PLANNING, HERITAGE, DESIGN & ACCESS STATEMENT

Wroxham Football Club, Trafford Park, Skinner Lane, Norwich

Shared Access Ltd June 2018 P18-0879

JUNE 2018 | MP | P18-0879

PLANNING APPLICATION FOR REPLACEMENT OF AN EXISTING 17.5M FLOODLIGHT WITH A 20M MONOPOLE TO SUPPORT 3NO. TELECOMMUNICATIONS ANTENNA AND ANCILLARY EQUIPMENT (FLOODLIGHT TO BE INSTALLED)

PLANNING, HERITAGE, DESIGN AND ACCESS STATEMENT

WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE, NORWICH, NR12 8SJ

ON BEHALF OF SHARED ACCESS LTD AND MOBILE BROADBAND NETWORK LIMITED

TOWN & COUNTRY PLANNING ACT 1990 (AS AMENDED) PLANNING AND COMPULSORY PURCHASE ACT 2004

Pegasus Group

First Floor | South Wing | Equinox North | Great Park Road | Almondsbury | Bristol | BS32 4QL T 01454 625945 | F 01454 618074 | W www.pegasusgroup.co.uk

Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | Liverpool | London | Manchester

©Copyright Pegasus Planning Group Limited 2011. The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Limited SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

CONTENTS:

Page No:

1. INTRODUCTION 1 2. THE JOINT APPLICANTS AND THE SITE PROVIDER 3 3. THE RAILWAY PROJECT 5 4. THE APPLICATION SITE AND WIDER CONTEXT 8 5. PLANNING HISTORY OF THE SITE AND SURROUNDS 11 6. THE PROPOSED TELECOMMUNICATIONS INSTALLATION 13 7. PLANNING POLICY 16 8. PRE-APPLICATION CONSULTATION (CODE OF BEST PRACTICE) 22 9. DESIGN AND ACCESS STATEMENT 24 10. HERITAGE STATEMENT 26 11. LANDSCAPE ASSESSMENT 31 12. PLANNING ASSESSMENT 34 13. CONCLUSIONS 44

APPENDICES:

APPENDIX 1: SITE LOCATION PLAN APPENDIX 2: TELECOMMUNICATIONS INSTALLATIONS SITE PLAN APPENDIX 3: EXISTING AND PROPOSED LUX LEVELS APPENDIX 4: ICNIRP CERTIFICATE APPENDIX 5: PRE-CONSULTATION LETTER TO EXISTING RESIDENTS APPENDIX 6: SCHOOL CONSULTATION LETTER APPENDIX 7: WROXHAM CONSERVATION AREA MAP APPENDIX 8: RADIO COVERAGE PLOTS APPENDIX 9: ALTERNATIVE SITE PLAN

SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

1. INTRODUCTION

1.1 This Planning, Heritage, Design and Access Statement supports an application for the replacement of an existing 17.5m floodlight with a 20m monopole for the installation of electronic communications apparatus and has been prepared by Pegasus Group on behalf of Shared Access and Mobile Broadband Network Limited (MBNL) (joint applicants). The application site relates to Wroxham Football Club, Trafford Park, Skinners Lane, Norwich, NR12 8SJ (herein referred to as Wroxham FC). A Site Location Plan is provided at Appendix 1.

APPENDIX 1 – SITE LOCATION PLAN

1.2 The description of development listed on the application form is for the:

“Replacement of an existing 17.5m floodlight with a 20m monopole to support 3no. telecommunications antenna and ancillary equipment (floodlight to be installed)”

1.3 This document describes the application site, the detailed parameters of the proposal and clarifies the process that has led to the development proposal. The responsibilities and ownerships of the joint applicants will also be made clear. This statement provides the necessary background and justification for the technical requirement for an installation at Wroxham FC, in the context of planning policy and all other relevant material considerations. Importantly, this statement, and supporting enclosures, particularly ‘The Benefits of Mobile Connectivity’, highlight the economic, social and environmental benefits of the development proposal.

1.4 This site forms part of a wider national project by EE to provide improved coverage along major infrastructure routes, specifically the rail network, to enable 4G coverage across trainlines around the country. Known within the telecommunications sector as ‘100% coverage’ this project is focused on ensuring that key rail routes across the country have a full 4G service along the entire line throughout passengers’ journeys, including tunnels and other hard to reach ‘not spots’.

1.5 The site will be managed by MBNL which is a joint venture between both EE and Three UK Ltd where both infrastructure and antennas are often shared between operators. This allows the opportunity for Three UK Ltd to use the structure in the future should they also wish to provide similar coverage at this location. The site

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will also provide improved coverage and capacity across Wroxham with one of the antennas able to be targeted toward the built up area of the village.

1.6 The spectrum licences sold by Ofcom for 4G included targets for 98% of the British population to have access to a 4G network. The recent spectrum licences sold for 5G seek to ensure that the population have access to 5G irrespective of where they live or work. The 4G and 5G networks demand not only signal coverage, but also improved capacity in order to provide better and faster modern data intensive communications.

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2. THE JOINT APPLICANTS AND THE SITE PROVIDER The section describes the relationship between Shared Access, MBNL (joint applicants) and the site provider. Information is also provided in respect of each of these organisations and their background and make up.

Shared Access

2.1 Shared Access are an independent owner and operator of wireless communications infrastructure. The company develops and builds conventional telecommunications installations, floodlight schemes with integrated antenna systems, and is a leading investor for ‘In Building and Distributed Antenna Systems’. They are at the cutting edge of telecommunications technology and roll-out across the UK. Once developed, Shared Access manage the site ensuring maintenance, health and safety and site access are kept to the highest standards and within agreements with the site provider/landlord.

2.2 Alongside this they have created an attractive financial model to better enable telecommunications networks to be financed and deployed, whilst at the same time providing investment opportunities for community facilities and other community groups. Shared Access partner with various community groups, such as sporting clubs; Parish Councils; and, schools; to deploy discreet state-of-the-art telecommunication installations within sites and facilities owned by these groups.

2.3 This results in improved broadband and mobile coverage, provided on site through a lease agreement with the site provider, and investment in local community infrastructure. This partnership is rare within the telecommunication sector. Typically, Mobile Network Operators will seek to install masts on highways land (known as ‘streetworks’ installations), since there is limited land cost associated with such installations.

2.4 In the instance of Wroxham FC, Shared Access have partnered with MBNL to deliver a site that will enhance network coverage on the Great Eastern Mainline. The proposal will provide both an improvement in coverage to the local area across a range of technologies and network capacity bringing benefits to surrounding businesses and residents.

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MBNL (Mobile Broadband Network Limited)

2.5 MBNL is a joint venture between EE and Three UK, pursuant to which the two companies plan to jointly operate and manage a single network grid across the UK. The joint-venture agreement allows both organisations to pool their basic network infrastructure, while running two independent nationwide electronic communications networks; maximise opportunities to consolidate the number of installations in accordance with Government policy; and reduce significantly the environmental impact of network development. This includes enabling future site sharing opportunities where possible.

Wroxham FC

2.6 Wroxham FC are an active local football club. The club aims are to provide facilities for and promote participation of the whole community in the sport of football and be an asset for the whole community of Wroxham and the surrounding areas. The club has an academy associated with Norwich City.

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3. THE RAILWAY PROJECT

3.1 It is generally acknowledged and understood that working patterns have dramatically changed in the 21st century and people are increasing using flexible working practices across all industries. EE (MBNL) are looking to provide improved and enhanced coverage and capacity to busy and important commuter routes to enable such practises and support modern data heavy communication, integral to occupations across the spectrum of employment and employers. The proposed telecommunications installation is therefore essential to the technical coverage and capacity requirements of mobile connectivity, bringing the latest technologies and competitive coverage, including 4G and in the future 5G, to the Great Eastern Mainline.

3.2 The railway project is known as ‘100% coverage’ and is being led by EE focussed on providing 4G (incorporating 2G & 3G) coverage for commuters on major routes around the south of England and into London. This will not only make journeys more enjoyable and productive, but will help improve the operation and safety of the railway and deliver economic benefits for the whole of the UK. Current radio coverage is largely delivered through mobile phone networks that have been optimised to serve population centres, often based in locations away from rail tracks, meaning coverage is patchy in many places, non-existent in others.

3.3 In accordance with Government planning policy, EE (MBNL) is actively seeking to improve mobile telecommunications services to the Great Eastern Mainline and has identified the application site as the most suitable opportunity to provide the required level of radio coverage to resource this section of the railway, whilst minimising the impact of the development on the historic environment of Wroxham through an opportunity to replace an existing structure. The redevelopment of an existing floodlight will avoid the requirement for a standalone telecommunications installation elsewhere within the locality.

