Planning Statement Proposed Telecommunications Site RG10-01

Planning Statement

Proposed Telecommunications Site

RG10-01 - Hurst

Hurst Reading Berkshire RG10 0TG

Prepared by

On behalf of

Contents

1.0 Introduction 2.0 The applicant – Atlas Tower Group – a Wireless Infrastructure Provider (WIP) 3.0 The benefits and growth of mobile communications 4.0 The site and surroundings 5.0 The prior approval application 6.0 Planning Policy • Local Plan o Core Strategy 2010 o Managing Development Delivery (MDD) Local Plan 2014 • NPPF • Siting and appearance 7.0 Material considerations • Heritage impacts • Environmental impacts • Landscape/Townscape impacts • Alternative options • Public benefit (inc. any local digital strategy) 8.0 Access 9.0 Health and safety 10.0 Conclusions

1.0 Introduction

1.1 This Planning Statement is prepared on behalf of the Atlas Tower Group (‘the Applicant’) in support of an application, submitted to Wokingham Borough Council, for a 25m lattice telecommunications mast, 6 antenna, 2 transmission dishes and 8 equipment cabinets at Hurst, Reading, Berkshire, RG10 0TG. The role of the Atlas Tower Group in the UK’s national communications network is explained in Section 2 below. In this instance the proposed infrastructure will accommodate the radio coverage requirements of MBNL.

1.2 This application has been brought forward as part of the MBNL’s program for the maintenance of its overall UK network. MBNL look after all the shared aspects of the infrastructure portfolios of EE LTD and H3G (UK) LTD. This includes new roll-out, increased capacity, replacement of existing sites and upgrading of existing sites so that EE’s and Three’s customers enjoy the high quality communications network envisaged by Government and which is a growing customer-led requirement borne out by the ever increasing amounts of data travelling across this critical national infrastructure.

1.3 Finding a suitable radio site is a complicated matter. Firstly, a target search area is identified based on the radio coverage shortfall1, then surveyors (after a desk-based survey) physically search this area looking for potentially suitable sites. The main considerations, in no particular order of importance are a willing landowner, topography, availability of power and access, availability of backhaul2,any ecological considerations, heritage impacts, and planning designations. In this case, the proposal new mast will host replacement apparatus from the existing MBNL base station where the proposed upgrade of apparatus cannot be accommodated. Only after all of these matters have been assessed as satisfactory can a site be progressed to a planning application.

1.4 In this instance, the proposed communications mast is seeking to provide replacement 2G, 3G and 4G coverage and introduce 5G coverage across the area – as identified in the coverage maps which accompany the application.

1.5 This application has been taken forward in the line with the industry Code of Best Practice on Mobile Network Deployment in England3. Pre-application consultation was undertaken with Wokingham Borough Council, Hurst Ward Councillor and Hurst Community Councillor on 20/07/2020.

1.6 Access to high quality communications is an essential part of everyday social and economic life and the infrastructure to support it needs to be located where it is used. Whilst small in scale, this proposed development forms part of a larger nationwide network which delivers significant public benefit across the UK.

1 The primary consideration as this is the function of the proposed development 2 The ability to get the radio signal from an individual ‘cell’ (the mast/antennas) back into the network, by fibre as first choice, then transmission link (line of sight) 3 https://www.mobileuk.org/codes-of-practice 2

2.0 The Applicant

2.1 The Atlas Tower Group are a Wireless Infrastructure Provider (WIP) or ‘neutral host’. This means they build neutral infrastructure for use by those seeking to provide radio coverage, predominantly the Mobile Network Operators (MNOs). WIPs are an important and integral part of the UKs communications infrastructure network as they both bring new investment into the sector and help enable mast and site sharing. This is the main mechanism to reduce the proliferation of new individual base stations and is a central plank of national planning policy (discussed in more detail below). OFCOMs review of the market states the following;

201. The UK mobile sector has a range of different infrastructure models. The MNOs are vertically integrated, enabling downstream benefits generated by new investment (e.g. from retail customers or MVNOs) to be captured. ‘Neutral host’ or wholesale- only models could unlock new investment, address some of the 5G deployment challenges and reduce barriers to entry for service providers.

202. Sharing of sites and network infrastructure, such as masts and antennas, could make the deployment of 5G more cost effective. The Government will support industry initiatives to build on current MNO commercial agreements to share infrastructure, provided this does not restrict competition in the market.

