF2018 PC to address their CD risks such as waterproofing, rooftop overloading and concrete cracks requirements. IMDA expected MCSTs to anticipate these CD risks and respond to the PC. MCST council members usually consist of part-timers and retirees, and might not be aware of the CD risks.
When conducting a PC, it is essential to actively seek inputs from affected stakeholders, including MCSTs opposing the agenda. If a PC process only involves the benefiting parties (Telcos), while neglecting opposing views (MCSTs), it risks becoming a biased rubber-stamped process and was designed to avoid an open inclusive perspective. Given that only industry partners (Telcos) were engaged in this PC, the consultation is at best an Industry Consultation with NO MCST participation, rather than a Public Consultation. The "Public" word was used to mislead citizens that the consultation had public participation.
IMDA conducted “a Briefing to Industry (by invitation)” on 7 December 2018. This COPIF2018 briefing event was carried out with Telcos. There was no briefing conducted with any MCSTs to address their concerns and CD risks.
In the COPIF2018 cover note (28 November 2018), PART I: INTRODUCTION, only these PC participants were mentioned. None of the 4,593 MCSTs were involved.
Clause 2: At the close of the public consultation on 21 June 2017 (“First Public Consultation”), IMDA received comments from 11 respondents including M1 Limited, Mediacorp Ltd, NetLink Trust, Mr ********, Sheraton Towers Singapore, Singapore Telecommunications Ltd, SP Telecoms, StarHub Ltd, SuperInternet Access, Superloop Pte Ltd, TPG Telecom Pte Ltd.
Clause 4: At the close of the Second Public Consultation on 8 June 2018, IMDA received 6 submissions from respondents, namely M1 Limited, Mediacorp Ltd, NetLink Trust, Singapore Telecommunications Limited and SingTel Mobile Singapore Pte Ltd jointly, StarHub Ltd and TPG Telecom Pte Ltd.
1.6 In Seletar area, there are a mixture of private and HDB buildings.
The CellMapper geospatial information shows the SingTel's MCEs.
There would be a number of buildings with non-accessible 0.5 kN/m2 rooftops, which could be overloaded by the Telco's 1.5 kN/m2 COPIF load cause CD.
1.7 What is the value of rooftop space to the Telcos ?
On 1 October 2021, SingTel announced an agreement to sell a 70% stake in Australia Tower Network (ATN), for S$1.87 B in cash. That transaction gives ATN, which owns 2,312 mobile network towers and rooftop sites, an enterprise value of A$2.3 B. Each site is valued at A$ 1.0 M.
MIS is a revenue-generating rent free space to the Telcos. Telcos are using the rooftop space at no cost, while the MCST has to incur operational expenses such as waterproofing, security access, infrastructure maintenance and other indirect supporting expenditures, etc.
Is this fair that MCST owners subsidize the Telco profits using COPIF2018 ?
1.8 Rooftop space considerations
Rooftops are designed primarily as an overhead environmental shelter to protect the upper floor units against the sun and rain. Our rooftop as-built drawings show only a lift room and water tank.
In COPIF2018 owner obligations state the facilities are to be provided for new development constructed, after December 2018 (COPIF2018 date), as shown in the table below. But for buildings constructed before December 2018, our as-built drawings do not show any MCE. Hence this is an unknown CD risk to MCST, and the MCE is an unintended additional load on the 45-year-old rooftop.
In COPIF2013, BCA submission clearly states it is only applicable for NEW residential buildings:-
(5)?? ???For Building Developments that comply to COPIF 2013:
Building developments with Provisional Permissions (“PPs”) or Written Permissions (“WPs”), whichever is earlier, issued on and after 1 May 2013, are required to comply with the Info-communications Development Authority of Singapore (“IDA”)’s Code of Practice for Info-Communications Facilities in Buildings 2013 (“COPIF:2013”),
If COPIF2018 did not state anything on OLD building, it is expected that the COPIF requirement for COPIF2018 is the same as that of COPIF2013, which means NOT applicable.
1.9 Is a Code of Practice (COP) enforceable by law ?
In the Telecommunication Act 1999 states in:-
clause 23 (4) states “A code of practice issued under subsection?(1) does not have legislative effect”.?
clause 23 (7)?states “The Authority may give a written notice to a telecommunication licensee, or a developer, owner or occupier of any land or building, requiring compliance with any code of practice issued under subsection?(1)”. ??????