3.4 The constraints of this project are different from the ‘normal’ deployment of new telecommunications infrastructure where the very specific target area, the rail line, mean that the ‘cell search’ area (please see Section 12 for more details) and potential site options are significantly reduced. Typically, the built form of rail lines includes deep cuttings, tunnels and rail tracks have additional safety requirements which mean it is not often straightforward to deploy infrastructure along railway lines. This is also affected by the ‘Faraday effect’ where due to their construction

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using aluminium and multilayer metal laminated glass, modern train carriages act like giant ‘Faraday cages,’ which cause radio signals to glance off the outside of the carriage. This is further complicated by the high speeds at which trains travel that means ‘handovers’ between base stations and individual telecommunication installations is more complex than traditional forms of cellular coverage.

3.5 The Government is currently consulting on minimum standards for mobile connectivity for passengers on all mainline routes, with the aim to dramatically improve coverage by 20251. The rapid growth of mobile data requirements now means that consumers expect high quality, reliable connectivity everywhere. As part of its wider 5G strategy the Government has committed to improving coverage where people live, work and travel - including on train lines.

3.6 Over the past few years, the Government and train operators have invested in equipping trains with improved Wi-Fi and worked with Mobile Network Operators to address some rail ‘not-spots’. However, there is still a prevalence of ‘not-spots’, where there is either no signal or insufficient signal capacity to provide connectivity for commuters and rail passengers. These problems affect both mobile phones and on-train Wi-Fi, which typically uses mobile phone networks for ‘backhaul’, i.e. to connect the on-train service with core telecommunications networks.

3.7 There is a clear, strong economic link between improving coverage for rail commuters and deploying new sites relating to improved productivity. Given that 1.7 billion2 journeys are made each year, this lack of connectivity equates to a poor experience for commuters and passengers and most importantly, millions of productive hours lost. The UK Government is particularly keen to tackle relatively poor rates of productivity. In November 2017, the Government’s Industrial Strategy3 was announced to address productivity performance across the UK. Through boosting connectivity on the railways, millions of hours of productivity can be unlocked.

3.8 In recent decades commuting by rail has increased in popularity. Between 2002 and 2016, train usage increased by 56 per cent, with the time spent on the railway network rising by 43 per cent. However, the growth in rail journeys has not been

1 https://www.gov.uk/government/consultations/commercial-options-for-delivering-mobile-connectivity-on- trains-call-for-evidence 2 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/663116/rail-factsheet- 2017.pdf 3 https://www.gov.uk/government/topical-events/the-uks-industrial-strategy

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accompanied by a growth in mobile connectivity on rail networks. If fast and reliable mobile connectivity were available during journeys, commuters would have the option to use the time for work, accessing resources, communicating with colleagues and generally transforming those hours from dead time into productive time.

3.9 The result is that Mobile Network Operators need to provide direct and improved coverage and capacity along rail lines and the aim of this installation is to provide coverage in both directions of the targeted track. A third antenna is to be provided to ensure that additional/improved coverage can also be provided to the village of Wroxham.

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4. THE APPLICATION SITE AND WIDER CONTEXT 4.1 This section describes the application site and how it relates to Wroxham and its wider context. Centred at Grid Reference 629660, 316874, the application site is a small area in-between the clubhouse and toilet cabin located to on the eastern side of the wider football club. The area is currently occupied by an existing 17.5m floodlight. The site is a well-established football club situated to the south west of the centre of Wroxham which is comprised of a main grass playing pitch, two spectator stands, single storey clubhouse building, 6no. 17.5m floodlights with a galvanised steel finish and parking areas.

View of eastern side of pitch and site (middle floodlight) looking south- east

4.2 The south and west of the wider site is bound by significant trees and hedging with the eastern side bound by the railway line separating the football ground from Norwich Road and the built-up area of Wroxham. A single bungalow borders the site to the north with open countryside to the west and south. The site is generally well screened from public views, including from the north, with the various built form occupying the site, including clubhouse, in line with a modern sports facility.

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4.3 The site is located within the Wroxham Conservation Area but there are no other heritage or environmental designations affecting the site. The site is adjacent to the boundary of the Broads Authority, which has the equivalent status to a National Park. The nearest listed heritage assets are approximately 500m to the north of the site. The map extract below shows the Conservation Area marked in red with the Broads Authority shaded in green. Wroxham FC is bordered in blue

Wroxham FC

Extract from Map of Wroxham Conservation and the Broads

4.4 The Environment Agency’s flood map confirms the site is within Flood Zone 1, the area least at risk from flooding events. The nearest Public Right of Way (footpath) is located to the east of the railway line with Skinners Lane marked as a surfaced cycle path, shown on the Ordnance Survey Map extract below.

Wroxham FC

Ordinance Survey Map Extract (25K)

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Existing Telecommunications Installations in and around the site

4.5 The nearest existing telecommunication installation is a Network Rail installation a short way south of Wroxham. As set out later, the use of this mast by EE is prohibited by stringent health and safety issues operated by Network Rail.

4.6 Further around 750m to the north, located within Wroxham village, is a CTIL installation at Broadland Funeral Services. This site is now due to be re-located to Wroxham Church Hall. This installation currently (and in the future) incorporates apparatus on behalf of CTIL (O2 and Vodafone) and does not provide coverage for EE.

4.7 The nearest MBNL (EE and Three) telecommunications installation is located around 1.8km to the north at Hoveton and Wroxham Train Station. This is a 25m lattice structure that also provides coverage for CTIL (O2 and Vodafone).

4.8 Appendix 2 shows the existing telecommunications installation in and around Wroxham. This information has been gathered by a physical site survey and using the Councils online mapping, as well as, Ofcoms Sitefinder website and Mast Data that holds a database of telecoms sites.

APPENDIX 2 –TELECOMMUNICATIONS INSTALLATIONS SITE PLAN

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5. PLANNING HISTORY OF THE SITE AND SURROUNDS 5.1 This section details any planning history specifically relevant to the application site itself, as well as, any relevant determined applications in the immediate surrounds.

The Site

5.2 A review of Broadland District Council’s online planning records reveals various planning applications associated with the clubhouse and other facilities. Of note are the following historic planning applications at Wroxham FC:

 Application 880567 for ‘Erection of 6no. 17.5m floodlights’ was granted permission in 1998; and

 Application 20111885 for ‘Erection of fencing, turnstiles, covered spectator area, extension to grandstand, siting of mobile units’ was granted permission in 2012.

The Surrounds

5.3 It is noted that there have been a number of recent applications in and around Wroxham for telecommunications installations. The most relevant is a withdrawn application at Land off Skinners Lane adjacent to the Wroxham FC.

 Application 20172052 for ‘Installation of 1 No 15m Lattice Tower, 2 No Antennas, 2 No 0.6m Dishes, 3 No Equipment Cabinets & Ancillary Development within a 2.2m High Closed Board Wooden Fenced Compound’ at Land off Skinners Lane, Wroxham, NR12 8SL was withdrawn in November 2017.

5.4 It is noted that this application was withdrawn with many third parties and the Council indicating that further examination of sharing an existing structure at the Football Club should be investigated.

5.5 The existing CTIL mast at the Broadland Funeral Services has had recentapplications to upgrade and replace this existing site.

 Application 20160060 for ‘Replacement of existing monopole with a mini- macro pole of the same height supporting 3no. antennas and 2no. dishes 2m to the northeast of the existing position, along with the addition of 1no. ground based equipment cabinet and associated works’ at Broadland

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Funeral Services, 102 Norwich Road, Wroxham was approved in March 2016.

 Application 20171377 for ‘Proposed base station installation – 20 m high monopole supporting 3 No. antennas and 2 No. 600 mm dish antennas, installation of 2 No. equipment cabins, electricity meter cabinet and ancillary works – Prior Notification at Wroxham’ at Church Hall, Norwich Road, Wroxham was approved in September 2017.

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6. THE PROPOSED TELECOMMUNICATIONS INSTALLATION 6.1 This section sets out a detailed explanation of the parameters of the proposal and the factors that have influenced design, scale, siting and appearance.

6.2 As detailed within the Introduction of this Statement, the development proposal has materialised due to a specific technical requirement on behalf of the operator, MBNL, to improve existing network coverage to the Great Eastern Mainline for 2G, 3G and 4G cellular services. The site presents the opportunity to improve the existing telecommunications coverage network for the railway, and the village of Wroxham, without introducing another structure into the area. The scheme will also benefit Wroxham FC and the local community. This is achieved through the leasing of the small parcel of land for the installation in exchange for a capital sum.

Summary

6.3 At present the club is served by 6no. existing 17.5m high floodlights that illuminate the main pitch at Wroxham FC. The proposal seeks to replace one of the existing floodlight columns with a new monopole structure, that will serve a dual purpose by incorporating the existing floodlight at 15m, with the telecommunications equipment above to a maximum height of 20m. This will result in an increase in height over the existing floodlight structure of 2.5m. Associated equipment cabinets would be installed adjacent to the clubhouse and will be screened from public views away from the pitch.

6.4 The existing floodlight lamp will maintain FA compliant levels of lighting to the main pitch. The accompanying drawing package shows the general arrangement of the proposed installation and the accompanying Technical Drawings from Halliday Lighting, shown at Appendix 3, detail the revised lighting arrangements in detail.