203. We also anticipate that different infrastructure models may be needed in different areas and as demand evolves. There are many potential forms of ‘neutral host’ infrastructure. At one extreme, a wireless infrastructure provider might supply passive mast and tower infrastructure only. At the other extreme, a neutral host provider could deploy their own active equipment, transmitting on behalf of MNOs and MVNOs either in their own spectrum or the MNOs’ spectrum and delivering a data stream back to the MNO or MVNO.

204. Neutral host providers could help boost network coverage in the following areas: • In remote rural areas, where there could be insufficient demand to justify multiple networks; • In dense urban areas, where shared networks could be desirable in order to reduce deployment costs and minimise street clutter; and • In offices and factories, where landlords may wish to self-deploy a single network (possibly through a third party service provider) to provide coverage and capacity within the building

2.2 Atlas are in the process of investing in and building new infrastructure to help ensure that the UK has a world class mobile communications network.

2.3 Atlas also has powers under the Electronic Communications Code4. This brings with it a number of rights including, for example, permitted development rights under Part 16 of the Town and Country Planning (General Permitted Development) (England) Order 20155. This application in front of the local planning authority (LPA) uses these permitted development rights.

4 https://www.ofcom.org.uk/phones-telecoms-and-internet/information-for-industry/policy/electronic-comm-code/register-of-persons-with- powers-under-the-electronic-communications-code 5 http://www.legislation.gov.uk/uksi/2016/1040/pdfs/uksi_20161040_en.pdf 4

3.0 The benefits and growth of mobile connectivity

3.1 This infrastructure which this application seeks to establish will improve the mobile connectivity in this area.

3.2 Mobile communications now form an integral part of everyday life and connectivity provides both social and economic benefits. People’s devices provide far more than just voice services. Demand for data, through not just smartphones but other connected mobile electronic devices, is now as important as any voice function. Demand for new services and data is growing inexorably. The following graph6 shows data demand from mobile networks over just the last three years.

This increasing demand has resultant consequential demand for both additional and upgraded infrastructure such as that being proposed in this application.

3.3 The Government both needs and wants to meet this demand. Their ambitions are set out in the Future Telecoms Infrastructure Review 20187 which states (our emphasis):

The UK has good digital connectivity to meet the needs of today’s consumers. We compare well internationally for superfast broadband availability. Mobile coverage is also improving, 87% of UK landmass has a 4G signal from at least one operator (compared to 78% in 2017). However, the UK must prepare for the future. Demand for high capacity, reliable broadband will increase – particularly as homes, businesses and infrastructure become smarter.

The UK has only 4% full fibre connections and lags behind many of our key competitors. For the UK to be the best place to start and grow digital businesses, we will need much greater investment to build fixed and wireless networks that are fit for the future, and take advantage of the benefits of fixed and mobile convergence.

3.4 The realisation of this ambition will require work across all levels of government. Letters were sent to the Chief Executives of all local authorities from the Department of Culture Media and Sport (DCMS) in Spring 2019 seeking this cooperation. It states:

6 https://www.ofcom.org.uk/research-and-data/multi-sector-research/infrastructure-research/connected-nations-2019 7 https://www.gov.uk/government/publications/future-telecoms-infrastructure-review 5

Local authorities have an essential role to play as site providers. As Chief Executives, you can support investment in digital communications infrastructure by ensuring your organisations have policies and procedures in place that promote effective engagement with the digital communications industry and minimise barriers to deployment.

3.5 The main planks of Government support for new telecommunications infrastructure given through the planning system is by both legislation and policy.

Legislation Part 16 of the GPDO sets out what development code operators can undertake without planning permission. This legislation, for example, acknowledges that antennas need certain minimum operating heights and so allows for mast heights of 25m on unprotected and 20m on Article 2(3) land and public highways. To accommodate the growth in demand for mobile communications some of the limitations in Part 16 were relaxed in 2016. To accommodate further growth and realise the ambitions of Government for 5G and increased geographical coverage further relaxations are currently being considered. In bringing forward the consultation on the proposed changes the Government states:

The Government recognises that widespread coverage of mobile connectivity is essential for people and businesses. People expect to be connected where they live, work, visit and travel.

The Government is determined to ensure the UK receives the coverage and connectivity it needs…

As well as improved mobile signal, 5G networks are also crucial to drive productivity and growth across the sectors that local areas are focusing on through their emerging Local Industrial Strategies. Enabling and planning for 5G implementation is central to achieving the Government’s objective to deliver prosperity at the local level and enable all places to share in the proceeds of growth.