COP is only an Industry guideline for its IMDA's partners and is not a law in clause 23 (4).
IMDA uses clause 23 (7), which is essentially a “blank cheque” written notice, to insert any COP in the Telecommunication Act. ?This blank cheque clause, which can be abused by inserting any COP, without ever affected parties being consulted about the risks and consequences.
1.10 Common Space Authority and Responsibility
In BUILDING MAINTENANCE & STRATA MANAGEMENT ACT 2004 (BMSMA), the rooftop common space comes MCST’s authority and responsibility. If the rooftop usage authority is taken away from MCST under COPIF2018, then this action is similar to a Land Acquisition method using the Telecommunication Act’s clause 23 (7). Such methods are more commonly used in third world countries.
On 6 September 2023, BCA email states "We would like to highlight that it is the MCST's duty under the Building Maintenance and Strata Management Act 2004, as the owner of the common property at Mimosa Park, to keep in a state of good and serviceable repair the common property (including the roof structure and waterproof membrane in the roof, and not limited to the area below the equipment)."
If the rooftop usage authority is given to IMDA, while BMSMA designates it's responsibility to MCST, then this situation creates a conflict in decision-making. Authority must go together with Responsibility. It becomes impractical, when the IMDA holds the Authority, but have NO Responsibility. While the MCST holds the Responsible, but NO Authority.
BCA clearly stated that common property is the responsibility of MCST.
The conflicting situation arises in MCST as the MCE was deployed as a compliance to IMDA written notice on COPIF. This COPIF2018 MCE's load is 1.5 kN/m2, while the MCST water proofing layer can only support 0.5 kN/m2.
If these MCE deployments cause water seepages into unit below, will IMDA take the responsible ? to resolve the problems of the affected owner, organize the site investigations, engage the structural and waterproofing specialists to determine for the root cause and then organize the repairs. IMDA treats COPIF2018 damages as the responsibility of MCST. IMDA and Telcos did not take pro-active steps to prevent damages on the rooftop.
1.11 Verified damages by Telco MCE to upper floor unit ceiling.
In 2022, a resident complained about water seepages in the living ceiling. Investigation found that they were caused by the Telco’s MCE. MCST is still addressing the problems in 2023-2024. Both IMDA and Telco showed no interest in this problem after the MCE was removed, as it is no longer a COPIF2018 topic and assumed that this CD has to be resolved between MCST and the Resident.
Subsequently, MCST engaged an independent PE, who confirmed that the Telco MCE had overloaded rooftop. The overloading had cause cracks in the concrete slab and the water proofing layer.
In units with false ceilings, these damages can only be inspected after the false ceilings are removed. The false ceilings masked any ceiling water stains and corrosion. It gives the owner a false sense of safety, until the roof collapses!
IMDA imposes these COPIF2018 requirements, without conducting any due diligent on building serviceability and waterproofing CD risks. IMDA had relied on Telco’s PE for MCE load compliance to COPIF2018 only. IMDA ignored water seepages, concrete corrosion, cracks, concrete spalling, overloading, parapet wall risk. Hence all MCSTs must check for these waterproofing and building serviceability requirements, shown in pictures below.
President @ West Point Society of Singapore | Leadership, Entrepreneurship
1 年Guan Hong Tan thank you for raising awareness of this slow kill detail. May MCSTs start to pay attention. For me, it does add-on to another observable symptom of a deeper systemic decay in tolerating professional incompetence & non-compliance in standards by established govt institutions. It reinforces how much lip service we pay to #safety. This share reveals to me another data point that reflects the institutional #mentalmodel towards safety. Similar to the issue of safety in transporting foreign workers versus school kids. Where it is expedient, our policies will conveniently say it is safe to transport lives in lorries without safety belts. And the institutional leadership accepts such a status quo because of the impact to biz costs. there is a difference between making policies on paper and making policies grounded in fundamentals. There is a difference between Doing Things Right & Doing the Right Thing. Too much helicopter vision can sometimes blur and blind you to the importance for details on the ground because if we are not careful, the altimeter could be faulty in indicating your actual altitude in flight. Yet until there is more #accountability from the leadership, life remains biz as usual.