APPENDIX 3 – EXISTING AND PROPOSED LUX LEVELS

Telecommunication Proposal

6.5 The technical apparatus necessary as part of the justified MBNL coverage requirement consists of a 20m monopole with 3no. antennae and 2no. dishes. The antenna will be located on a slim headframe to provide a discreet appearance but also to enable the antennae to be directed toward the required target area, namely the railway and the built-up area of the village. The 2no. dishes will be located at 16.5m being 0.6m and 0.6m in diameter. The monopole will have a galvanised

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finish to match the existing floodlight columns. The location of the replacement structure is marginally different from the exiting floodlight, being very slightly to the south.

6.6 The proposed height to the top of the installation is 20m. The required height is defined by a combination of safeguarding the existing floodlighting, nearby trees and the topography of the area, which would otherwise obstruct the signal. A smaller mast would not provide the necessary coverage requirements because surrounding landform and trees would prevent the radio signal from propagating in an efficient matter toward the rail line which is the specific target for this required coverage.

6.7 The site has been selected due to its potential for a replacement of an existing floodlighting column offering a subtler intervention than a new structure, as well as, its location beyond the historic heart of Wroxham. The site benefits from existing access and the nearby clubhouse allows the installation of cabinets and power connections to be screened. The surrounding trees also serve to help partially screen the mast from nearby residential properties.

6.8 5no. cabinets include radio equipment and the electricity supply will be discreetly located within the grounds between the clubhouse and the toilet block. The details of the cabinets are as follows:

 1no. MBNL Cobra Cabinet - 1898mm x 798mm x 1898mm;

 1no. MBNL Link A/C Cabinet - 600mm x 500mm x 1781mm;

 1no. MBNL Fredo Cabinet - 900mm x 800mm x 1490mm;

 1no. FSGC – 655mm x 255mm x 1265mm; and

 1no Shared Access Meter Cabinet – 1000mm x 470mm x 1250mm.

6.9 The cabinets will be painted grey a recessed colour to blend into the nearby buildings. The cabinets themselves are of vandal proof design.

6.10 The ICNIRP certificate that accompanies this submission demonstrates that the proposal meets International Commission guidelines for public exposure.

APPENDIX 4 – ICNIRP CERTIFICATE

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Floodlight Proposal

6.11 The existing floodlight will be attached at 15m to the new structure. This will result in some minor changes to the floodlighting levels but will still meet modern standards and those of the Football Association.

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7. PLANNING POLICY

7.1 In this section, national and local planning policy guidance pertinent to the application site and development proposal are identified. The plan-led approach to development, as enshrined by Section 38 (6) of the Planning and Compulsory Purchase Act 2004, requires development proposals to accord with the adopted development plan unless material considerations indicate otherwise.

7.2 The Development Plan relevant to this proposal comprises:

 Joint Broadland, Norwich and South Norfolk Core Strategy (adopted 2011, amendments 2014);

 Broadland District Council Development Management DPD (adopted 2015); and,

 Broadland District Council Site Allocations DPD (adopted 2016).

7.3 Material policy considerations include the relevant National Policy Guidance:

 National Planning Policy Framework (NPPF) (2012)

7.4 Other material policy considerations include:

 Sport England – A Sporting Future for the Playing Fields of England

i) The Development Plan

Joint Core Strategy DPD 2014

7.5 The Joint Core Strategy (JCS) covers three separate local planning authorities Broadland District Council, Norwich City Council and South Norfolk District Council. The JCS was originally adopted in 2011 but subsequent High Court challenges brought about a series of amendments in 2014.

7.6 Policy 1 - Addressing climate change and protecting environmental assets: This policy incorporates the only heritage policy for the Broadland District. It states:

‘The built environment, heritage assets, and the wider historic environment will be conserved and enhanced through the protection of buildings and structures which contribute to their surroundings, the

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protection of their settings, the encouragement of high-quality maintenance and repair and the enhancement of public spaces.’

7.7 Policy 2 – Promoting Good Design: All development will be designed to the highest possible standards, creating a strong sense of place. This includes taking account of the following (inter alia):

• The historic hierarchy of the city, towns and villages, maintaining important strategic gaps;

• The landscape setting of settlements including the urban/rural transition and the treatment of ‘gateways’;

• The landscape character and historic environment, taking account of conservation area appraisals and including the wider countryside and the Broads area; and,

• Townscape, including the city and the varied character of our market towns and villages

7.8 Policy 6 – Access and Transportation: This policy outlines the strategy for improving access throughout the area, including “provision of IT links, telecommunications and promotion of home working”. This also includes promoting and enhancing rail services and ensuring that fast broadband connections will be promoted throughout the area. All new development must demonstrate how it contributes to this objective.

Development Management DPD 2015

7.9 The Broadland District Council’s Development Management DPD was adopted in 2015 and builds on the key strategic policies of the Joint Core Strategy.

7.10 Policy GC2 – Location of New Development: This policy sets out that new development will be accommodated within settlement limits defined on the policies map.

7.11 Policy GC4 – Design: Development is expected to achieve a high standard of design. They should pay adequate regard to (inter alia):

i. The environment character and appearance of an area;

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ii. Considering the impact upon the amenity of existing and future properties;

iii. Making efficient use of land and resources; and

iv. Incorporating appropriate infrastructure.

7.12 Policy EN2 – Landscape: Sets out that proposals should have regard to the Landscape Character Assessment SPD and protect and enhance landscape character with particular regard to (inter alia):

i. Visually sensitive skyline, indulging the setting of the Broads Area; and,

ii. Conservation Areas.

7.13 Policy CSU1 – Additional Community Facilities: This policy promotes proposals which improve the range of community facilities and local services available within the district will be encouraged where no significant adverse impact would arise. It has a specific subsection on telecommunications.

7.14 Sub-Section 9.5 – Telecommunications: “Paragraphs 43-46 of the NPPF provide guidance for local planning authorities when determining telecommunications applications (including for prior approval under part 24 of the General Permitted Development Order). Policy 6 of the JCS promotes the provision of IT links, telecommunications and home working. Policy 10 states that major development locations will ensure high quality telecommunications and adequate energy supply and sewerage infrastructure.”

Site Allocations DPD 2016

7.15 Policy WR01 – Land west of Salhouse Road: This is the only site allocated at Wroxham which is to be developed for 100 dwellings and open space in line with Planning Permission 20130965 to the south east of the football club.

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ii) Material policy considerations

National Planning Policy Framework 2012

7.16 The National Planning Policy Framework (NPPF) forms the national planning policy against which this proposal should be assessed. Section 5, paragraphs 42-46 covers Telecommunications.

7.17 One of the core planning principles contained within the NPPF is the need to proactively drive and support sustainable economic development in order to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Paragraph 42 of the NPPF states that the development of high-speed broadband technology and other communications networks plays a vital role in enhancing the provision of local community facilities.

7.18 Policy within the NPPF stresses that advanced, high quality communications infrastructure is essential for sustained economic growth. The NPPF also recognises that local planning authorities should support the expansion of electronic communications networks, including telecommunications. The proposal will provide vital high-speed mobile broadband and multimedia technology communication networks to local residents and businesses in their homes and businesses and to people passing through dependent upon their mobile phones.

7.19 The NPPF stresses that local planning authorities should aim to keep the number of masts to a minimum consistent with the efficient operation of the network. Paragraph 44 states that local planning authorities should not impose a ban on new telecommunications development in certain areas or insist on minimum distances between new telecommunications development and existing development.

7.20 Paragraph 45 insists that as part of a planning application for a new mast, applicants should provide supporting information which demonstrates that they have explored the possibility of erecting antennas on existing buildings, masts or other structures and that they submit a statement that self certifies that International Commission guidelines for safety are met by the proposed installation. Justification of the proposal against Paragraph 45 is provided in the following section of this statement.

7.21 Paragraph 46 confirms that local planning authorities must determine applications on planning grounds and should not question the need for the telecommunications

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system, or determine health safeguards if the proposal meets International Commission Guidelines for public exposure.

7.22 Paragraph 65 sets out that Local planning authorities should not refuse planning permission for buildings or infrastructure which promote high levels of sustainability because of concerns about incompatibility with an existing townscape, if those concerns have been mitigated by good design.

7.23 Paragraphs 128 and 131 cover the determination of applications in regard to heritage asserts. In particular it outlines that applicants should describe the significance of any heritage assets affected, including any contribution made by their setting but also that level of detail should be proportionate and no more than is sufficient to understand the potential impact of the proposal on their significance.

7.24 Paragraph 133 goes on to set out that where a development will lead to less than substantial harm, the public benefits of the proposal should be weighed against the harm.

7.25 The revised NPPF published for consultation in March 2018 is a material consideration from the day of publication. It should be noted that there are very few changes to the policies concerning telecoms development and that the expansion of mobile networks and electronic communications is reconfirmed as essential to the economic and social prosperity of the country.