Planning Policy Discussed in more detail below, the National Planning Policy Framework (NPPF)8 is the mail planning policy document of the Government. Local Plan policies are required to be drafted to both accord with and support the main policy aims set out in the NPPF. Section 10 is titled ‘Supporting high quality communications’. It states:

Advanced, high quality and reliable communications infrastructure is essential for economic growth and social well-being. Planning policies and decisions should support the expansion of electronic communications networks…..

3.6 Access to fixed line networks is tangible and demonstrable, however often those using mobile networks will not know exactly where their mobile signal is coming from and how that signal is then

8 https://www.gov.uk/government/publications/national-planning-policy-framework--2 6

fed into the network. Fixed line broadband is also generally hidden from view being based around underground fibres and the existing BT (wire) phone network. The Government support for mobile communications set out above takes account of how mobile signals are delivered and that new masts are often required. These are required where people want to use mobile devices and this cuts across land uses and designations such as National Parks, AONBs and Conservation Areas.

3.7 This application is being brought forward during the Covid-19 crisis. Communication networks have been critical during this time to allow continued contact during the ‘lockdown’ please. This was acknowledged through the emergency legislation brought forward to deal with the crisis with telecommunications being categorised as a key and critical sector9.

3.8 Behavioural trends and patterns of usage in the mobile sector which have been emerging over recent years have accelerated rapidly during the lockdown – these mainly being; • Increased working from home • Increased online shopping/home deliveries • Increased use of online entertainment • Increased use of video conferencing for work and social reasons (Zoom, Teams etc) Some of the environmental benefits of the reduced travel and consumption have been readily apparent and policy makers are already seeking to capitalise on this and capture these benefits into the medium and long term. This will not be possible without an advanced communications network across the UK.

3.9 The maintenance of productivity as significant numbers of the workforce worked from home, combined with extra-flexibility and reduced travel time experienced by home workers, will mean this trend should become normalised behaviour. Remote access to healthcare services and even education (schools and Universities) adopted during the ‘lockdown’ will also lead to faster adoption of online provision of services as the new normal. Again, this will not be possible without an advanced communications network across the UK.

3.10 The proposal in front of the LPA will improve mobile connectivity locally – it forms part of the wider UK network. In coming to planning decisions, balancing competing factors is inherent in the assessment of any application. The foregoing demonstrates that in making that assessment, the weight that should be afforded to the provision of network infrastructure is very significant. Access to networks is not a luxury or discretionary, it underpins the fabric of our societal and economic lives. This public benefit is discussed further before (paras 7.5 – 7.8)

9 https://www.gov.uk/guidance/covid-19-guidance-for-telecommunications-infrastructure-deployment-in-england 7

4.0 Site and surroundings

4.1 The application site comprises of agricultural land. It is located south of the small village of Hurst and north of the mixed residential and industrial area of Winnersh, east of Reading and north of Wokingham. The proposed site is approximately 50m from the A329 to the south. It is this substantial road infrastructure which characterises the immediate area. In addition, there is a run of tall electricity pylons.

4.2 The site will be accessed from the existing access track. Due to the proposed location, adjacent to the existing access track, access across the field to the existing pylon site will cease. The site provider has confirmed this is preferred to prevent the continuation of access issues especially in wet weather.

4.3 The surrounding land is to the north predominately agricultural and to the south urban. To the south, adjacent to the motorway is a line of trees and a thick hedgerow, providing an extensive visual and contextual barrier. Surrounding the site to the east and west, are thick hedgerows which line the access road reducing visual impact from these locations. Beyond this lies the residential areas of Winnersh to the south, Hurst to the north and Dinton Pastures Country Park and Hurst Golf Club to the west. This area is already associated with telecommunications as the existing telecommunications equipment, to be replaced by the proposal, is accommodated on a pylon to the north of the proposed site and an additional mast is located on the southern side of the A329.

4.4 In terms of the sites setting, public views of the site will be minimal. The main views will come from the public using the adjacent access road however, although this minor road provides access to residencies to the west of the site it is not the main route. Views from the motorway will be from behind a row of trees and thick hedgerow as will views from the residential area if Winnersh, these will provide effective screening for the structure – however will be set within the context of the existing pylons. Views from the village of Hurst will be from a significant distance circa 2km and will therefore be negligible due to topography as will views from the country park to the west circa. 500m.

