CASE OFFICER'S REPORT

Application Reference: 17/03498/PNTEL Date site notice posted: 28/04/17 Date of inspection: 25/05/17 Date of press notice: n/a

LEGISLATION The Town and Country Planning (General Permitted Development) (England) (Amendment) (No. 2) Order 2016 Part 16 - Communications

POLICIES Wiltshire Core Strategy Core Policy 51: Landscape Core Policy 57: Ensuring high quality design and place shaping/amenity Core Policy 58: Ensuring the Conservation of the Historic Environment Core Policy 59: The Stonehenge, Avebury and Associated Sites World Heritage Site and its Setting

Core Policy 59 underlines that precedence will be given to the protection of the World Heritage Site (WHS) and that development will be acceptable only where it is “not adversely affecting the WHS and its attributes of Outstanding Universal Value (OUV). This includes the physical fabric, character, appearance, setting or views into or out of the WHS”.

Any development proposal is required to set out how it will protect and enhance the WHS in line with Policy 59. As part of the application it is necessary to “demonstrate that the development will have no individual, cumulative or consequential adverse effect upon the Site and its OUV. Consideration of opportunities for enhancing the World Heritage Site and sustaining its OUV should also be demonstrated”.

The Stonehenge and Avebury World Heritage Site Management Plan (2015) Policy 1a – Government departments, agencies and other statutory bodies responsible for making and implementing national policies and for undertaking activities that may impact on the WHS and its environs should recognise the importance of the WHS and its need for special treatment and a unified approach to sustain its OUV. Policy 1d – Development which would impact adversely on the WHS, its setting and its attributes of OUV should not be permitted. Policy 3c – Maintain and enhance the setting of monuments and sites in the landscape and their interrelationships and astronomical alignments with particular attention given to achieving an appropriate landscape setting for the monuments and the WHS itself.

Paragraph 7.4.7 highlights the fact that: “infrastructure related to telecommunications such as masts and other related infrastructure have the potential to have significant negative impacts on the setting of monuments and in some cases their physical remains”. Kennet Landscape Conservation Strategy (2005): p.30 - Marlborough Downs “Much of this area is inaccessible downland devoid of settlement, and where most types of development would be out of character and unacceptable. Perhaps the biggest threat to the visual integrity of the area is from telecommunication masts. Where these are essential they should be sited so that they do not break the skyline from all primary view points and that they are located within or adjacent to mature tree clumps. Hedge planting using native species will usually be required around all telecommunication compounds. Telecommunication masts should be located outside the Avebury World Heritage Site and where they do not visually impact upon it”.

National Planning Policy Framework March 2012 Section 5 Supporting high quality communications infrastructure Section 7 Requiring good design Section 11 Conserving and enhancing the natural environment Section 12 Conserving and enhancing the historic environment

Paragraph 132 states that great weight should be given to the conservation of designated heritage assets. “The more important the asset, the greater the weight should be”. WHSs are recognised as designated assets of the highest significance.

ISSUES Principle of development Siting and appearance, with particular reference to the WHS and the AONB. Health and safety

REPRESENTATIONS Fyfield and West Overton Parish Council: Has strong concerns about the design and especially the siting of the proposal:  In spite of assurances given by the operators that the council would be kept informed about the site selection process, it has been kept almost wholly in the dark.  The proposed location clearly breaches planning policy. The site is in the World Heritage Site, where Local Plan Policy PS7 provides that telecommunications development will only be permitted where technical considerations mean that there are no satisfactory alternative locations. The reasons which the operators have advanced for rejecting alternative sites show that examination of these was no more than perfunctory. Examples are:- ‘The [site] was considered to be restrictive in terms of coverage capacity’, with no attempt to justify this conclusion; ‘No response from the site provider to the proposal made’. In the latter instance the council has learnt that the landowner never received the approach which the operators claim to have made.  Given that telecommunications coverage depends on line of sight communication, it seems perverse to have chosen a location in the bottom of a valley rather than one on top of a hill or ridge, or a high building such as a church tower. The result is that, by the operators’ own account, coverage of East Kennett would be incomplete, while Lockeridge would receive little or none. This could create undesirable pressure for an additional mast or masts.

Avebury Parish Council: The site lies inside the WHS and is visible from significant heritage assets within the WHS, notably The Sanctuary and the barrow cemetery on Overton Hill. The settings of both of these would be adversely affected by the proposed telegraph pole which would be both prominently visible and incongruous in this location. Views to and from The Ridgeway would also be adversely affected.

There are also concerns about the adverse impact of the proposed development on the landscape of the AONB.

In 2010 considerable efforts were made by the WHS team to obtain funding under Offgem’s environmental improvement programme to remove overhead high voltage powerlines leading up to Overton Hill. These had interrupted critical views of the WHS, especially for travellers along the A4. The bid was successful and Scottish and Southern completed the very expensive works of undergrounding the cables costing about £200k - £250k.