Sport England Planning Policy Statement: A Sporting Future for the Playing Fields of England

7.26 Sport England are a statutory consultee on all planning applications for development affecting playing field land. They recently updated their Playing Fields Policy is set out in Sport England ‘Playing Fields Policy and Guidance’ (March 2018).

7.27 Policy P1 says that Sport England will oppose the granting of planning permission for any development which would lead to the loss of, or would prejudice the use of, all or any part of a playing field, or land last used for a playing field unless, in the judgement of Sport England, specific mitigating circumstance apply.

7.28 The document goes on to list specific exceptions. Exception 3 is applicable to the current application and states there would be no objection where the proposed development affects only land incapable of forming part of a playing pitch, and does

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not reduce any playing pitch, the sporting capacity of the playing field or the loss of any other sporting provision or /ancillary facilities.

7.29 Since the application site relates to an area away from the pitches and main field of the football ground, the application is regarded to preserve the playing pitch.

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8. PRE-APPLICATION CONSULTATION (CODE OF BEST PRACTICE) 8.1 This section sets out details of the pre-application discussions and assessments that have taken place prior to the submission of the application.

8.2 The Telecommunication Operator Code of Best Practice on Mobile Development in England, published November 2016, sets out best practice for pre-application consultations for development proposals that include the installation of new and upgraded electronic communications base stations, such as installations. In accordance with that Code, the applicants carried out pre-application consultation with local residents and various statutory bodies including the local planning authority.

8.3 This is supported in the NPPF where paragraph 45 sets out that mobile operators and infrastructure providers should provide supporting information which includes the outcome of consultations with organisations with an interest in the proposed development

8.4 The Code of Best Practice sets out advice on how telecommunication code system operators should approach pre-application consultation. Depending on a traffic light rating of the site, different levels of pre-application consultation are recommended. In this case, the installation of the telecommunications equipment has been assessed as ‘Amber’ given its relative remoteness from the built-up area of Wroxham. The Code of Best Practice stresses that a rating of amber does not mean the proposal should not be progressed. Rather, it simply indicates a higher level of public consultation may be needed prior to submission of the planning application.

8.5 In this case, the applicant has written to local schools within 1km, the local MP and Ward Councillors, as well as approximately 120 local resident addresses within the area, shown by the below map extract. The pre-consultation letter is provided at Appendix 5.

APPENDIX 5 – PRE-CONSULTATION LETTER TO EXISTING RESIDENTS

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Map showing area of community consultation

8.6 The following schools and nurseries were written to in accordance with The Code of Best Practice. An example letter is provided at Appendix 6.

 St John's Community Primary School and Nursery, Horning Road, Hoveton, Norwich, NR12 8NX

APPENDIX 6– SCHOOL CONSULTATION LETTER

8.7 There were no medical facilities and health centres within 1km of the site.

Responses

8.8 A total of 5 response were received. Two objected to the mast and indicated they favoured the previous proposal at Land off Skinners Lane, two requested further information regarding O2 and the status of the mast at Church Hall, and a response from the Broadland District Council stated that further evidence of need and an assessment of alternative sites was necessary.

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9. DESIGN AND ACCESS STATEMENT

9.1 The development proposed involves engineering operations and so is exempt from the requirement to provide a design and access statement under Article 8 (4) (c) of The Town and Country Planning (Development Management Procedure) (England) (Amendment) Order 2013.

9.2 However, to assist the Council’s determination and in accordance with validation requirements, this section provides a description of the process adopted in the design of the proposal and explains the access considerations.

Use

9.3 The proposed development will provide 2G, 3G and 4G radio coverage to both the Great Eastern Mainline and the local area.

9.4 A single new monopole is proposed to the replace the existing floodlight column that will have the existing floodlight installed with telecommunications apparatus located above.

9.5 The use as a football club would otherwise remain.

Amount and Layout

9.6 The land take of the proposal is less than 10 square meters.

9.7 The ground based telecommunications equipment is to be sited as close to the monopole as possible so as to consolidate apparatus and maximise the efficiency of radio transmission.

Scale

9.8 The monopole will measure 17.5m in height. 3no. antenna will sit on top of the monopole on a slim headframe to a maximum height of 20m, with 2no. dishes located at 16.5m. The floodlights would be installed to a maximum height of 15m. The 5no. ground based cabinets are approximately 6.9m3.

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Appearance

9.9 The equipment cabinets will be of metal construction and finished grey (RAL 7035). The mast itself will be galvanised, designed to match the existing floodlights that characterise the football club.

Access

9.10 Vehicular and maintenance access to the site will use an access route direct from Skinners Lane across the car park via the existing vehicular access. No alterations are required to these access routes in order to accommodate the development. Other than emergencies such as a fault or operational failure, there will typically be two visits to service the ground based equipment cabinets each year.

9.11 The proposal does not therefore give rise to any public issues associated with access and so there is no requirement to incorporate any inclusive access arrangements into the design and layout of the development.

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10. HERITAGE STATEMENT

10.1 This section assesses the significance of any potential for impacts upon heritage assets. This assessment is informed by guidance within the National Planning Policy Framework (NPPF - March 2012) and best practice. The NPPF sets out in paragraph 128:

“In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary.”

The Heritage Assets

10.2 Wroxham Football Club has no heritage assets associated within its grounds. However, the site is within the Wroxham Conservation Area. It forms the southern boundary to the Conservation Area with the area to the west of the Club and Skinners Lane up to the River Bure included. To the east the boundary continues following the railway line north with the main part of the Conservation Area focused around the built-up area of the village to the north and east of the site. This is shown in the Wroxham Conservation Area Map at Appendix 7.

APPENDIX 7: WROXHAM CONSERVATION AREA MAP

10.3 The nearest listed heritage assets are found approximately 500m to the north of the site, principally further along Church Lane and St Mary’s Close Street. These are considered to be at such distance, and with intervening buildings/vegetation, that no meaningful intervisibility or impact upon setting would occur and the proposal would not raise any issue in respect of the understanding of these assets. It is therefore reasonable to assert that there is no opportunity for any impacts upon listed heritage assets and this heritage statement focuses upon the development of the proposed installation on the Conservation Area.

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The Setting and Significance of the Heritage Asset

10.4 A review of the Wroxham Conservation Area Character Appraisal shows there are no identified key views that intersect the Football Club. Nevertheless, the Football Club is identified as an opportunity for enhancement. The character appraisal notes:

‘While not making any special contribution to the character of the conservation area, the football ground is in a sensitive location which is important in long views of the conservation area from the south and for the setting of Bureside and Fairfields.”

10.5 The sites value therefore is as part of the setting of two nearby buildings of interest that occupy riverside locations to the west of the Football Club, namely Bureside and the Lodge, and Fairfields and long-distance views from the south. Their significance as buildings of interest is principally formed of their unusual architectural style, but also from their riverside setting with each having extensive gardens and boat houses that add to their value.

The Proposed Development

10.6 The development of the application proposal has been based firstly upon the need for telecommunications coverage to within this immediate geographical area, as set out elsewhere within this statement. An assessment of alternatives is included within the planning assessment at Section 12 of this statement, which addresses alternatives sites. Alternative locations were also considered within the Football Club and the selected site was chosen as the most preferable location based on trying to minimalise the impact upon the wider area and operational needs associated with ‘100% coverage’ of the installation. It was considered that a change in height of the central floodlight on the eastern side of the club would be less noticeable from outside the ground with views from the east limited by the railway. The proposal replacement structure is 20m tall to provide sufficient clearance above nearby trees to enable the coverage improvements required, while allowing existing floodlight levels to the football pitch to be maintained. A reduction in height would result in obstruction of the coverage by the trees thereby decreasing radio propagation along the railway, the target for coverage improvements.

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Relevant Policy

10.7 The National Planning Policy Framework identifies the policy context in paragraphs 131-139. Paragraph 137 specifically refers to looking for opportunities to enhance or better reveal the significance of heritage assets within their setting.

10.8 Paragraph 134 sets out that:

“Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.”

10.9 Policy 1 of the Broadland, Norwich and South Norfolk Joint Core Strategy (2014) states:

‘The built environment, heritage assets, and the wider historic environment will be conserved and enhanced through the protection of buildings and structures which contribute to their surroundings, the protection of their settings, the encouragement of high-quality maintenance and repair and the enhancement of public spaces.’

The Impact of the Development

10.10 The Football Club will remain predominantly open in nature and its importance to the setting of the Conservation Area is that this open character is maintained. Given the vegetation along Skinners Lane, as well as, the surrounding vegetation to the east of the site, there is limited intervisibility between the floodlights on the eastern side of the club and the buildings of interest to the west of the site. It is not thought that any views from the south will be impacted upon and the setting and significance of these buildings will see no meaningful impact from the limited increase in height arising from the proposed telecommunications installation.