4.5 In Local Plan policy terms, the site falls within an area detailed as “proposals outside the development limits”, the relevant policy is CP11. To the west, within the country park, is a local wildlife site and to the south is an area of urban development.

4.6 In terms of siting and appearance, the site location chosen allows the use of a lattice mast design which can both meet current network demand, allow future sharing and by being light permeable it can be visually absorbed by its backdrop, and as such impacts are minimised.

4.7 The planning history of the site has been checked using the LPAs online planning records and we have found no relevant planning applications.

5.0 The prior approval application

5.1 This planning application is submitted as a ‘prior approval’ application. This is because the overall permission is already granted through the General Permitted Development Order (GPDO)10. In England the legislation was amended in 2016 to allow LPAs to be even more supportive of telecommunications development - which in turn will allow the faster and more efficient roll-out and upgrade of communications development. A consultation is now underway to relax these rights further to expedite 5G rollout. The key components of the application are as follows: • 24m lattice telecommunications mast • 6 antennas • 2 transmission dishes • 8 equipment cabinets • ancillary development • 5.2 What should accompany a prior approval application is set out in legislation. Atlas is providing information which should help the LPA in their assessment of the application alongside this planning supporting statement. This includes: • Drawings o Location Plan o Site Plan o Elevation • ICNIRP Certificate • Coverage Plots • Assessment of heritage impacts (within this supporting statement) • Assessment of streetscape/landscape impacts (within this supporting statement)

5.3 Legislation requires that planning applications should be made in accordance with the development plan unless material considerations indicate otherwise. For applications made under the GPDO, planning permission is already granted through the general grant of permission with the determining issues for the LPA being the siting and appearance. In this respect, those polices which deal with these issues will be the most pertinent and carry the most weight.

5.4 For this application, the location means that the main issue for the decision-maker will be the impact on the landscape and natural environment, when balanced against the need to provide replacement and upgraded coverage to the surrounding area. Part of that balancing will also include the support from the Government for improved connectivity, especially for high data networks such as 4G.

5.5 The following analysis, we hope, demonstrates that the proposed solution represents the best balance between the often-competing factors of efficient radio coverage and protection of the landscape.

10 The Town and Country Planning (General Permitted Development) (England) (Amendment) (No. 2) Order 2016 10

6.0 Planning Policy

Development Plan 6.1 In considering and determining applications for development, the LPA has a statutory duty to determine any application in accordance with the development plan unless material considerations indicate otherwise.

6.2 The Core Strategy Plan was adopted in 2010 and is the extant development plan for this application.

6.3 Within the Core Strategy Plan CP4 is the relevant policy relating to infrastructure, the current proposal poses no friction with this policy as it will result in an improvement to the existing telecommunication services in the area. Additionally, due to the existing infrastructure at this location the cumulative impact is minimal.

6.4 As can be seen the proposed site is located within proximity to two designated areas of land. To the south is a large urban area which is designated as an area of ‘major development’ and to the north west is a ‘local wildlife site’. The development site lies in an area detailed as “proposals outside the development limits” and the relevant policy is CP11. The proposal is aligned with this policy as 1) ‘it contributes to diverse and sustainable rural enterprises within the borough’, by ensuring they have access to improved communications.

6.5 Described above, views onto the site will be limited, especially from the populated suburban area to the south. Topography and the trees and hedgerows create a very effective visual barrier between residential areas to the south and west and the application site. There will be some short-range views from the adjacent road however these will be minimal as this is a minor road which is unlikely to see much traffic. Whilst there would be some longer-range views from the road network to the south these are reduced due to the line of trees detailed above. Taking all this into account means there will be little friction with any of the development plan policies designed to protect the countryside or environment such as CP3, CP4 and CP11. It would however help Wokingham meet the policy objectives in several areas such as Spatial Objective M, ‘Encourage the provision of appropriate infrastructure, services and facilities that enable the borough’s residents to achieve their potential’. Based on the siting and appearance of the proposal there is accordance with the Development Plan.

National Planning Policy Framework (NPPF) 6.6 Introduced above, the main national planning policy guidance in England is the NPPF. This a material consideration which carries great weight in any development control decisions affecting electronic communications networks. The importance of such networks is clear from the policy. Passages from the policy are set out below. 112. Advanced, high quality and reliable communications infrastructure is essential for economic growth and social well-being. Planning policies and decisions should support the expansion of electronic communications networks, including next generation mobile technology (such as 5G) and full fibre broadband connections. Policies should set out how high quality digital infrastructure, providing access to services from a range of providers, is expected to be delivered and upgraded over time; and should prioritise full fibre connections to existing and new developments (as these connections will, in almost all cases, provide the optimum solution.)

