SUPPLEMENTARY INFORMATION
1. Site Details
Site Name: Manor Farm Site Address: Land at Manor Farm West Overton West Overton National Grid 412777, Marlborough Reference: 168250 Wiltshire SN8 4ER Site Ref Number: CTIL 241849 / Site Type:1 Macro – Greenfield TEF 80767
1.1 Background
This application is proposed to infill a coverage requirement for both Telefonica UK Limited (trading in the UK as O2) and Vodafone Limited to improve their 2G, 3G and 4G coverage this area of Wiltshire.
Telefonica UK Limited has entered into an agreement with Vodafone Limited pursuant too which the two companies plan to jointly operate and manage a single network grid across the UK. These arrangements will be overseen by Cornerstone Telecommunications Infrastructure Ltd (CTIL) which is a joint venture company owned by Telefonica UK Limited and Vodafone Limited.
This agreement allows both organisations to: • pool their basic network infrastructure, while running two, independent, nationwide networks; • maximise opportunities to consolidate the number of base stations; • Significantly reduce the environmental impact of network development. The two companies therefore propose to meet this coverage requirement by utilising one installation to keep the overall impact of telecommunications development in the area to a minimum.
2. Pre-Application Check List
Site Selection (for New Sites only)
Was a local planning authority mast register available to Yes check for suitable sites by the operator or the local planning authority? If no explain why: N/A
Were industry site databases checked for suitable sites by Yes the operator: If no explain why: N/A
1 Macro or Micro
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Site Specific Pre-application consultation with local planning authority
Date of written offer of pre-application consultation: 15/03/17 Was there pre-application contact: No Date of pre-application contact: n/a Name of contact: n/a Summary of outcome/Main issues raised:
A pre-application email was sent to Wiltshire Council on 15/03/17 introducing the new site proposal as part of the new CTIL initiative.
To date, no site-specific comments have been received.
Community Consultation
Rating of Site under Traffic Light Model: Red Amber Green Outline of consultation carried out:
A pre-consultation letter and proposed site drawings were sent via email to the ward councillor, Jemima Milton, Fyfield, Lockeridge & West Overton parish council and MP for Devizes, Claire Perry on 15/03/17 introducing the new site proposal as part of the new CTIL initiative.
Consultation was also carried out with Stonehenge and Avebury World Heritage Site Partnership.
Summary of outcome/main issues raised:
Representatives of the parish council responded and enquired as to what the extent of the new coverage would be and whether it would improve coverage in East Kennet and Lockeridge.
Mrs Perry also enquired as to what the extent of the coverage improvements would be and whether the adjacent villages would also benefit. Existing / Proposed 4G coverage maps were sent to Mrs Perry on 03/04/2017.
Stonehenge and Avebury World Heritage Site Partnership provided the following comments, ‘The proposed site is within the Avebury part of the Stonehenge and Avebury World Heritage Site. It is near the gateway to the World Heritage Site and it within the setting of the Sanctuary and Overton Hill barrow cemetery; both important attributes of Outstanding Value for which the World Heritage Site was placed on the UNESCO World Heritage List. The open landscape in this part of the WHS is extremely important with 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 in this area to enhance this part of the World Heritage Site landscape.
I would object to the current proposed site for the 17.5 m mast and base station as it is does not comply with policies in the World Heritage Site Management Plan or the Wiltshire Core Strategy.
School/College
Location of site in relation to school/college (include name of school/college):
No schools / colleges are deemed close enough to have a functional relationship with the site.
Outline of consultation carried out with school/college (include evidence of consultation):
n/a
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Summary of outcome/main issues raised:
n/a
Civil Aviation Authority/Secretary of State for Defence/Aerodrome Operator consultation (only required for an application for prior approval)
Will the structure be within 3km of an aerodrome or airfield? No Has the Civil Aviation Authority/Secretary of State for No Defence/Aerodrome Operator been notified? Details of response:
N/A
Developer’s Notice
Copy of Developer’s Notice enclosed? Yes Date served: 03/04/17 Track and Trace ref number GK273427696GB
Proposed Development
The proposed site:
The proposed site is located on private land at Manor Farm, West Overton. The installation proposed is for a 17.5m replica telegraph pole, 2no. microwave dishes and 1no. equipment cabinets, along with ancillary works.