 The proposal conflicts with policies and guidance for the WHS, in particular:  NPPF para 132, concerning protection of the WHS (a designated asset of the highest significance) and its setting  Wiltshire Core Strategy, Policy 59, concerning protection of the WHS and its setting  The WHS Management Plan 2015, especially its Vision (page 10); and policies 1a, 1d and 3c, concerning the need for special treatment of and a unified approach to the WHS, along with its protection from development that would adversely affect it and its landscape setting  The WHS Management Plan 2015, paragraph 7.4.7 which highlights the potential for telecoms infrastructure to impact adversely on the WHS.

The Parish Council draws attention particularly to the Kennet Landscape Conservation Strategy for the Marlborough Downs (2005)  Much of this area is inaccessible downland devoid of settlement, and where most types of development would be out of character and unacceptable. Perhaps the biggest threat to the visual integrity of the area is from telecommunication masts.  Telecommunication masts should be located outside the Avebury WHS and where they do not visually impact upon it.

The Parish Council notes that this is a sensitive location, and that tree planting cannot be guaranteed to provide screening in the long term or for all seasons of the year.

The Parish Council urges Wiltshire Council to require the applicant to seek a more appropriate location that further improves mobile phone reception for Avebury Parish and on the A4 while also preserving the visual integrity of the area.

Stonehenge and Avebury World Heritage Site Partnership Manager: Objects. Her original advice at the pre-application stage included the fact that locating mobile phone masts within the WHS would raise substantial policy- based objections. The mast would represent a highly visible, vertical intrusion in the World Heritage landscape and have a harmful impact on the setting of the both the Sanctuary and Overton Hill barrow cemetery; both important attributes of Outstanding Value for which the WHS was placed on the UNESCO World Heritage List.

The open landscape in this part of the WHS is extremely important as it provides unimpeded views up to the monuments which are currently dominant in the landscape. Within the last decade around £250,000 has been invested in undergrounding electricity poles and cables to the north of the A4 in this area to enhance this part of the WHS landscape and remove intrusion in the wider open landscape setting of the attributes of OUV. It would be highly counterproductive to place a replica 17.5 m telegraph pole in this area and reintroduce harmful intrusive structures detracting from the OUV of the WHS.

The proposed site does not comply with World Heritage Site Management Plan policies 1a, 1d and 3c or Wiltshire Core Strategy Policy 59. Furthermore there have been no systematic, objective studies such as Historic Impact Assessment and LVIA to assess the impact of the proposal on the OUV of the WHS as is required by Policy 59 or on the wider landscape character. The pre-application documentation to which she originally responded stated that North Farm, Bath Road, West Overton, Marlborough, Wiltshire, SN8 1QE had been dismissed as an alternative location due to its location within the WHS and AONB. The land at Manor Farm suffers the same constraints and if anything is more prominent within the open landscape and more sensitively located in relation to the setting of monuments that are attributes of OUV. This would have been apparent if the studies indicated in Policy 59 had taken place.

Historic England: Has concerns regarding the application on heritage grounds. The application does not meet the requirements of the NPPF, in particular paragraph number 128.

The proposal has the potential to impact on the setting of sensitive heritage assets of international and national significance. This matter is referred to in NPPF paragraph 132. The application does not include any meaningful assessment of the potential impacts of the proposal to the historic environment. They would have expected that an application of this nature and in this location would include a robust Historic Impact Assessment and, potentially, a Landscape and Visual Impact Assessment (LVIA). The matter of assessment of potential impacts is referred to in paragraph in NPPF paragraph 128. The Avebury Society: Aware that telecommunications signals are poor or lacking in West Overton and welcome an initiative to remedy the situation. Nevertheless do have concerns about the visual impact of the proposed mast on the environment and setting of the WHS. They fully supported the successful removal of telegraph poles from the approach to Overton Hill and feel that to locate a new mast in a nearby location would be a retrograde step. Ask the Council to explore with the applicants the possibility of sharing the mast at West Woods or locating a new mast in a less visually sensitive position.

CPRE: Object. The site lies just inside the WHS and is visible from significant heritage assets within the WHS, notably The Ridgeway, the barrow cemetery and the Sanctuary on Overton Hill, the settings of all of which would be adversely affected by the proposed telegraph mast which would be both prominently visible and incongruous in this location.

There are also concerns about the adverse impact of the proposed development on the landscape of the AONB.

It would be a pity if the telegraph mast were permitted here when considerable efforts were recently made to successfully remove telegraph poles leading up to Overton Hill that had interrupted critical views of the WHS, especially for travellers along the A4.