113. The number of radio and electronic communications masts, and the sites for such installations, should be kept to a minimum consistent with the needs of consumers, the efficient operation of the network and providing reasonable capacity for future expansion. Use of existing masts, buildings and other structures for new electronic communications capability (including wireless) should be encouraged. Where new sites are required (such as for new 5G networks, or for connected transport and smart city applications), equipment should be sympathetically designed and camouflaged where appropriate.

6.7 The above policy demonstrates the importance attached by the Government for telecommunications, especially in rural areas and it is considered it offers strong support for this application. In this case the proposal represents new investment in communications infrastructure to the west of Wokingham. It will provide both replacement and enhanced coverage for the mobile operators on the proposed mast. In a prior approval application such as this the only considerations for the LPA are the siting and appearance.

Siting 6.8 Coverage – this location being close to the previous site is a good match for radio coverage (see coverage plots).

• Topography – The elevated location means the mast height itself can be kept to a minimum. This allows good coverage across the village of Hurst to the north and Winnersh to the south (see coverage plots).

• Ownership – before progressing any site a landowner needs to be willing.

• Designations – Discussed above, the siting avoids any designations, planning, environmental or heritage.

• Access – The site can be accessed easily from the existing access track. This limits any additional environmental impacts through creating a new lengthy access track.

• Power – There is already power at the existing telecommunications site. This ensures the new mast can obtain power with very little additional development.

• Backhaul – The elevated location means that the transmission links can easily obtain line-of-site (LOS) to existing base stations. This ensures connectivity into the wider network.

• Availability of alternatives – discussed below – other options had poorer coverage characteristics and/or greater impacts.

• Benefits of site – The chosen site benefits from a location already associated with telecommunications and services infrastructure which provides context to the proposal. The line of trees to the south provides screening from the properties in Winnersh and views from the motorway and being located alongside existing trees and vegetation can both screen and backdrop the ground-based apparatus and the lower section of the mast (see image below).

Appearance 6.9 The chosen design is a lightweight lattice mast. Described above, the design chosen allows the accommodation of the proposed 6no. antennas and 2no. transmission dishes. These could not be accommodated at the existing structure. In addition, as a wireless infrastructure provider, Atlas also 13

allow their infrastructure to be shared by other users – this is their business model - shared infrastructure being the main mechanism in reducing mast proliferation. The lattice design allows antennas and dishes to be added far more readily than a monopole due to its structural integrity. Further, the lightweight lattice design, being light permeable, can be less obtrusive when set against a backdrop. The tree cover in the area allows this (see image below).

6.10 Taking all the above together it is considered that there is both development plan compliance and that the main policy material considerations also support the proposed mast.

7 Material Considerations

Heritage assets 7.1 As can be seen on the map below, there are no heritage assets close to the proposed development. The nearest is a grade II listed building circa 350m to the north west of the application site. However, this is beyond thick hedgerows and trees, a residential area and a road. As such there will be no impacts on this asset. Additionally, there is another grade II listed building circa. 450m to the north east however, again distance and thick hedgerows remove any impact.

Environmental Impacts 7.2 Using environmental records and mapping we have established that there are no environmental designations within the immediate area of the application site, e.g. SSSI, SAC, SPA. In addition, no habitats or evidence of protected species were observed at or close to the site. As can be seen from the map below the nearest environmental designations are Lodge Wood and Sandford Mill SSSI and Lavells Lake, a local nature reserve both located over 1.5km from the proposed site.

Landscape Impacts 7.3 The proposed site lies within the National Character Area 115 – Thames Valley. This area is characterised by a ‘mainly low-lying, wedge-shaped area, widening from Reading, which includes Slough, Windsor, the Colne Valley and the southwest London fringes. The River Thames provides a unifying feature through a very diverse landscape of urban and suburban settlements, infrastructure networks, fragmented agricultural land, historic parks, commons, woodland, reservoirs and extensive minerals workings.’ These descriptions align with the proposed site; fragmented agricultural land to the north east and urban and suburban settlements to the south. The River Thames and its tributaries form part of the South West London Waterbodies Special Protection Area however, the proposal is over 5km from the River and will therefore have no impact on these areas.