10.11 The proposed equipment cabinets would have a negligible impact upon any heritage assets by virtue of their discreet form/location within the existing built form of the club.

10.12 The main potential for a heritage impact arising from the scheme is long views to the Wroxham Conservation Area. The setting of the Conservation Area and nearby buildings of interest would remain largely identical in respect of the

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telecommunication equipment given the proposal envisages swapping out an existing structure. The new telecommunications structure will also appear broadly similar to that currently in place with an increase in height of only 2.5m.

10.13 In addition, the value to the setting to the Conservation Area from the Football Club is defined by its open nature. The proposed development would not materially change this such that the setting could no longer be described as ‘open’ in its form over the current Football Club and its surrounds. It is therefore apparent that the open character that forms the setting to the Conservation Area would remain in place and the proposal would safeguard the character of the setting to the Conservation Area and nearby buildings of interest.

10.14 Given that any perceived impact to heritage assets from the proposal can only be limited to the setting of the Conservation Area and buildings of interest within it, and taking account of the above assessment of this setting, any harm can only possibly be interpreted as a negligible degree of less than substantial harm.

10.15 The public benefits of the scheme are material to the assessment of any impact upon a heritage asset in accordance with the NPPF. The proposal brings readily acknowledged public benefits under government policy and guidance in the form of improved 2G, 3G and 4G telecommunications coverage for EE customers in the area, set out in more detail within Section 12 and supporting submission that form part of the planning application.

10.16 These benefits readily outweigh any extremely limited potential for impact upon heritage assets. The scheme does not have any archaeological implications given its minimal extent and need for foundations.

Conclusion

10.17 This heritage section demonstrates the significance of any heritage assets that could be affected by the proposal and goes on to demonstrate that the proposed development siting and form have been carefully selected to minimise any impact.

10.18 This impact is considered so minimal so as to not result in any material impact. However, if considered to present harm by the decision maker this statement makes clear that this can should be interpreted as a negligible degree of ‘less than substantial’ in its nature and when weighed against the public benefits offered by

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telecommunications infrastructure in the locality the scheme would adequately address heritage issues.

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11. LANDSCAPE ASSESSMENT

11.1 The Local Validation List (February 2009) for Broadland District Council identifies that a landscape assessment will be required for all operational development, but that the level of detail will be commensurate with the proposed development. The site is located near the boundary of the Broads and therefore, it is considered appropriate to include a Landscape Assessment to support the application.

11.2 The site and surrounding uses, landscaping, materials and views are set out in the site description and details about the proposal set out in Sections 4 and 6 of this Statement. The topography of the site and immediate surrounds is largely flat, with land rising to the south away from the Broads.

11.3 Policy EN2 Landscape sets out that proposals should have regard to the Landscape Character Assessment SPD and protect and enhance landscape character. The Broadland District Landscape Character Assessment identifies the application site and its surrounds as within Character Typology F1: Wroxham to Ranworth. This character assessment identifies the following visual character:

 Wooded slopes of the lower reaches of the River Bure, land gently descends toward the Broads;

 Landuse strongly influence by agriculture;

 Enclosed views and strong wooded horizons;

 Gradual transition between farmland and woodland;

 Settlements are generally linear with scattered isolated farmsteads;

 Wroxham is seen an ‘exception’ where transport routes and the nucleated settlement pattern have outweighed the historic core; and

 Complex road networks.

11.4 The following inherent landscape sensitivities have been identified:

• Mosaic of arable fields, pockets of pasture, woodland and parkland, providing a diverse and interesting landscape character;

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• Mature landscape structure including substantial blocks and belts of woodland, copses of mature trees and intact hedgerows, providing a robust visual mosaic;

• Landscape setting of historic houses, halls and churches;

• Architectural and landscape features of historic halls, including scenic parkland landscapes rich in idyllic components such as rides and parkland trees;

• Landscape setting of historic villages;

• Nucleated medieval market towns with a strong historic core;

• Distinctive close wooded horizons;

• Rich historic character and a strong sense of place; and,

• Characteristic views across the farmland to landmark churches, often isolated and amid woodland.

11.5 Notably the Landscape Planning Guidelines state that development proposals should:

‘Seek to ensure the sensitive location of development involving further tall structures (such as steel pylons and telecommunication masts) in relation to prominent skyline locations both within the character area and within adjacent character areas.’

11.6 The Football Club grounds can be described as part of the setting of the built-up area of Wroxham and is perceived in the context of nearby rail line and countryside to the south from most vantages. The Football Club is defined by the existing sporting infrastructure which is emphasised by the existing floodlights, which define the settled and non-agricultural nature of the use of the site from relative distance. Notably the benefits of this proposal include not introducing any further tall structures, with only a small increase to an existing tall structure proposed.

11.7 Further afield to the south and west, the area adopts the ‘key characteristics’ set out above and vantages across to the Football Club are limited by the wooded areas and flat topography leading toward the Broads. To the east and north built form

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including the railway screens and views and ensures that any effect from the development will be limited.

11.8 It is concluded that the character for the site and its immediate surrounds is as open recreational uses evidently associated with the built-edge of Wroxham. They are therefore clearly read as associated with, but differentiated from the wider characteristics of landscape in the area. Therefore, it is considered that an increase in height of one floodlight column will have minimal impact on views to and from Wroxham

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12. PLANNING ASSESSMENT 12.1 This section outlines the planning matters that are considered to be important to the determination of the application. Considerations are addressed in turn and explained in the context of the relevant planning policy. In order to demonstrate that the site meets the requirements of national and local policies the following matters are considered:

 A technical consideration of the proposal and the need for telecommunications equipment in the proposed location (‘100% coverage project’);

 Details of the search for alternative sites, including the possibility of mast sharing, use of existing buildings or other structures and the upgrade of existing installations;

 Compliance with International Commission on Non-Ionizing Radiation Protection (ICNIRP);

 Whether the appearance of the telecommunication equipment would have a harmful impact on the visual amenities of the surrounding area; and,

 Whether the proposal would have an acceptable impact on the Conservation Area.

 The public benefits of the scheme

A technical consideration of the proposal and the need for telecommunications equipment in the proposed location

12.2 This application is driven by the requirement of the applicant to improve network coverage and capacity in the immediate geographic area surrounding the proposal site, namely the Great Eastern Mainline railway to the east of the site. The scheme will also improve coverage to the built-up area of Wroxham village.

12.3 The technical requirement for the site is dictated by specific constraints affecting railway sites, this being the linear nature of the rail tracks and their general built form, using deep cuttings and high embankments, containing tunnels and generally being heavily screened by mature vegetation. This manifests itself in ‘not spots’ along railway lines where the existing telecommunications network is unable to specifically serve parts of the rail track. This can only be resolved by locating

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telecoms installations on sites that are able to provide uninterrupted coverage in both directions along a railway line. A site therefore needs to be in proximity to the ‘not spot’ and must be able fill this gap in coverage and be able to overcome the barriers that are leading to the area of limited coverage at this location.

12.4 Supporting technical information provided at Appendix 8 shows the current radio coverage along the railway line near Wroxham. A key to explain the colour coding system and the varying levels of radio coverage to be provided is included. The key shows the strength of the network at various locations along the railway with the most dense and desirable form of coverage marked in green. In contrast, the areas with least coverage, other than no coverage at all, are marked in black. In reality, those areas marked in black will not be served by 4G and are only likely to have sufficient strength to provide very limited use of a mobile with users likely to experience breaks in any services.

APPENDIX 8 – RADIO COVERAGE PLOTS

12.5 In the case of Wroxham this gap in coverage can be clearly explained by the landform around the railway line. The extract over page from the 50k (scale) ordnance survey map demonstrates that both to the north and the south of the Football Club the railway line is in a cutting. Cuttings are marked by black triangles, either surrounded by a solid line facing toward the track, when the railway line is below ground level, or with black triangles facing away from the track where the railway line is above ground level.

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Wroxham FC

Extract from 50k ordnance survey of Wroxham

12.6 As can be seen from the extract above, although the general topography of the wider area is relatively flat, the rail track to the south of Wroxham sits within a cutting and this alongside the mature vegetation that lines the embankments creates a ‘not spot’ for radio coverage. The photograph below taken from Castle Street to the north that crosses the railway line emphasises these issues.

Photo from Castle Street looking South.

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12.7 The proposal will provide new 4G coverage to the railway for EE customers and will address this through improved capacity and throughput. This improved telecommunication coverage will contribute to the aims of the NPPF through sustainable economic development.

12.8 The scale of the installation at 20m has been carefully selected between the radio planners, Pegasus Group and Shared Access as the optimum height to deliver the required coverage whilst minimising the visual impact upon the surrounding area. The height is not greater than required given the surrounding trees and topography and the specific area to which it is targeted.