The proposed equipment is to be adjacent trees of a similar height as the proposed telegraph pole, which will assist in assimilating the site into the existing landscape. The proposed pole is to be a replica telegraph pole with a brown, wood effect finish. The cabinet is to be painted green.
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Type of Structure (e.g. tower, mast, etc): Description:
The installation of a 17.5m replica telegraph pole, 2no. 300mm microwave dishes, 1no. equipment cabinet, along with ancillary works.
Overall Height: 17.5 Metres Height of existing building (where applicable): Metres Equipment Housing: Lancaster cabinet Length: 1.898 Metres Width: 0.798 Metres Height: 1.648 Metres Materials (as applicable): Tower/mast etc – type of material and external Steel replica telegraph pole – Timber effect (brown) colour: Equipment housing – type of material and Steel – Green (RAL 6009) external colour:
Reasons for choice of design, making reference to pre-application responses:
Telefonica UK Limited, commonly known as O2 and Vodafone Limited, have entered into a new agreement in which the two companies plan to jointly operate and manage a single network grid across the UK. This initiative strengthens the network infrastructure partnership between the two companies, previously rolled out as part of ‘Cornerstone’.
Now a newly formed joint venture company called CTIL (Cornerstone Telecommunications Infrastructure Limited) has been formed. CTIL is owned equally by the aforementioned operators allowing a single grid infrastructure with both organisations pooling and consolidating their respective networks while running two, independent, nationwide networks. Each operator will keep ownership and control of its network spectrum; however each operator will have responsibility to manage, maintain and provide coverage in one half of the UK.
CTIL have upgraded the existing base stations where possible and this project (Grow the Grid) now seeks to facilitate much needed improvement to the coverage that the 2 operators have in the area.
In this instance, Telefonica are acting as the responsible operator for this part of the UK. The choice of design in this latest case has been influenced by the need for a certain minimum height and operator requirements.
The overall height of the proposed replica telegraph pole at 17.5 metres has been kept to its technical minimum given the structure types which are available to the aforementioned operators. The proposed pole is at a height of 17.5 metres so as not to compromise on the centre line of the antennas and to allow for good coverage to the target area and provide coverage improvements in East Kennett & Lockeridge, as well as West Overton.
The dimensions of the structure allow the site to support the technically preferred antennas and feeder cables. It is of note that the antennas which function for both operators are closely spaced together so as to keep the profile of the site as thin as possible. In this respect, each operator’s antennas are not distinguishable as separate elements, whereby taking into account the form and appearance of proposed site as a whole, to the naked eye the mast share gives the illusion of a single operator installation.
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The choice of a replica telegraph pole is considered to be appropriate as it would minimise the visual impact of the development within the locality. In light of the above and in choosing this particular design, it is considered that the scheme takes a form which is sympathetic within the context of its immediate landscape.
It is of note that the proposed equipment cabinets are small for a telecommunications development (less than 2.5m3) and will be located close to the pole. The proposed equipment cabinets have an appearance similar to existing cabinets found in a street scene. In this respect it is considered that the design of the ancillary development will not have a detrimental impact upon the visual amenity of the area.
Technical Information
International Commission on Non-Ionizing Radiation Protection Declaration Yes attached (see below)*
International Commission on Non-Ionizing Radiation Protection public compliance is determined by mathematical calculation and implemented by careful location of antennas, access restrictions and/or barriers and signage as necessary. Members of the public cannot unknowingly enter areas close to the antennas where exposure may exceed the relevant guidelines.
When determining compliance the emissions from all mobile phone network operators on or near to the site are taken into account.