Alternative Options 7.4 1. Hatch Gate Farm - Greenfield site beside new farm buildings, but land needed for future expansion. 2. The Wheelwrights Arms – The site provider (Wadworths' Brewery) is unwilling to consider accommodating telecommunications equipment on site. 3. Area south of the A329 – Flood zone and therefore unsuitable for development. 4. Dintons Pasture Country Park – this is a designated area and therefore has been avoided as more suitable options were available.

Public benefit 7.5 Discussed above, planning decisions are reached after the decision-maker balances any competing factors giving appropriate weight to each of the factors. We know, for example that the protection of national landscape designations such as National Parks and AONBs should be given significant weight, as should conserving the character and appearance of heritage assets. Where friction is identified then this must be balanced against the public benefit. This is explicit in the case of heritage assets and set out in para 196 of the NPPF11. 7.6 Section 3 above demonstrates how critical access to communications networks is in today’s society and economy. It also demonstrates that the Government, through legislation and policy guidance, is committed to ensuring that all areas of the UK have good access to such networks. Not only this but they should have a choice available - choice bringing down price and increasing quality through the marketplace. This commitment is based on public benefit. The weight this should be given is very significant. 7.7 The public benefit can be witnessed by initiatives to ensure better coverage across the UK. The most significant of these, discussed above, are the changes in property law and planning law. These are designed to speed up and ease the roll out of telecommunications infrastructure because of the public benefit. • Electronic Communications Code12 – this was reformed at the end of 2017.

The reforms to the outdated legislation will reduce the costs of housing phone masts and other communications infrastructure on private land. This opens the way for faster and more reliable broadband and mobile services, particularly in rural areas.

11 Where ‘less than substantial’ harm is identified 12 https://www.gov.uk/government/news/rule-changes-to-speed-up-rollout-of-mobile-and-fast-broadband-in-rural-areas 17

The changes to the UK’s Electronic Communications Code will:

o bring down the rents telecoms operators pay to landowners to install equipment to be more in line with utilities providers, such as gas and water o make it easier for operators to upgrade and share their equipment with other operators to help increase coverage o make it easier for telecoms operators and landowners to resolve legal disputes, and o help to drive investment and stimulate the continued growth, rollout and maintenance of communication technology infrastructure, an increasingly significant area of the UK’s economy

• Relaxation of permitted development rights (Part 16 of the GPDO)13

The following is taken from the Introduction to the consultation, which took place in late Summer 2019. Whilst the COVID-19 situation will have created timetabling issues in Parliament, it is expected that changes would come through later in 2020. The ‘Introduction’ encapsulates some of the issues surrounding the public good, or benefit which is what is driving these changes in legislation and is reproduced below

The Government recognises that widespread coverage of mobile connectivity is essential for people and businesses. People expect to be connected where they live, work, visit and travel. That is why the Government is committed to extending mobile geographical coverage further across the UK, with continuous mobile connectivity provided to all major roads and to being a world leader in 5G.

This will allow everyone in the country to benefit from the economic advantages of widespread mobile coverage, something rural communities in particular have been calling for. A recent report found that better mobile infrastructure has the potential to transform the rural economy by enabling small businesses to grow, recruit and retain staff and making it easier for people to work from home2. As well as improved mobile signal, 5G networks are also crucial to drive productivity and growth across the sectors that local areas are focusing on through their emerging Local Industrial Strategies. Enabling and planning for 5G implementation is central to achieving the Government’s objective to deliver prosperity at the local level and enable all places to share in the proceeds of growth.

The Government is determined to ensure the UK receives the coverage and connectivity it needs, and, in recent years, a number of initiatives have been completed to help achieve this. In 2014, the Government reached a landmark deal with mobile network operators, securing their commitment to significant investment in mobile infrastructure and to the achievement of specific coverage targets. In return, following an extensive period of research and consultation, the Government introduced reforms to the Electronic Communications Code (the

13 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/827162/Proposed_reforms_to_permitted_dev elopment_rights_to_support_the_deployment_of_5G_consultation.pdf 18

Code) in 2017 that will incentivise and support network investment, by making it cheaper and easier for communications apparatus to be installed, maintained and upgraded.

The Government has also made significant reforms to the planning system to support increased mobile connectivity. In 2016 we amended planning regulations in England to extend the existing permitted development rights to enable ground and building-based mobile telecommunications masts to be built without the need for a full planning application. Whilst in 2018 we strengthened national planning policy to support the expansion of electronic communications networks. Collectively the reforms to the Code and the planning system have played an important role in supporting the Government’s ambitions for improving mobile connectivity.