Details of the search for alternative sites, including the possibility of mast sharing, use of existing buildings or other structures and the upgrade of existing installations;

12.9 It is acknowledged by the applicant that new telecommunications facilities can be installed in a variety of places, using a variety of construction techniques. This must be balanced with the specific geographic requirements of the EE railway project. The parameters of the project mean that the ‘cell search’ area, the area where a telecoms installation could technically serve the railway, is limited. The number of sites and locations that could provide coverage and capacity along a railway line is influenced by specific constraints that obstruct the efficient operation of electronic communications network.

Cell Search Area

12.10 The optimal ‘cell search’ area is shown on the Alternative Sites Map in Appendix 9. As shown on this plan due to the technical constraints of ‘not spots’ described above this ‘cell search’ area is focused on the key location along the track where coverage is lacking. Any installation will need to be in very close proximity to the railway in order to provide the required coverage at this specific location. Telecoms installations are normally able to provide coverage over a relatively wide area, between 500m and above in radius from any given installation. However, due to the specific issues affecting railway line coverage the area where a newly deployed site could cover the ‘not spot’ is extremely limited. The ‘cell search’ area reflects these limitations.

APPENDIX 9 – ALTERNATIVE SITES PLAN

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Alternative Sites

12.11 In order to show how each of these alternative possibilities have been considered and discounted, the following categories are used:

 Possibility of mast sharing and upgrade of existing masts;

 Use of existing buildings or other structures; and

 Other new installations.

Site Search Methodology

12.12 Following the identification of a ‘not spot’, MBNL radio planners undertake a desktop analysis to identify the best way of meeting the coverage requirement.

12.13 The desktop search identifies other operators’ existing telecommunications installations. This interrogation of databases ensures any mast-sharing opportunities are identified and maximised where possible. Where available, Local Planning Authority mast registers are also reviewed. Broadland District Council does not hold such a register.

12.14 The radio planner defines a cell search area as described above, which is then issued to an acquisition agent who undertakes a detailed ground search with the radio planner to identify suitable options. This could be existing buildings or masts, as well as, greenfield structures. In this case, the target area encompasses the immediate area surrounding track at Wroxham.

12.15 The acquisition agent will obtain site-specific details to identify those sites that are viable options. The possible options are short-listed according to those that combine location within the search area; a willing landlord with acceptable commercial terms; adherence to planning and environmental policy; and other site- specific issues such as access to a suitable power supply. These options are then returned to the radio planners for a computer modelling assessment, taking into account the ground height, potential available antenna height and surrounding obstructions such as trees, buildings, cuttings and tunnels.

12.16 A site survey is conducted to provide a full structural analysis of the site including confirming power routes and how the site will be linked into the network. Terms

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with the landlord are then finalised, detailed plans prepared and the application progressed to submission.

12.17 The above methodology outlines the long-term procurement process involved in progressing new telecommunications sites. A number of important key factors must align before any site is progressed making the prospects of finding sites difficult and often long-term.

12.18 The following provides an explanation of the lengths the applicant has explored with regard to site selection and alternative sites. The scope of the applicant’s assessment has considered the surrounding designations as well as existing masts and other buildings in the surrounds.

Possibility for Mast Sharing and Upgrade of Existing Mast

12.19 The nearest existing installation shown is the Network Rail mast to the south of the site. This would not be able to be shared as Network Rail will not permit the use of their existing sites that are trackside due to their very stringent health and safety regulations.

12.20 The current Vodafone/O2 installation at Broadland Funeral services is due to be replaced with the site at Village Hall. However, in order for either the existing or new site to provide even the most basic level of coverage an increase in height to circa 25m would be required and the structure swapped out for one of a much larger diameter, with an increased footprint to allow both Mobile Network Operators (CTIL & MBNL) to technically share the site. This would have a significant detrimental impact on the Wroxham Conservation Area and nearby residential properties being located within the built-up area of the village. It is noted that the Council’s Conservation Officer has already objected to the revised 20m installation at the Village Hall.

12.21 There are therefore no existing alternative masts or telecoms installation that would form a viable alternative.

Use of Existing Buildings and Other Structures and other new facilities

12.22 MBNL have undertaken an alternative site search several times without success for both buildings and other structures.

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Other new installations

12.23 Notwithstanding the NPPFs preference for the use of existing structure over greenfield sites, the following sites have been considered and dismissed.

Site NGR Site Type Reason for dismissing This location has limited screening and so would be very visible from nearby residential properties and therefore considered likely to have an unacceptable impact on residential amenity. Further, the Easting: Anglian Radio Planner has advised that from 630080 Water site, New a technical point of view this site Northing: Keys Drive, Installation would be likely to provide a poor 316880 Wroxham level of coverage. As such, and being a new greenfield structure, it was discounted in terms of being an inferior option from both a planning policy and technical perspective.

This location while relatively close to the railway has residential properties either side and is located too far from the required coverage area. As such, Wroxham Easting; it was discounted from a technical Library, 630020, New basis noting the likely impact of any Norwich Rd, Northing: Installation installation at this location could be Norwich 318000 NR12 8R problematic in policy terms specifically a new vertical structure within the Conservation Area.

Negative feedback from community during a prior approval application saw the application withdrawn. The Land off Easting: LPA expressed their view that it Skinners 629661, New would be favourable from a visual Lane, Northing: Installation impact perspective to swap an Wroxham, 316790 existing structure to prevent a NR12 8SL proliferation of structures of this nature in the area.

Compliance with International Commission on Non-Ionizing Radiation Protection (ICNIRP)

12.24 The ICNIRP certificate provided at Appendix 4 demonstrates that the proposal fully meets International Commission guidelines for public exposure.

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12.25 ICNIRP compliance is required under NPPF paragraph 45 (bullet 2). Shared Access has self-certified that the proposed telecommunications installation is fully compliant with Government adopted ICNIRP Guidelines.

12.26 Paragraph 46 of the NPPF states that Local Planning Authorities should not determine an application on health grounds if the proposal meets International Commission guidelines for public exposure.

Whether the Height and Form of the Telecommunication Equipment would have a Harmful Impact on the Visual Amenities of the Surrounding Area

12.27 The installation has been arranged to provide the requisite signal coverage requirements in the most discreet form possible. The monopole is the minimum height necessary to allow for the coverage required to service the railway and maintain floodlighting levels at Wroxham FC. The mast will replace and existing structure and be seen in the context of the 5no. other floodlighting structures. The equipment cabinets will be placed adjacent to the clubhouse and will not be able to be seen from outside the Football Club. The proposal would therefore appear appropriate to this environment.

12.28 It is acknowledged that there will be views of the site from the north. However, replacing the existing floodlight, as well as, the chosen location of the scheme mean that the proposal will have a limited impact upon the character and appearance of the Football Club and surrounding area.

12.29 As set out in Section 11, the impact of the development on the wider landscape is considered to be minimal and screened from wider views and this will also protect the setting of the Broads. Overall, the development is considered in accordance with Core Strategy Policy 2, and Development Management Policies GC4 and EN2. The proposed installation will not affect the use of the sporting facilities in line with the guidance of Sport England.

Whether the proposal would have an acceptable impact on the Conservation Area

12.30 As set out in Section 9 of this statement, the proposal would have a negligible impact upon heritage assets. While the Football Club may have limited value, the scheme would not have any material impact upon the Wroxham Conservation Area, due to not affecting any key views of the Conservation Area and not being notable

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in any views of importance. The proposal is considered in accordance with the NPPF and Core Strategy Policy 1 and will have no impact on nearby heritage assets.

The public benefits of the scheme

12.31 In accordance with paragraph 134 of the NPPF the public benefits of the scheme are set out on more detail in the supporting enclosure ‘The Requirements and Benefits of Mobile Connectivity’ that forms part of this application. Nevertheless, these are briefly described below

12.32 Reflecting on the wider benefits of the proposal these can be broken down into each of the aspects of sustainable development as set in the NPPF:

 Economic Benefits – modern communications in all of their different and emerging forms, including mobile communications, help maintain high and stable levels of economic growth and employment. The contribution to the national economy is also significant where all businesses, from large to small, benefit from modern communications. This proposal will improve the ability of local businesses to operate and compete effectively through access to modern communications thereby helping to maintain and increase local employment opportunities.

 Social Benefits - modern communications, including mobile communications, aid social progress, which recognises the needs of everyone. Connecting to the Internet via a mobile device allows people to access a wide range of central and local government services. Mobile devices enable flexible forms of working that provide opportunities to working parents or carers and help them achieve a better work life balance with both family and community benefits. By providing means of communication that improve convenience and enhance personal safety and security. This is especially important to vulnerable groups who may otherwise feel unable to participate in certain activities.

 Environmental Benefits - modern communications, including mobile communications, provide effective protection of the environment by helping reduce the need to travel by enabling modern working practices such as greater home working. Such practices alleviate the pressure for new commercial development such as offices, through more efficient and flexible use of existing accommodation. For the same reasons, modern

JUNE 2018 | MP | P18-0879 Page | 42

SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

communications, including mobile communications, help ensure the prudent use of natural resources.

