Proposed installation of antennas and ancillary development at existing telecommunications base station, , Hull Road, Withernsea, HU19 2DY

Planning/Heritage/Design & Access Statement

The following has been provided to accompany the planning application for the addition of 3x no antennas, ground based apparatus and ancillary development at the above address.

The development site lies within Withernsea. It is located on a listed building.

Application Site

Due to the small-scale nature of the proposed development at an existing telecommunications base station, this statement is being kept purposefully short as a proportionate response to the anticipated impacts from the proposal.

There are 31 different planning applications which are listed with the property with a number of these reacting to both planning applications and listed building consent applications for communications apparatus dating back to 1996. We will not repeat all of these here and the Council will obviously hold all this planning history.

The most recent of these ‘telecommunications’ applications was submitted in 2015 and involved the upgrade of the Cornerstone apparatus with the removal of 4 antennas and installation of 6 (with associated development). There was also an associated listed building consent application.

• 15/01678/PLB • 15/01676/PLF

This is considered to be the most relevant material consideration in the case of the application. The response from the conservation officer stated:

NO OBJECTION - Withernsea Lighthouse is a late Victorian grade II Listed Building, erected in 1892 to 1893. Under section 16 (2) of the Planning (Listed Buildings and Conservation Areas) Act 1990, local authorities when considering whether to grant listed building consent for any works the local planning authority or the Secretary of State shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.. The Lighthouse already has visible mobile telecommunication equipment on the top outer handrail. The equipment is only noticeable if the receptor is really looking for it, or it is pointed out. Part of the equipment is disguised as a flag-pole and all will be reversible and painted white to minimise visual impact on the appearance and setting of the Lighthouse. Only a small amount of harm would be introduced to the appearance of the lighthouse, which would be negligible when viewed at ground level. Following guidance in paragraph 134 of the National Planning Policy Framework. Harm to a designated heritage asset which is less than substantial should be weighed against the public benefits of the development. The public benefits in this application are quite substantial in terms of the improvement to mobile phone services and the economic benefits improved communications could bring.

The two applications were approved by the then case officer.

Existing Proposed

The principle and acceptability of a communications mast and subsequent modifications have therefore been previously assessed and found to be acceptable and as can be seen from the above planning drawing extracts, the change in the character and appearance of the building is limited.

Development Plan

The approved, and hence extant, Local Plan is the East Riding Local Plan 2012 – 2029 (Adopted April 2016).

It does not have a specific telecommunications policy as encouraged by the NPPF however does have the following to say about communications infrastructure.

The Local Plan has an important role to play in supporting the provision of new and/or improved infrastructure and facilities, which can include the maintenance of infrastructure that serves new development. This includes proposals for improving communication networks (such as broadband and telecommunications), road improvements and sports facilities. Maximising the use of existing infrastructure and facilities should be prioritised, especially where new provision may result in adverse impacts. For example, it may not be necessary to construct new telecommunications masts where existing masts are available (our emphasis).

The proposed development does use existing infrastructure and the prioritisation of this is preferred as per the above. Should the lighthouse not be used for this development, to replicate the proposed new coverage a new mast of around 30m in height would need to be installed veery close to Withernsea. This would have far greater impacts than the development being proposed.

The Local Plan context can be seen from the map extract above. As described above, there is no specific communications policy within the Plan however the policies which govern impacts on the historic environment will be pertinent.

NPPF

The main national planning policy guidance in is the National Planning Policy Framework (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. 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, encouraging as it does the use of existing infrastructure and buildings. It goes on to provide guidance for development which will have heritage assets. For the reasons set out above it is considered that there will be very little impact (less than substantial) on the host listed building. In terms of para 189 of the NPPF, below is set out the details of the heritage asset.

Listed Building – Withernsea Lighthouse

Taken from the Historic England listing, the following gives a full description of the heritage asset.

Details

WITHERNSEA HULL ROAD 5266 TA 32 NW (south side) 4/93 Withernsea Lighthouse and adjoining pair of 16-10-85 lighthouse keepers' houses (formerly listed as The Lighthouse) GV II

Lighthouse and adjoining lighthouse keepers' houses. 1892-3, probably by Sir James Douglass or Thomas Matthews, for . Brick, stuccoed and whitewashed; incised in imitation of ashlar to houses. Welsh slate roof to houses. T-shaped on plan: tapered octagonal tower with passage to pair of 3-room houses adjoining on south side; entrances to passage, and north and south sides of houses. Tower: 6 stages, surmounted by lantern; overall height approximately 38 metres. Chamfered plinth. Deeply-recessed segmental-headed 2-light windows with quoined surrounds and projecting sills. Polychrome painted relief panel to first floor, north side, with Trinity House arms, crest and motto "Trinitas in Unitate" in raised surround with sill. Deeply-coved cornice carrying railings to light inspection platform with cast-iron square column principals with moulded bases, capitals and finials, and plain rails. Tall faceted cylindrical lantern with full-height diagonal glazing bars and domed cupola with handrail, surmounted by cylindrical ventilator with handrail, domed cap and weather- vane. Houses, south side: 2 storeys, 4 first-floor windows. Chamfered plinth, quoins. Steps to pair of central part-glazed doors flanked by single-light and 2-light cross windows, 4 simlar w indows to first,floor. All opening In quoined surrounds; projecting sills to windows. Overhanging eaves. Hipped roof. 3 black painted tall axial stacks with chamfered plinths and clustered shafts, stepped cornices, domed caps and cylindrical pots. Similar windows and details to east and west elevations. Main entrances to north have steps to recessed board doors with overlights. Single storey passage linking houses and tower has 3-bay east and west fronts, each with steps to a recessed 2-fold board door with overlight flanked by single-light windows. Interior. The lighthouse tower contains no floors apart from that of the inspection chamber and upper lamp room, reached by a spiral staircase on the interior walls. A prominent lankmark, it ceased operation in 1976. Sir James Nicholas Douglass (1826-98) was Engineer-in-Chief for Trinity House from 1863-92, for whom he designed 20 new towers, including Eddystone and Bishop Rock. He was succeeded by Thomas Matthews, who designed the 1893-5 Lighthouse (qv). A well-designed group, with accompanying range of original outbuildings and garden wall (qv). D Jackson, of England and Wales, 1975, p 105; D B Hague and R Christie, Lighthouses: their architecture, history and archaeology, 1975, p 217