The Future Telecoms Infrastructure Review, published in July 2018, sets out the Government’s long-term strategy for meeting its digital connectivity targets3. It restated our commitment to tackling barriers to deployment and concluded that there were steps the Government could take in order to create the right conditions for the investment required to deliver additional network coverage and capacity. These measures included keeping the planning regime under review and listening to suggestions from industry for how new technology is best supported in the planning regime.

We are now considering further reforms to the planning system in England in order to support the network upgrades that will be required to deploy 5G and to extend network coverage, particularly in rural areas. The purpose of this consultation is to seek views on the principle of amending permitted development rights for operators with rights under the Code to support deployment of 5G and extend mobile coverage, and the circumstances in which it would be appropriate to do so.

These changes will underpin, for example, the more recent and very significant announcement of the Shared Rural Network (SRN) which will see a £1bn investment in achieving coverage in total not-spots and partial not-spots across the UK. This will bring mobile coverage to areas which currently either have no, or only patchy, mobile coverage.

7.8 The foregoing has been driven by and against a backdrop of work which highlights this public benefit and underpins these policy, legislative and investment initiatives. It is important to understand the proposed development in the context of public good and it not be dealt with, for example, in the way a minor speculative private development. Some of this work is highlighted below (links to full documents are referenced)

Lowering Barriers to 5G deployment14 Whilst this document is looking at how 5G can be more readily rolled-out across the UK, a starting point for the 5G network is the existing and (still growing) 4G network. 5G will not be a success without a mature 4G network. It is the difficulties in rolling out previous generations of networks which has resulted in specifically changes to the Electronic Communications Code, but also to planning legislation with a further round of relaxations due in the near future after the

14 http://www.broadbanduk.org/2018/07/20/forging-our-5g-future-barriers-and-solutions-to-network-deployment/ 19

consultation in late Summer 2019 This also includes the opening up of Council assets like the appeal site. Three specific recommendations are:

• Develop and implement a clear communications strategy to raise awareness on the benefits of the 5G roll out • Continue to ease barriers to deployment of new fixed networks • Streamline access to government-owned assets, sites and land for mobile infrastructure

Delivering Change – how cities can make the most of digital connections15

This document again stresses the importance of public bodies engaging with the new technology to ensure that everyone has good connectivity. It concludes

This new and improved ‘hardware’ must be matched at the local and national level by far better ‘software’ that gives individuals, businesses and cities the skills and confidence to take up the potential of better digital connectivity. This will require greater collaboration at the city level to support a cohesive, efficient and responsive skills system, as well as leadership by cities in embracing digital innovation. Failure to do so will likely see the greatest rewards of better digital infrastructure once again accrue to those places and people that have already benefitted from previous advances in technology, thus widening existing digital divides.

Future Telecoms Infrastructure Review16

This document looks at where UK PLC wants to be in terms of its connectivity moving into the near future. Making it easier to deploy sites both through the planning system and through the availability of publicly owned land is crucial. The Review identified four priority areas, one if these being:

Make it easier and cheaper to deploy mobile infrastructure and support market expansion, including the implementation of the wide-ranging Electronic Communications Code (ECC) on site access and consideration of further planning reforms;

Report for the Broadband Stakeholder Group – Lowering barriers to telecoms infrastructure deployment17

Whilst looking at the far wider issues of ensuring the UK has a fit-for-purpose communications networks, once again the planning system is identified as being a blocker to this happening. Decisions such as the refusal of this application form part of that issue. This is a simple mast using existing trees as screening and backdrop. Sites such as this need to get planning consent to help the UK achieving the aims and ambitions of the Government, residents and businesses throughout. It states:

15 https://www.centreforcities.org/publication/how-cities-can-make-the-most-of-digital-connections/ 16 https://www.gov.uk/government/publications/future-telecoms-infrastructure-review 17 http://www.broadbanduk.org/wp-content/uploads/2017/05/Lowering-barriers-to-telecoms-infrastructure-deployment-Final-report.pdf 20

In addition, specific practical issues surrounding the planning process of deployment across the country have been known to result in delays in households and businesses being connected.