In order to minimise interference within its own network and with other radio networks, Telefonica UK Limited operates its network in such a way the radio frequency power outputs are kept to the lowest levels commensurate with effective service provision
As part of Telefonica’s network, the radio base station that is the subject of this application will be configured to operate in this way.
All operators of radio transmitters are under a legal obligation to operate those transmitters in accordance with the conditions of their licence. Operation of the transmitter in accordance with the conditions of the licence fulfils the legal obligations in respect of interference to other radio systems, other electrical equipment, instrumentation or air traffic systems. The conditions of the licence are mandated by Ofcom, an agency of national government, who are responsible for the regulation of the civilian radio spectrum. The remit of Ofcom also includes investigation and remedy of any reported significant interference.
The telecommunications infrastructure the subject of this application accords with all relevant legislation and as such will not cause significant and irremediable interference with other electrical equipment, air traffic services or instrumentation operated in the national interest.
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3. Technical Justification
Enclose predictive coverage plots if appropriate, e.g. to show coverage improvement. Proposals to improve capacity will not generally require coverage plots.
Reason(s) why site required e.g. coverage, upgrade, capacity
A base station site is required in this location in order to improve existing network coverage and capacity, as well as catering for future networks demands for both Telefónica, commonly known as O2 and Vodafone to this area of Wiltshire. There are no existing Telefonica or Vodafone sites that can be upgraded to provide the coverage required in this area, hence the need for a new site.
Telefonica and Vodafone are both Electronic Communications Code Systems Operators licensed under the terms the Communications Act 2003 to provide mobile personal communications networks in the UK. In order to improve the level of service it provides for their customers in line with its licence requirements, both companies are constantly developing their networks, as well as refining and modernising their equipment. Given the dynamic and constantly evolving nature of technological advances in telecommunications products, coupled with the demands on operators from subscribers to provide new and better quality services, this dictates a continual reinvestment programme in the infrastructure behind the use of mobile devices. Operators are currently involved in developing sites to provide coverage to areas which have not benefited from access to the full services they offer and to areas of their existing network where increased capacity or improved service quality is required.
Due to the dramatic rise in the use of mobile data, the industry has had to consider new operating models that are efficient at delivering services to a much larger percentage of the UK’s population. As previously discussed both companies will pool their basic network infrastructure, while running two, independent, nationwide networks. By doing this, they will both reach far more of the country far faster than they could achieve on their own. This single network grid will automatically increase each operator’s footprint by 40%, adding competition and choice for customers in areas that previously only had one operator’s coverage available.
This agreement will also lay the foundations for advancements in mobile technologies which can be rolled out faster to customers with enabled devices. The pooling together of the networks could also mean a reduction in the number of sites in the UK from the two operators, so there would be environmental benefits as some base stations will be decommissioned. In the future the CTIL agreement will also allow new sites to be built in areas which neither company has been able to reach on its own. From a customer perspective, users should not see any depreciation in coverage as a result of the CTIL venture as customers will continue to use each operator’s independently branded networks.
Further detail regarding the general operation of the Telefonica and Vodafone networks can be found in the accompanying document entitled ‘General Background Information for Telecommunications Development’. This information is provided to assist the local planning authority in understanding any technical constraints on the location of the proposed development.
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4. Site Selection Process
Alternative sites considered and not chosen
Site Site Name and address National Reason for not choosing Grid Reference St Michael & All Angels 413382, The church was not selected by the operator. RT Church, The Grange, West 168134 The church was considered to be restrictive in Overton, Wiltshire, SN8 terms of coverage capacity. 4ES
The Bell PH, 99 Bath 412820, The construction of The Bell PH does not lend RT Road, West Overton, 168274 itself well to accommodating a rooftop Marlborough, Wiltshire, telecommunications site. SN8 1QD
South Farm, West Overton, 413258, There are tall, mature trees at Land at South GF Marlborough, Wiltshire, 167714 Farm. A site in this location would be likely to SN8 4ER require a substantially bigger structure which could appear prominent in an elevated position.