Significance of, and impacts on, the asset: the description is set out above and has been previously assessed as part of the planning history of the building. It forms a locally significant heritage feature. The scale of the proposed development is very small and the lighthouse already hosts communications apparatus. Whilst the building has not been used as a lighthouse for some time, that use and hence the building’s design, is that of communication i.e. communicating to seafarers the presence of land. Its current use as a telecommunications base station is therefore appropriate in terms of character assessed against that original use but also its current use as telecommunications base station. Overall, it is considered that there are negligible impacts (less than substantial) on the asset and that these impacts are outweighed by the public benefits of the improved (4G) communications network to be provided by the applicant.

Also of note is that there are two other listed buildings within the settings of which the lighthouse sits. These being:

• Church of St Mathew (Grade II) – List UID 1392281 • Outbuildings of lighthouse (Grade II) – List UID 1310188

Due to the scale of the proposed development, when set against the size and scale of the host lighthouse, it is considered that there will no impacts on these assets.

Public Benefit

Set out above, in planning policy terms, the NPPF is clear on the public benefit of having access to high quality communications networks, stating:

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

In March 2019 the DCMS wrote to all local authorities to stress the importance of digital connectivity, writing: ‘Government is committed to supporting investment in high-quality, reliable digital connectivity so that communities can benefit from faster economic growth and greater social inclusion. It is essential to keep pace with growing demand for internet bandwidth and mobile data from local businesses, residents and those who visit our communities. As outlined in the Future Telecoms Infrastructure Review, the Government would like to see nationwide full fibre coverage by 2033. We would also like the UK to be a world leader in 5G, with the majority of the population covered by a 5G signal by 2027. We are writing to ask for your help in supporting the investment necessary to achieve these objectives. Recent years have seen substantial investment in mobile and fixed digital infrastructure across the UK. While mobile coverage across the UK has been significantly improving, there are still too many areas where coverage is poor. We need to create the market and policy conditions necessary to support the large-scale commercial investment required to extend and future-proof digital connectivity. 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’.

The most recent OFCOM – Connected Nation Report 20201 states

Being connected has never been more important to the UK People have been relying on phone and broadband services more and more over recent years, and the Covid-19 pandemic during 2020 has brought this reliance into even sharper view. In March 2020, life changed suddenly for millions of people across the UK. Fast, reliable broadband and mobile connections were essential to allow them to work from home, keep up with schoolwork, access medical appointments and public services, stay in touch with friends and family, order shopping online, and keep themselves entertained.

The UK’s fixed broadband networks have seen significantly more demand, with average monthly data usage increasing almost 80% in two years. It now stands at 429 GB per connection, up from 315 GB last year (itself up from 241 GB in 2018). As well as an increase in traffic, the Covid-19 lockdown period has also seen a shift in how people use their services. While peak broadband use is still in the evenings and has continued to grow, daytime traffic has increased significantly. Upload traffic has also increased, driven by more use of video calling for work and to keep in touch with friends.

On 23rd October 2020 Digital Infrastructure Minister Matt Warman spoke about ongoing work by the government and telecoms industry to boost the UK's world class digital connectivity, stating:

“….But, first, I thought that I would reflect on the changed times that we are living in. COVID has altered the way we live, work and, most importantly, stay connected with our family and friends. The digital infrastructure that keeps us all connected was essential to our daily way of life under lockdown – and is now more important than ever as we head into recovery. Many of these changes - such as increased working from home - will stay with us for the foreseeable future. People in this sector have long referred to the internet as “the fourth utility” - and it’s true. For countless people across the country, having fast and reliable broadband and a good mobile connection is as essential and vital to our daily lives as gas, water and electricity. That’s why I’m committed to working with you all to ensure the entire nation has access to world class, next generation gigabit connectivity that is secure and resilient enough to deal with all sorts of future challenges. This government is ambitious for the UK’s digital infrastructure.

Support for improved communications networks is substantial and makes clear that Government recognises the public benefit of having access to these networks. In making the assessment required by Para 196 of the NPPF, the applicant considers that the very significant public benefits of the improved communications network will outweigh the small impact on the heritage asset.

1 https://www.ofcom.org.uk/__data/assets/pdf_file/0024/209373/connected-nations-2020.pdf The above assessment against public benefit will also hold true for the surrounding listed buildings where the impacts will be far less than the host building.

Summary

Overall, the use of an existing communications base station and existing building, combined with the very small-scale nature of development results in a proposal which is in accordance with the development plan and where no material considerations, the most significant of which is the potential impact on heritage assets, point to any other outcome than approval and it is hoped that the LPA can approve the application and allow the communications network to be improved in this area.