4G in rural areas: how to close the digital divide 201818

This is a report from the All-Party Parliamentary Group (APPG) for Rural Business and which supports the approach taken forward in the Shared Rural Network which, in its forward, states:

4G is now the expected standard for mobile connectivity and it is revolutionising the way in which rural life functions, where once people and businesses left to go work within the cities it is now a place of work in its own right beyond traditional countryside businesses. Mobile technology allows for remote working with people both in the UK, but also much further afield. As Owen Paterson MP told our group you “could sit in a remote part of Shropshire and talk to Ulaanbaatar” This has facilitated both people returning to rural areas and moving in for the first time. It also plays a vital role for tourism businesses wanting to be able to market properties far and wide.

It’s not just connecting people that 4G has made easier. It’s also changing the way we farm. Harper Adams University is testing innovations with its Hands-Free Hectare project which is trialling the use of precision farming where all of the practical work, which is normally human led, is carried out by technology that relies on 4G. Services and amenities are also being improved with the use of connectivity, with apps being developed to speak to medical services over FaceTime and libraries lending digital books. These innovations will pass the countryside by if we do not improve the coverage of 4G in rural areas.

While this report focuses solely on improving 4G coverage we are concerned that the Government has become distracted by the pursuit to achieve 5G, of which it has already committed £200 million2, and that the countryside which is still lacking decent 4G coverage will lag behind. You cannot achieve 5G coverage without having a high-quality network in place for 4G and our report seeks to identify solutions to help achieve this goal across the countryside.

It goes onto state that the planning system has a part to play and advocates, in its key recommendations, that Local Plans should make provision for future mobile infrastructure. This has yet to be taken forward and in the meantime the only way to ensure this increased connectivity is through individual development management decisions such as the application in front of the Council.

A common theme recurring through all the above documents is an acknowledgement that how mobile infrastructure roll-out meets public agencies need to change if the UK is to benefit fully from technology, as there are still problems with people getting access to networks and thus to services. The planning system is one of those areas. In terms of this application, the applicant would argue that if a

18 https://www.cla.org.uk/sites/default/files/APPG%204G%20Report%20FINAL.pdf 21

replacement mast such as this (appearance) can’t be installed in a location such as this (siting), these problems will persist - the merits of the siting and appearance being discussed above and being the pertinent consideration for a GPDO proper approval application.

8 Access

8.1 Access to the site will be provided by the route show on the accompanying plans Once constructed, the development will be unmanned requiring only periodic visits, typically once every two to three months for routine maintenance and servicing.

8.2 In accordance with all relevant health and safety legislation and guidelines, access to the site will be restricted to authorised personnel and the routine maintenance and servicing of the apparatus will only be carried out by properly trained and qualified staff. Electronic communications base stations are specifically designed to prevent unauthorised access by members of the public and, therefore, there is no requirement to incorporate inclusive access arrangements into the proposed layout and appearance of the development.

9 Health & Safety

9.1 The application is accompanied by an ICNIRP Certificate. The proposal will be ICNIRP compliant. The NPPF states that: “Local planning authorities must determine applications on planning grounds only. They should not seek to prevent competition between different operators, question the need for an electronic communications system, or set health safeguards different from the International Commission guidelines for public exposure.”

10 Conclusions

10.1 This planning statement is submitted in support of the application for the installation of a 25m lattice telecommunications mast, 6 antenna, 2 transmission dishes and 8 equipment cabinets. The development will support the voice and data services including 5G.

10.2 The location chosen for the mast is well screened by the adjacent trees and thick hedgerows, it additionally benefits from the context provided by the existing services infrastructure within the same field. There were no buildings or structures which could provide a more suitable alternative in terms of siting or appearance.

10.3 Siting: There are no heritage assets in the vicinity. No environmental designations will be affected and there will be no adverse impacts on the landscape. The large scale infrastructure in the area including the A329(M) and the electricity pylons create a suitable context for the proposed development.

10.4 Appearance: The use of the lattice mast is required to structurally support the proposed apparatus for two MNOs. This is the type of mast design which best minimises impacts being in mind the number of antennas required and the height they need to be installed at. The light-permeable lattice design provides for less visual ‘weight’ and these matters combine to show that the design is the most practicable and which best minimises its impacts across the landscape.

10.5 The public benefits of access to high quality communication networks is substantial and is set out in this statement. This application improved connectivity in this area as part of the operators’ wider national network. The weight public benefit should be afforded is significant.

10.6 Taking all matters together, balancing any impacts of the proposed installation versus the benefits of the coverage and the limitations of the small search area, as well as the technical requirements of mobile connectivity, prior approval for siting and appearance for the proposal should not be required, however if it is so, then it should be granted.