JUNE 2018 | MP | P18-0879 Page | 43

SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

13. CONCLUSIONS

13.1 This Planning, Heritage, Design and Access Statement has explained the proposed development, detailed applicable national and local planning policy and guidance and justified the proposal against these parameters.

13.2 The proposal constitutes the replacement of an existing 17.5 floodlight pole with the installation of a 20m monopole to provide telecommunications equipment designed to improve the 2G, 3G and 4G network coverage and capacity specifically to the Great Eastern Mainline to the east of the site. The site will also provide further coverage and capacity to the built-up area of Wroxham. The scheme is required due to existing ‘not spot’ on this stretch of the railway line and the proposal will provide competitive coverage and network solutions for EE. The development has been designed with regard to relevant national and local planning policy as well as codes of best practice for communications networks.

13.3 In accordance with paragraph 45 of the NPPF evidence that the possibility of erecting antennas on an existing buildings, masts or other structures has been provided. Further, the applicant has also undertaken pre-application consultation and has demonstrated that the proposal fully meets International Commission guidelines for public exposure.

13.4 Paragraph 46 of the NPPF states that LPAs should not question the need for new installations and the proposal complies with all relevant policies in the NPPF. The proposal includes numerous demonstrable benefits and would contribute towards the Government’s long-standing and well-documented commitment to maintaining and improving communications networks across all the UK. This includes the provision of telecommunications antenna such as those proposed which will provide improved coverage in an area that is demonstrably deficient in this service. This is set out in more detail in the supporting enclosure ‘The Benefits of Mobile Connectivity’.

13.5 Improved telecommunications links within the area will improve the attractiveness of Wroxham and its immediate surrounds to prospective residents and business occupiers. Further, the capital funding provided to Wroxham FC is a material benefit of the scheme. These are demonstrable material social and economic benefits of the proposal which should weigh in favour of the proposed installation.

JUNE 2018 | MP | P18-0879 Page | 44

SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

13.6 The equipment cabinets will be screened from public view by virtue of their limited height and surrounding screening. The installation has been designed so as to ensure that the visual prominence of the structure has been substantially minimised. These factors combine to result in a proposal that will have a limited impact on the visual amenities of the area. Paragraph 43 of the NPPF recommends that where new sites are required, equipment should be sympathetically designed and camouflaged where appropriate, the siting of this installation replacing an existing floodlight column is entirely appropriate.

13.7 Should the Council perceive that any harm is caused to the designated Conservation Area, it has been demonstrated that this harm could only be read as a negligible degree of less than substantial harm that is clearly outweighed by the significant public benefits clarified within this statement and The Benefits of Mobile Connectivity document enclosed as part of this submission.

13.8 The NPPF confirms a presumption in favour of sustainable development and that social, economic and environmental issues must be balanced and integrated, at the same time, by the decision-taker when determining planning applications. Section 38(6) of the Act requires that decisions should be assessed against the Development Plan unless material considerations suggest otherwise.

13.9 In this regard the application not only meets the ambitions of the NPPF in improving telecommunications networks but also accords with policies of the Development Plan. Advanced, high quality communications infrastructure is essential for sustainable economic growth and the application scheme will provide this in a location that is deficient in coverage. These benefits of the scheme should weigh heavily in its favour and outweigh any potential perceived harm to the local area.

JUNE 2018 | MP | P18-0879 Page | 45

SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

APPENDIX 1

SITE LOCATION PLAN

JUNE 2018 | MP | P18-0879

N

MP 7.75

SKINNERS LANE

242 35 ALL SCALES AS SHOWN WHEN PRINTED AT A3

FOOTBALL GROUND

250

256 263

16 CONSTRUCTION ACCESS AREA ALSO INCLUDES SITE LOCATION

SITE ACCESS

PUBLIC HIGHWAY

POWER ROUTE (INDICATIVE) 0cm 1cm 2cm 3cm 4cm 5cm 6cm 7cm 8cm 9cm 10cm

SITE ADDRESS WROXHAM FC TRAFFORD PARK SKINNERS LANE, WROXHAM NORWICH, NR12 8SJ

DEPENDENCIES YES NO TITLE DOES THIS SITE DESIGN CONFORM TO CHERRY PICKER SURVEY NO STANDARD ICNIRP DESIGN GUIDELINES X. STAT SEARCH YES WROXHAM FC TRIAL DIG YES IF NO DETAIL THE EXCEPTIONS BELOW : GEOTECH YES 1. GDC YES BOLT PULL-OUT TEST NO 2. A FIRST ISSUE TEL 16.05.18 STRUCTRUAL CALCULATIONS NO 3. REV DESCRIPTION BY DATE BUILDING REGULATIONS NO HARLEQUIN GROUP ELECTRICAL LOAD TEST YES CROWN COPYRIGHT RESERVED. DRAWN TEL CHECKED DP APPROVED D.I MAPS REPRODUCED WITH THE PERMISSION OF THE SCALE AS SHOWN SITE LOCATION MAPS INNOVATION CENTRE REC SERVICE ALTERATION NO CONTROLLER OF HM's STATIONERY OFFICE. WHEN PRINTED AT A3 DATE DATE DATE MAIDSTONE ROAD 16.05.18 16.05.18 16.05.18 COMMS SERVICE ALTERATION NO LOCATION PLAN - Digital Mapping Solutions from Dotted eyes. CHATHAM ASBESTOS SURVEY YES © Crown Copyright 2017. All rights reserved Licence number 100019918 ALL DIMENSIONS IN mm UNLESS OTHERWISE STATED. OPERATOR REF SITE CODE OPT No DRG TYPE DRG No REV KENT, ME5 9FD ANTENNA TESTING YES SITE BLOCK PLAN - Digital Mapping Solutions from Promap. THIS DRAWING TO BE READ IN CONJUNCTION WITH ALL SCALES AS SHOWN WHEN PRINTED AT A3 TEL: +44 (0) 1634 683635 COOLING CALCULATIONS NO © Crown Copyright 2017. All rights reserved Serial number 100020449 OTHER RELEVANT DRAWINGS. 76772 1514274 1 GA 100 A SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

APPENDIX 2

TELECOMMUNICATIONS INSTALLATIONS SITE PLAN

JUNE 2018 | MP | P18-0879

SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

APPENDIX 3

EXISTING AND PROPOSED LUX LEVELS

JUNE 2018 | MP | P18-0879

88 POINT ILLUMINATION REPORT FOR FLOODLIGHTING SURVEY

CLUB NAME: Wroxham Football Club TEST DATE: 20-Jan-16 TIME: 5-30 PM

AVERAGE LUX LEVEL: 126 LUX MAXIMUM LUX LEVEL: 190 LUX MINIMUM LUX LEVEL: 51 LUX UNIFORMITY FACTORS MIN / MAX: 0.27 MIN / AVG: 0.40 SWITCHING POSITION

51 125 106 98 94 97 138 62

142 178 131 133 110 132 171 160

127 154 118 144 117 133 136 105

106 155 121 126 121 128 126 103

118 163 133 110 107 129 142 115

142 190 136 109 103 133 157 119

127 166 143 112 104 122 157 119

110 150 143 132 116 120 133 100

116 155 159 148 129 98 127 112

157 180 133 134 132 110 161 145

52 146 108 91 93 100 138 51

Highlights Floodlighting Ltd Floodlighting Equipment 5 x 18m Masts (M1,M2,M3,M4,M6) 1 x 15m Masts (M5) Each carrying the following Floodlights :- M1,M3,M4,M6..... 4 x MHN-LA2000W M2,M5..... 2 x MHN-LA2000W

Lamps (Philips) MVF024 1xMHN-LA2000W/400V/842 MB (220 000 INITIAL Lm)

Illuminance Levels Maintained - (100hrs) E.i.ave = 127Lux Uniformity Emin/Eave = 0.61 Maximum Lux = 192Lux

Grid values in Lux(initial). Grid interval = 5m. Contour values in Lux (initial). Contours: 5, 15, 25, 50 Lux.