The proposal conflicts with policies and guidance for the WHS, in particular:

 NPPF para 132, concerning protection of the WHS (a designated asset of the highest significance) and its setting);  Wiltshire Core Strategy, Policy 59, concerning protection of the WHS and its setting;  The WHS Management Plan, especially its Vision (page 10); and policies 1a, 1d and 3c, concerning the need for special treatment of and a unified approach to the WHS, along with its protection from development that would adversely affect it and its landscape setting.  Management Plan, paragraph 7.4.7 which highlights the potential for telecoms infrastructure to impact adversely on the WHS.

Draw attention particularly to the Kennet Landscape Conservation Strategy for the Marlborough Downs (2005 p.30): “Much of this area is inaccessible downland devoid of settlement, and where most types of development would be out of character and unacceptable. Perhaps the biggest threat to the visual integrity of the area is from telecommunication masts. Where these are essential they should be sited so that they do not break the skyline from all primary view points and that they are located within or adjacent to mature tree clumps. Hedge planting using native species will usually be required around all telecommunication compounds. Telecommunication masts should be located outside the Avebury World Heritage Site and where they do not visually impact upon it”. The NPPF, para.43, advises that telecoms masts etc. should be kept to “a minimum consistent with the efficient operation of the network. Existing masts, buildings and other structures should be used, unless the need for the new site is justified”.

Use of the site proposed for this mast has not been justified in the application. This is a sensitive location. Tree planting cannot be guaranteed to provide screening for a considerable growth period or in the longer term. Urge the Council to preserve the visual integrity of the area by requiring the applicant to seek a more appropriate location — preferably to share a mast already in situ, such as the one located in West Woods, not very far away.

Highway Authority: No objection.

Drainage Engineer: No objection.

Local residents: Objections have been received from 4 local residents. Their main concerns can be summarised as follows:  The site is situated within the WHS and the AONB. The mast would intrude inappropriately and harshly onto the historic and beautiful landscape which has been recognised internationally for these specific qualities. Furthermore the mast would be prominent and visible from a number of local sites of considerable antiquity, heritage and aesthetic value including The Ridgeway, the West Kennet long barrow cemetery and the Sanctuary on Overton Hill, thereby eroding the integrity of the environment and its essential character. Such aesthetic considerations were previously deemed to be important and a precedent was set with the removal of the telegraph poles on the approach to Overton Hill due to their intrusion on views of the landscape of the WHS.  The mast would be visible from West Overton.  The proposal is contrary to NPPF paragraphs 43 and 132, Wiltshire Core Strategy Policy 59, the WHS Management Plan and the Kennet Landscape Conservation Strategy for the Marlborough Downs.  The proposal might give West Overton better coverage, but would not improve the situation for East Kennett or Lockeridge. If implemented, there would be still be demand for further masts to serve these other villages.  There needs to be a full consultation with residents from all 3 villages as to the best location for a mast.  The applicant was presented with several alternative sites, some of which would have solved the problem in giving much better reception to all villages - and these should be re-considered and re-examined. These other options were on much higher ground than the relative low position of the mast outlined in this application and perhaps more effort should be encouraged in having a dialogue with other land owners and farms that have access to a much higher land position, e.g. West Woods.  The mast would be sited close to dwellings in West Overton. The long term health risks of living close to mobile phone masts has not yet been fully established.

THE PROPOSAL The proposal is for a 17.5m mast as a replica telegraph pole, 2 no. microwave dishes and 1 no. equipment cabinet, on land at Manor Farm, West Overton. The pole would have a brown, wood effect finish. The cabinet would be painted green. The pole would be situated adjacent trees of a similar height. The site is located in both the North Wessex Downs AONB and the Avebury WHS. It is in close proximity to the following Scheduled Monuments:

 The Scheduled Monument known as' Iron Age enclosure on Overton Hill, 600m north west of North Farm' (National Heritage List for England ref. 1007490);

 A group of three Scheduled Monuments collectively known as the Overton Hill Bronze Age round barrow cemetery (NHLE refs.1008459, 1008463 1008464);

 The Scheduled Monuments known as: 'Bowl barrow 50m south of The Sanctuary on Overton Hill, forming part of the Seven Barrow Hill round barrow cemetery' (NHLE ref. 1007489); 'Iron Age enclosure on Overton Hill, 600m north west of North Farm' (NHLE ref. 1007490); 'Three Roman burial mounds, a Bronze Age bowl barrow, a pagan Saxon inhumation cemetery and a short length of Roman road on Overton Hill' (NHLE ref. 1008461); and 'The Sanctuary, Overton Hill' (NHLE ref. 1014563).

