Costing a telecommunications compliance declaration for a mast

The ICNIRP declaration itself costs almost nothing. It is produced by the operator's own radio engineering team as part of the design of the installation, and it confirms that the equipment and the installation are designed to be in full compliance with the public exposure guidelines issued by the International Commission on Non-Ionizing Radiation Protection. There is no third party certification requirement and no external fee. The expensive parts of a telecommunications application sit elsewhere: the alternative site assessment, the visual evidence on designated land, and the time spent finding a site at all.

That matters because applicants frequently budget for the declaration as though it were a technical report and then under-budget for the siting evidence, which is the material the authority can actually refuse on.

What the declaration confirms

The declaration is a statement of conformity with the ICNIRP guidelines for limiting exposure to electromagnetic fields. It covers the equipment specification and the installation as designed, including cumulative exposure where the site carries equipment from more than one operator.

Its legal effect is procedural. Where a prior approval or planning application for telecommunications development is accompanied by the declaration, national policy is clear that the authority should not question the need for the network or set health safeguards different from the ICNIRP guidelines. In other words, the declaration closes the health issue.

That is also its limit. The declaration says nothing about appearance, nothing about the choice of site, and nothing about heritage or visual effects, which is where the decision is actually made.

Who is competent to produce it

The operator. A declaration is signed on behalf of the electronic communications code operator by someone with the radio engineering knowledge to stand behind it, working from the antenna specification, the power levels, the downtilt and the exclusion zone calculation.

Councils expect a suitably qualified author and professional review is strongly advised, particularly on shared sites where cumulative exposure has to be assessed across operators. What councils do not do, and are not asked to do, is audit the calculation. Where a member of the public challenges the declaration at committee, the answer is national policy rather than a re-run of the modelling.

A Telecommunications Compliance document assembles the declaration alongside the other material the application needs, which is where the drafting effort actually belongs.

Siting and appearance as the reserved matters

Part 16 of Schedule 2 to the General Permitted Development Order grants permitted development rights to code operators, with prior approval required from the authority for the siting and appearance of defined installations such as ground based masts.

Those two words set the whole scope of the decision. The authority may consider where the mast goes and what it looks like. It may not consider whether the network needs it, and it may not impose health conditions beyond ICNIRP.

The limits in Part 16 were widened by amendments in 2022, covering mast heights, the strengthening of existing masts and equipment cabinets. The permitted heights differ between ordinary land and designated land, and they have changed more than once, so check the current consolidated Order rather than relying on a remembered figure.

Evidence of coverage need, and why it still matters

Coverage evidence still matters even though the authority cannot refuse on need, because the siting judgement depends on it. An officer deciding whether a mast could go 200 metres away, behind a tree belt, needs to understand why that position does not work, and a coverage plot showing the search ring and the shortfall is the only persuasive way to explain it.

The practical submission is short: a plan of the search area, the coverage or capacity deficiency being addressed, and the technical constraint that fixes the location within metres rather than hundreds of metres.

Alternative sites assessment

This is the document that wins or loses the application, and the one worth spending money on. National policy expects operators to use existing masts, buildings and other structures where possible, and to share sites where they can.

A credible assessment works through the options in order.

1. Sharing an existing mast within the search area, with the reason any shared site fails on coverage, structural capacity or landlord refusal.
2. Mounting on an existing tall structure, such as a building, pylon or floodlight column.
3. A new mast on a less sensitive site within the search area.
4. The proposed site, with the reasons the preceding options were discounted.

Each discounted option needs a reason an officer can test. "Not technically suitable" is not a reason. "The existing mast is 1.2 kilometres outside the search ring and would not resolve the in-building coverage deficiency in the area shown" is.

An illustrative example

This example is illustrative. An operator needs a site to address an in-building coverage gap in a village. The search ring covers open countryside on three sides and the village edge on the fourth, part of which lies within a conservation area.

Two existing structures are assessed. A church tower is discounted because the parish declines access. A floodlight column at the recreation ground is discounted on height, since the antennas would sit below the surrounding tree canopy.

The proposed site is a 20 metre monopole in a field corner behind a mature hedge, outside the conservation area, with a green finish. The application carries the ICNIRP declaration, a coverage plot, the alternative site assessment and photographs from four public viewpoints with the mast shown to scale.

The declaration took an afternoon. The alternative site assessment and the photographic work took three weeks, and they are what the officer's report discusses.

Designated land and the tighter limits

On land within a conservation area, National Park, National Landscape, World Heritage Site or the Broads, Part 16 applies more restrictive limits, and some development that would be permitted elsewhere requires a full application instead.

The evidence expectation rises with it. Where a mast is proposed in or affecting a designated area, expect to produce visual material of the standard a Townscape and Visual Impact Assessment would contain, and a Heritage Statement where a listed building or conservation area is affected. Those are the real cost lines on a sensitive site.

Where a full application is needed instead

Three situations take the proposal out of prior approval and into a planning application: the installation exceeds the Part 16 limits for the land in question, the rights have been withdrawn by an Article 4 direction, or the development falls outside the classes Part 16 covers.

The fee position differs between the two routes, and the determination period and appeal rights differ too. Our note on full application fees by floorspace and site area sets out how the national fee schedule works, and the figures are indexed, so check the current schedule before pricing a submission.

See PlanScope pricing for the free report, the per report price and the Professional tier used by agents producing these regularly.

This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.