North Farm, Bath Road, 413148, It is considered a new structure in this location GF West Overton, 168636 would appear more prominent and visually Marlborough, Wiltshire, intrusive than the proposed option. SN8 1QE
Dene Farm, Lockeridge, 414148, The site is not available for a GF Marlborough, Wiltshire, 168699 telecommunications installation. SN8 4EQ
Flintstone Stud, West 414070, No response from the site provider to the GF Overton, Marlborough, 168043 proposal made. Wiltshire, SN8 4ER
Kennet Valley Hall, 414198, The site is too far east to provide the required GF Lockeridge Lane, 167973 coverage improvements to East Kennett. Lockeridge, Marlborough, Wiltshire, SN8 4EL
Alternative land at Manor 412625, Some of the land at Manor Farm has been GF Farm, Manor Farm, West 167804 relatively recently sold. The owner / land agent Overton, Marlborough, of the land sold has failed to confirm any Wiltshire, SN8 4ER interest that the would be available for a telecommunications site. West Overton SW, Land 412852, Limited available highways land. There are SW Adjacent Manor Farm, 168186 also power lines in very close proximity. A site West Overton, cannot be built in this location due to health & Marlborough, Wiltshire, safety restrictions. SN8 1QD
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If no alternative site options have been investigated, please explain why:
N/A
Land use planning designations:
The site is located within the North Wessex Downs Area of Outstanding Natural Beauty and Avebury World Heritage Site.
North Wessex Downs AONB Management Plan 2014 – 2019
‘The Management Plan 2014-19 will: • seek to support a viable rural economy, so as to provide resources for those who manage the area’s landscapes; • outline the principles of our response to development that may affect the beauty and tranquillity of the North Wessex Downs; • identify priorities for resources, including staff and money, that will maximise conservation and minimise damage; and • inform people about the unique landscapes of the area and how best to enjoy these beautiful landscapes and support their conservation.
The North Wessex Downs lies across nine different local authority areas. Planning law requires that applications for planning permission must be determined in accordance with the development plan, unless material considerations indicate otherwise. Therefore, the North Wessex Downs looks to its constituent local authorities to consider the designation within their Local Plans. This is set out in the CRoW Act 2000 and National Planning Policy Framework (NPPF).
To assist its local authority partners the North Wessex Downs Partnership will: • actively engage in the policy making process; • provide advice on specific planning applications and appeals; and • provide guidance through its Management Plan and Position Statements
‘The National Planning Policy Framework provides specific guidance for plan makers and decision takers in relation to AONBs. It confirms that “great weight” should be given to conserving their landscape and scenic beauty; and that they have the highest status of protection in relation to landscape and scenic beauty. In relation to major development, the NPPF (paragraph 116) states that planning permission should be refused in AONBs, except in exceptional circumstances and where it can be demonstrated, they are in the public interest. The North Wessex Downs Partnership will define “major development” as set out in Statutory Instrument 2010 No.218450
Particular attention drawn to is paragraph 14 footnote of the NPPF that restricts the “presumption in favour of sustainable development” in AONBs. The NPPF states that local authorities should set criteria based policies against which proposals for any development on, or affecting, protected wildlife or geodiversity sites or landscape areas will be judged (paragraph 113). Local Plan policies should clearly differentiate between land within and outside AONBs. Recognition of the special qualities of the North Wessex Downs by local authority partners will strengthen Local Plans. The North Wessex Downs Partnership will: • advise their local authority and neighbourhood planning partners in the preparation of plans; • advise on forming decisions on planning applications and appeals; and • monitor objectives of Local Plans and development management decisions’
Stonehenge and Avebury World Heritage Site Mangement plan
4.2 Planning and policy framework Protection of the WHS 4.2.1 Article 4 of the World Heritage Convention requires States Parties to protect World Heritage Sites. The planning system depends on a hierarchy of the National Planning Policy Framework (NPPF) and Local Plans which include Core
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Strategies and other relevant Development Planning Documents including Neighbourhood Plans. These documents set out policies according to which local authorities determine planning applications. It should be remembered that although the policy framework may have changed as discussed below, legal obligations remain in force, such as the Ancient Monuments and Archaeological Areas Act 1979 which protects individual Scheduled Monuments within the Site through the Scheduled Monument consent system and the World Heritage Convention itself.