ASSESSMENT Principle of development

Part 16 of the Town and Country Planning (General Permitted Development) (England) (Amendment) (No. 2) Order 2016 permits new telecoms masts provided they adhere to the following regulations:

A. Development by or on behalf of an electronic communications code operator for the purpose of the operator’s electronic communications network in, on, over or under land controlled by that operator or in accordance with the electronic communications code, consisting of— (a) the installation, alteration or replacement of any electronic communications apparatus, (b) the use of land in an emergency for a period not exceeding 18 months to station and operate moveable electronic communications apparatus required for the replacement of unserviceable electronic communications apparatus, including the provision of moveable structures on the land for the purposes of that use, or (c) development ancillary to radio equipment housing. A.1—(1) Development consisting of the installation, alteration or replacement of electronic communications apparatus (other than on a building) is not permitted by Class A(a) if— (a) in the case of the installation of electronic communications apparatus (other than a mast), the apparatus, excluding any antenna, would exceed a height of 15 metres above ground level; (b) in the case of the alteration or replacement of electronic communications apparatus (other than a mast) that is already installed, the apparatus, excluding any antenna, would when altered or replaced exceed the height of the existing apparatus or a height of 15 metres above ground level, whichever is the greater; (c) in the case of the installation of a mast, the mast, excluding any antenna, would exceed a height of— (i) 25 metres above ground level on unprotected land; or (ii) 20 metres above ground level on article 2(3) land or land which is on a highway; or (d) in the case of the alteration or replacement of a mast, the mast, excluding any antenna, would when altered or replaced— (i) exceed the greater of the height of the existing mast or a height of— (aa) 25 metres above ground level on unprotected land; or (bb) 20 metres above ground level on article 2(3) land or land which is on a highway; or (ii) together with any antenna support structures on the mast, exceed the width of the existing mast and any antenna support structures on it by more than one third, at any given height.

The site lies within the North Wessex Downs AONB, which is classified as article 2(3) land. The size of the proposed at 17.5m mast is within the 20 metre limits defined by the 2016 GPDO for article 2(3) land.. Thus the mast as designed is permitted development, subject to a formal assessment by the LPA of its impacts, in particular with regard siting and appearance.

Siting and appearance, with particular reference to the WHS and the AONB

The Local Planning Authority has received a significant number of objections, which have been noted and taken into consideration. These highlight the fact of the site’s location within both the WHS and the AONB, and the proposal’s conflict with multiple planning policies. In particular they point to the harm which the proposal would cause to the setting of important monuments within the WHS and to the overall landscape of the WHS and AONB. The proposed mast would represent a highly visible, vertical intrusion in the World Heritage landscape and have a harmful impact on the setting of the both the Sanctuary and Overton Hill barrow cemetery; both important attributes of Outstanding Value for which the WHS was placed on the UNESCO World Heritage List. The proposal would also be harmful to the landscape quality of the AONB. As a consequence the Local Planning Authority cannot support this prior notification application on siting and appearance grounds.

Health and safety One local objector expresses concerns about the health risks of mobile phone masts.

Paragraph 46 of the NPPF states that: “Local planning authorities must determine applications on planning grounds. They should not seek to prevent competition between different operators, question the need for the telecommunications system, or determine health safeguards if the proposal meets International Commission guidelines for public exposure.”

The submitted statement from the applicant confirms that: “The proposed equipment and installation is designed to be in full compliance with the requirements of the radio frequency (RF) public exposure guidelines of the International Commission on Non-Ionizing Radiation (ICNIRP), as expressed in the EU Council recommendation of 12 July 1999 on the limitation of exposure of the general public to electromagnetic fields (0Hz to 300GHz)”.

Consequently, the proposal would appear to comply with the national guidance regards this matter, and hence, a refusal of the scheme on health and safety concerns would be difficult to justify.

OTHER MATTERS The submitted “Supplementary Information” document is incorrect to make reference to Saved Local Plan Policy PS7 “Telecommunications”. This is in fact a saved policy from the Salisbury District Local Plan 2011, which only covers the southern part of the county of Wiltshire. Although this policy would apply to the Stonehenge half of The Stonehenge, Avebury and Associated Sites WHS, it does not apply to the Avebury half.

CONCLUSION Whilst the proposed mast would offer potential public benefits by providing improved mobile phone coverage to the village of West Overton, there is considerable local objection to this proposal, and the Council considers that the proposed mast would represent a highly visible, vertical intrusion in the landscape of the Avebury WHS and have a harmful impact on the setting of the both the Sanctuary and Overton Hill barrow cemetery; both important attributes of Outstanding Value for which the WHS was placed on the UNESCO World Heritage List. The proposal would also be harmful to the landscape quality of the North Wessex Downs AONB. As such the proposal would be contrary to the aims of Wiltshire Core Strategy policies CP51, CP57, CP58 and CP59, to the aims of The Stonehenge and Avebury World Heritage Site Management Plan (2015) and to the aims of the Marlborough Downs section of the Kennet Landscape Conservation Strategy (2005).

RECOMMENDATION:

Prior approval is required and refused

Peter Horton 30 May 2017