Maintenance Factor = 0.80

Wroxham FC

www.halliday-lighting.co.uk

Proposed floodlighting

JS

Wroxham FC 1:750 @ A3

HLS/Wroxham FC Proposal SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

APPENDIX 4

ICNIRP CERTIFICATE

JUNE 2018 | MP | P18-0879

Select:

Select:

Cell No:

Cell Name:

Address:

Drawing Number(s):

Date:

Completed by: For and on behalf of:

Position:

Company GSDD Version Used for 4.0 assessment 5.0 6.0

Select Project Type:

MBNL Cell ID

Completed by: email address Completed by: subcontractor ICNIRP Restrictions? No restrictions MBNL only (ie not multi- operator) Restricted Carriers Restricted tilt

Please confirm drawing Yes has been completed No

Was a FIXIT raised for Yes Have you visited site as Yes Date of site visit (if applic) this assessment No part of this assessment? No Comments Please enter any relevant comments relating to ICNIRP compliancy

Powered by TCPDF (www.tcpdf.org) SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

APPENDIX 5

PRE-CONSULTATION LETTER TO EXISTING RESIDENTS

JUNE 2018 | MP | P18-0879

RC/P18-0879

17 May 2018

OWNER/OCCUPIER «Address_1» «Address_2» «Address_3» «Address_4» «Address_5» «Address_6»

Dear Sir/Madam,

Public Consultation for Proposed Telecommunications Structure at Wroxham FC, Trafford Park, Skinner Lane, Norwich, NR12 8SJ

Pegasus Group are working as Planning Consultants in partnership with Shared Access, who are preparing a planning application for an integrated telecommunications and floodlight structure to the Wroxham Football Club, Trafford Park, Skinner Lane, Norwich, NR12 8SJ. The existing lighting to the football ground will be maintained and telecommunications equipment integrated that will improve network coverage in the local area for EE customers. EE also provides network coverage for the following Mobile Virtual Network Operators: 1pMobile, Airwave Smart Mobile, Anywhere Sim, Asda Mobile, Auracall Travel Talk, Axis Telecom, BT, CTExcelbiz, Delight Mobile, Digital Phone, Econet Mobile, Go Mobile, Jump, HP Mobile Connect, Kingdom Mobile, Krisant Telecom, Lomo Mobile, Matrix Cellular, Meem Mobile, MTel, Natterbox, NordTelekom, Now PAYG, Pebble Mobile Network, Piranha Mobile Ltd, Plusnet Mobile, Talk Home Mobile, The Phone Co-op, U2i Mobile, Telecom Plus, Vectone Mobile, Virgin Mobile, Food Mobile, and White Calling.

A Site Location Plan is included with this letter to show where the equipment will be sited.

This letter has been prepared to provide local residents with some initial information about the proposal and to offer the opportunity to make comments or suggestions about the scheme during the design and development stage, before any planning application is submitted to the Council.

Shared Access has been working with The Trustees of Wroxham Football Club to propose a scheme which would involve one of the existing floodlighting columns to the football ground being replaced with a structure that will maintain the existing floodlighting and incorporate a telecommunications antenna. The existing floodlights are 17.5m tall and the proposed mast will be a maximum height of 20m.

Shared Access is a property company that specialise in developing telecommunications infrastructure. The company operates in the United Kingdom and Ireland, where they have built, acquired, own and manage approximately 500 sites. Shared Access are the exclusive managing agent for the Office of Public Works (Irish Government) and have exclusive partnerships with national governing bodies, including the Football Association and the Lawn Tennis Association, to provide investment into grassroots sport and facilities.

First Floor | South Wing | Equinox North | Great Park Road | Almondsbury | Bristol | BS32 4QL T 01454 625945 | F 01454 618074 | W www.pegasusgroup.co.uk

Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | Liverpool | London | Manchester Pegasus Group is a trading name of Pegasus Planning Group Limited (07277000) registered in England and Wales Registered Office: Pegasus House, Querns Business Centre, Whitworth Road, Cirencester, Gloucestershire, GL7 1RT

Page | 1

The telecoms structure will deliver next generation 4G communications infrastructure to the area, as well as improve coverage for other existing technologies. The 4G network will provide exceptionally fast internet to local residents and businesses. As you may be aware, the Government promotes new telecommunications development, as it contributes to improving communications and encouraging economic growth.

The proposal will be fully compliant with standards set down by the International Commission on Non-Ionizing Radiation Protection (ICNIRP). ICNIRP is an independent scientific organisation whose aim is to provide guidance and advice on the health implications of telecommunications development.

I look forward to receiving any comments you may have. Please endeavour to provide your suggestions within two weeks of the date of this letter, to ensure your input is taken into account during the design stage of the proposal. In the meantime, if you require any additional information in respect of the above proposal, please do not hesitate to contact me, either by the address on this letter, by email (below) or by telephone 01454 625 945. We will respond to any comments, queries, or concerns received at the end of the consultation period, on the 31st May.

Yours faithfully

Rachel Chen Planning Assistant Email: [email protected]

Enc

Page | 2

SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

APPENDIX 6

SCHOOL CONSULTATION LETTER

JUNE 2018 | MP | P18-0879

RC/P18-0879

17 May 2018

Ms Rebecca Quinn Headteacher St John’s Community Primary School and Nursery Horning Road Hoveton Norwich NR12 8NX

Dear Ms Quinn

Public Consultation for Proposed Telecommunications Structure at Wroxham FC, Trafford Park, Skinner Lane, Norwich, NR12 8SJ

Pegasus Group are working as Planning Consultants in partnership with Shared Access, who are preparing a planning application for an integrated telecommunications and floodlight structure to the Wroxham Football Club, Trafford Park, Skinner Lane, Norwich, NR12 8SJ. The existing lighting to the football ground will be maintained and telecommunications equipment integrated that will improve network coverage in the local area for EE customers. EE also provides network coverage for the following Mobile Virtual Network Operators: 1pMobile, Airwave Smart Mobile, Anywhere Sim, Asda Mobile, Auracall Travel Talk, Axis Telecom, BT, CTExcelbiz, Delight Mobile, Digital Phone, Econet Mobile, Go Mobile, Jump, HP Mobile Connect, Kingdom Mobile, Krisant Telecom, Lomo Mobile, Matrix Cellular, Meem Mobile, MTel, Natterbox, NordTelekom, Now PAYG, Pebble Mobile Network, Piranha Mobile Ltd, Plusnet Mobile, Talk Home Mobile, The Phone Co-op, U2i Mobile, Telecom Plus, Vectone Mobile, Virgin Mobile, Food Mobile, and White Calling.

A Site Location Plan is included with this letter to show where the equipment will be sited.

Shared Access has been working with The Trustees of Wroxham Football Club to propose a scheme which would involve one of the existing floodlighting columns to the football ground being replaced with a structure that will maintain the existing floodlighting and incorporate a telecommunications antenna. The existing floodlights are 17.5m tall and the proposed mast will be a maximum height of 20m.

Shared Access is a property company that specialise in developing telecommunications infrastructure. The company operates in the United Kingdom and Ireland, where they have built, acquired, own and manage approximately 500 sites. Shared Access are the exclusive managing agent for the Office of Public Works (Irish Government) and have exclusive partnerships with national governing bodies, including the Football Association and the Lawn Tennis Association, to provide investment into grassroots sport and facilities.

The telecoms structure will deliver next generation 4G communications infrastructure to the area, as well as improve coverage for other existing technologies. The 4G network will provide exceptionally fast internet to local residents and businesses. As you may be

First Floor | South Wing | Equinox North | Great Park Road | Almondsbury | Bristol | BS32 4QL T 01454 625945 | F 01454 618074 | W www.pegasusgroup.co.uk

Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | Liverpool | London | Manchester Pegasus Group is a trading name of Pegasus Planning Group Limited (07277000) registered in England and Wales Registered Office: Pegasus House, Querns Business Centre, Whitworth Road, Cirencester, Gloucestershire, GL7 1RT

Page | 1

aware, the Government promotes new telecommunications development, as it contributes to improving communications and encouraging economic growth.

The proposal will be fully compliant with standards set down by the International Commission on Non-Ionizing Radiation Protection (ICNIRP). ICNIRP is an independent scientific organisation whose aim is to provide guidance and advice on the health implications of telecommunications development.

Government Guidance states that it is good practice for mobile telecommunications operators to notify local educational institutions of our proposal to install a telecommunication site where it is near to a school.

We would be grateful if you could consider this letter and the accompanying information about the proposals and let us know your views no later than four weeks from the date of this letter. Any comments received from you within this period will be considered by us and will be submitted with our application to the Council.

In the meantime, if you require any additional information in respect of the above proposal, please do not hesitate to contact me, either by the address on this letter, by email (below) or by telephone 01454 625 945.

Yours sincerely

Rachel Chen Planning Assistant Email: [email protected]

Enc

Page | 2

SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

APPENDIX 7

WROXHAM CONSERVATION AREA MAP

JUNE 2018 | MP | P18-0879

y 7,. + < u a \J Cfl (I 0 ^ .1 0 s

0 §ga. ? s ?^s 8-^§ ItsI? |SS S3s^s 3 s £ is, "c|sls 8u c S Q. •o li- 51'5 ©.co

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1 ni T l^l! IBS IHI 1/1 ^ ^ SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

APPENDIX 8

RADIO COVERAGE PLOTS

JUNE 2018 | MP | P18-0879

SHARED ACCESS AND MBNL WROXHAM FOOTBALL CLUB, TRAFFORD PARK, SKINNERS LANE PLANNING STATEMENT

APPENDIX 9

ALTERNATIVE SITE PLAN

JUNE 2018 | MP | P18-0879

pegasusgroup.co.uk

First Floor, South Wing, Equinox North,Great Park Road, Almondsbury, Bristol, BS32 4QL

E [email protected] T 01454 625 945

COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Group. Crown copyright. All rights reserved, Licence number 100042093