4.2.11 The general approach to assessing the impact of development is set out in the NPPF. It requires that sufficient evidence is provided by developers to assess the impact on the WHS and its attributes of OUV. This might include visual impact and other methods of assessment. Reference is made to the ICOMOS Heritage Impact Assessment Guidelines and English Heritage’s Setting Guidance (2011).
Additional relevant information (planning policy and material considerations):
“Recognising the vital importance of mobile connectivity for residents and local economies, the urgent delivery of the required network improvements continues to be a Government priority. As recently as 9th March 2016 former Prime Minister David Cameron stated:
‘Ten years ago, we were all rather guilty of leading campaigns against masts and all the rest of it. Our constituents now want internet and mobile phone coverage. We need to make sure that we change the law in all the ways necessary, that the wayleaves are granted, that the masts are built, that we increase coverage and that everyone is connected to the information superhighway.’
This is substantiated in the budget announcement of 16th March 2016, which commits to provisions for “greater freedoms and flexibilities for the deployment of mobile infrastructure”. The proposed telecommunications base station at Land at Manor Farm, West Overton forms a part of this greater drive to address the deficit in mobile phone coverage and capacity.”
Planning Policies
Local Planning Policy
The local plan sets out local planning policies and identifies how land is used, determining what will be built where. In Wiltshire, the local plan includes the Wiltshire Core Strategy, saved policies from district local plans and minerals and waste plans.
Wiltshire Core Strategy
In January 2015, we adopted the Wiltshire Core Strategy. The Core Strategy replaces the South Wiltshire Core Strategy and many saved policies from former district local plans. The Wiltshire Core Strategy Development Plan Document (‘the plan’) was formally adopted on 20 January 2015. The plan provides a positive and flexible overarching planning policy framework for Wiltshire for the period up to 2026.
Saved Local Plan Policy - Telecommunications - PS7
‘Telecommunications are an essential and beneficial element of modern day life and the national economy. Much of the telephone network within the District is long established. New communication technology is now spreading rapidly, required to meet the growing demand in the area for better communications at work and home, in business and in public services.
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In considering proposals for new telecommunications development, the Local Planning Authority will take into account the impact of the proposal on the environment and residential amenity protecting as far as possible, the appearance of buildings, settlements and the countryside from unsightly telecommunications equipment. This is particularly important in the New Forest Heritage Area, the Stonehenge World Heritage site and its setting, the Cranborne Chase and West Wiltshire Downs Area of Outstanding Natural Beauty, Sites of Special Scientific Interest and Conservation Area. In most cases, early proposals for new telecommunication development will be subject to the following considerations:
(i) where the proposal involves the New Forest, the Stonehenge World Heritage site, the Cranborne Chase and West Wiltshire Downs Area of Outstanding Natural Beauty, Sites of Special Scientific Interest, Conservation Areas or areas and buildings of architectural and historic importance, such development will only be permitted where technical considerations mean that there are no satisfactory alternative locations available. In such instances, the environmental impact of the development should be minimised by the judicious use of siting, design and landscaping. (ii) elsewhere in the District proposals will be allowed provided that their siting and design minimise the environmental impact of the apparatus; and (iii) applications for large masts should show evidence that the possibility of erecting antennae on an existing building, mast or other structure has been explored. Where such development is no longer required its removal will be sought.
National Planning Policy Framework (2012)
5 - Supporting high quality communications infrastructure The National Planning Policy Framework (NPPF) set out Central Government’s planning policies for England and how these are expected to be applied. It replaces a number of planning documents including Planning Policy Guidance 8 – Telecommunication. NPPF sets out the Central Government’s requirements for the planning system only to the extent that it is relevant, proportionate and necessary to do so. It provides a framework within which local people and their accountable councils can produce their own distinctive local and neighbourhood plans, which reflect the needs and priorities of their communities.
Pertinent to telecommunications development section 5 of NPPF sets out the Governments general overview regarding supporting high quality communications infrastructure and is stated as follows: -
“42. Advanced, high quality communications infrastructure is essential for sustainable economic growth. The development of high speed broadband technology and other communications networks also plays a vital role in enhancing the provision of local community facilities and services.
43. In preparing Local Plans, local planning authorities should support the expansion of electronic communications networks, including telecommunications and high speed broadband. They should aim to keep the numbers of radio and telecommunications masts and the sites for such installations to a minimum consistent with the efficient operation of the network. Existing masts, buildings and other structures should be used, unless the need for a new site has been justified. Where new sites are required, equipment should be sympathetically designed and camouflaged where appropriate.
44. Local planning authorities should not impose a ban on new telecommunications development in certain areas, impose blanket Article 4 directions over a wide area or a wide range of telecommunications development or insist on minimum distances between new telecommunications development and existing development. They should ensure that: • they have evidence to demonstrate that telecommunications infrastructure will not cause significant and irremediable interference with other electrical equipment, air traffic services or instrumentation operated in the national interest; and • they have considered the possibility of the construction of new buildings or other structures interfering with broadcast and telecommunications services.
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45. Applications for telecommunications development (including for prior approval under Part 24 of the General Permitted Development Order) should be supported by the necessary evidence to justify the proposed development. This should include: • the outcome of consultations with organisations with an interest in the proposed development, in particular with the relevant body where a mast is to be installed near a school or college or within a statutory safeguarding zone surrounding an aerodrome or technical site; and • for an addition to an existing mast or base station, a statement that self-certifies that the cumulative exposure, when operational, will not exceed International Commission on non- ionising radiation protection guidelines; or • For a new mast or base station, evidence that the applicant has explored the possibility of erecting antennas on an existing building, mast or other structure and a statement that self certifies that, when operational, International Commission guidelines will be met.
46. 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.”
Planning Assessment
From the outset, it should be appreciated that irrespective of the installation's use as a telecommunications base station, the installation of a tall structure will always be, to some degree, a noticeable alteration to those residents and regular passers-by found closest. However, it should be recognised that visibility or a development's height and design does not automatically result in an overwhelming adverse harm.
As mentioned previously, it is considered that the replica telegraph pole choice of design, adjacent trees of a similar height, will not undermine the visual amenity of the area. In this respect balanced against the other matters as below, it is considered that the proposal is acceptable.
Taking into account the wider area and it is considered that this area of Manor Farm is an appropriate location for a Greenfield installation, with a ‘streetworks’ style design. In light of the above it is considered that the proposal would not be overly intrusive in the locality and its visual impact would not outweigh the continued need and future demands to provide coverage to this area of West Overton, East Kennett and Lockeridge. The visual impact of the site will be assimilated by the adjacent trees and existing telegraph poles, albeit of a smaller height. It is evident that the proposed development adheres to the above policy. First of all, the proposal opens the possibility of sharing: the site would be utilised by two operators.
Secondly, it would not have a significantly adverse effect on the character and visual amenities of the locality. The fact that the installation will be visible at point in the surrounding area, does not itself demonstrate that the proposal will cause unacceptable harm to the visual amenity of locality.
There are no available existing structures in the search area and an ICNIRP Declaration has been submitted with this application.
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Contact Details
Name: (Agent) Craig Horn Telephone: 07851 005034 Operator: Telefonica UK Fax no: Limited Address: 2 Charnwood House Email Address: [email protected] Marsh Road, Bristol, BS3 2NA 04/04/2017 Signed: Date: Maxema Limited
Position: Surveyor Company:
(on behalf of CTIL and above operator)
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