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Documents for a telecoms mast under Part 16

7 min readBy PlanScope Editorial Team

The Order requires only a description, a location plan and the fee. Everything else you submit exists to make the chosen position and design defensible on siting and appearance.

The documents for a telecoms mast prior approval under Part 16 are short by the standards of a planning application, and they are short for a reason. The Order itself requires only a written description of the proposed development, a plan showing its location and the fee. Everything else you submit is there to answer the two matters the authority can actually decide: siting and appearance.

Consultants who submit a full suite of technical reports are wasting the client's money. Consultants who submit the statutory minimum and nothing else frequently lose on appearance, because the authority had no basis on which to find the proposal acceptable.

What prior approval under Part 16 tests

The permission comes from Part 16 of Schedule 2 to the General Permitted Development Order 2015. The application asks the authority to determine whether its prior approval is required for the siting and appearance of the development, and if so, to give or refuse that approval.

Two consequences shape the submission. The authority cannot consider need, health or commercial arrangements, so documents addressing those add nothing to the determination. And the authority can refuse on siting and appearance grounds alone, so the submission has to make the chosen position and design defensible against the alternatives.

Before anything else, confirm the proposal sits within the Part 16 limits for the land in question, which differ between unprotected land and article 2(3) land. Where it does not, the route is a full planning application and the document list changes completely. The 56-day determination period, after which development may proceed without approval, is dealt with at the end of this piece.

Site selection and alternatives evidence

This is the document that wins prior approvals. The authority is deciding whether this position is acceptable, and the honest answer to that depends on what else was available.

A site selection statement should set out the coverage or capacity objective in general terms, the search area, the candidate sites considered, and why each was discounted. Reasons that carry weight are physical and planning-based: no landlord agreement available, insufficient height to clear an obstruction, unacceptable visual effect on a listed building, no vehicular access for maintenance, or an existing structure unable to take the load.

Three points of discipline:

  • discount candidate sites on stated grounds rather than in a sentence each
  • include sites the community will raise, particularly the obvious industrial estate or the existing mast half a mile away, and explain the position on each
  • address mast sharing explicitly, because it will be raised and because the code of practice for wireless network development expects it to be considered

Avoid overstating the constraint. A statement claiming that no other site in the area could work, where a reader can see an industrial estate on the map, invites a refusal and an appeal that is harder than it needed to be.

Siting and appearance material

The drawings carry this part. The set should include a location plan, a site plan showing the compound and its boundary, elevations of the apparatus with dimensions, a section where ground levels vary, and details of the finish.

For appearance, the useful material is comparative. Show the proposed support design against the alternatives considered: a slimline monopole against a lattice tower, a shrouded headframe against exposed antennas, a dark grey finish against galvanised steel. Where the apparatus is on a building, show the parapet relationship and whether the antennas break the roofline.

Specify the finish rather than leaving it to a condition. A stated colour reference, a matt finish and a commitment to keep cabinets within the compound give the officer something to approve.

Photomontages from agreed viewpoints are worth the cost on any prominent site. Three or four views, taken from publicly accessible positions and including the nearest residential frontages, answer more objections than a paragraph of assessment.

The exposure compliance certificate

The application must be accompanied by a declaration that the equipment and installation will be designed to comply with the public exposure guidelines of the International Commission on Non-Ionizing Radiation Protection.

Submit it as a separate document, clearly titled, rather than as an appendix inside the statement. Officers need to find it quickly, and its absence is a straightforward ground for the authority to say the application is not valid.

The declaration is a self-certification by the operator. That is the position under government policy, and where it is provided the authority should not question the health aspects of the proposal. The supporting technical material and the standards engaged are described on the Telecommunications Compliance page.

Visual impact and designated areas

On article 2(3) land, and where a listed building or conservation area is affected, the appearance assessment has to do more work.

For a conservation area or the setting of a listed building, a short heritage appraisal identifying the asset, its significance and the effect of the apparatus is proportionate, and for a prominent position a full Heritage Statement is justified. The statutory duties in relation to listed buildings and conservation areas apply to the siting and appearance decision, which is why heritage material changes outcomes here even though the process is narrow. Where the setting of several assets or a wider townscape is engaged, a Townscape and Visual Impact Assessment is the right instrument.

In open countryside and National Landscapes the issue is landscape rather than townscape, and a landscape and visual appraisal with viewpoints agreed in advance is the equivalent document. Keep it proportionate to the apparatus, since a 20-metre monopole does not need the assessment a wind farm would.

Where trees are affected by the compound, the access track or the cable route, a tree survey to the relevant British Standard and a protection plan should be submitted. Mature trees adjacent to a proposed compound are a common and effective objection, and dealing with them in advance costs less than a refusal. For sites inside a conservation area the wider document expectations set out in which documents a conservation area application needs are a useful cross-check.

Access and compound details

Maintenance access is a siting matter, so show it. The submission should include the access route from the public highway, the surface treatment, any gate and its position, and the turning and parking provision for a maintenance vehicle.

Compound details matter more than consultants expect. A palisade fence in galvanised steel reads very differently from a timber acoustic fence or a low wall with planting, and in a village setting the fence will attract more comment than the mast. Show the fence type, height and finish, and show any proposed planting with species and sizes.

Note the position of cabinets, meter housings and any generator provision, since these are the elements that appear at eye level and get added later without consent if they are not shown at the outset.

Timescales and deemed approval

The determination period is 56 days from the date the application is received. If the authority does not notify the operator of its determination within that period, the development may proceed, subject to the conditions and limitations in Part 16 and to the development being carried out within the period the Order allows.

That timetable drives the submission strategy. Submit a complete set first time, because an invalid application restarts the clock and a request for further information mid-period eats it. And respond to consultation comments quickly rather than waiting for a draft refusal, since the officer has limited time to reconsider.

Keep a record of the submission date and the validation date, and diarise the expiry. Where the period passes without determination, confirm the position in writing with the authority before mobilising, because disputes about whether an application was valid are easier to resolve on paper than on site.

This is general guidance, not legal advice. The limits, conditions and procedural requirements of Part 16 have been amended more than once, so check the current text of the Order and the authority's own validation requirements before relying on this.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.

Frequently asked questions

What does the Order actually require to be submitted?

A written description of the proposed development, a plan indicating its proposed location, the fee, and a declaration of compliance with the public exposure guidelines of the International Commission on Non-Ionizing Radiation Protection. Anything beyond that is submitted to make the siting and appearance case, not because the Order demands it.

How much site selection evidence is needed?

Enough to show why this position was chosen over the realistic alternatives. State the coverage objective in general terms, the search area, each candidate site considered and the reason it was discounted on physical or planning grounds. Include the sites the community will raise, including any existing mast nearby.

Is a heritage statement needed for a mast?

Where a listed building, its setting or a conservation area is affected, yes, because the statutory heritage duties apply to the siting and appearance decision. A short appraisal identifying the asset, its significance and the effect is proportionate for most sites, with a fuller statement justified on prominent positions.

Why does the compound fence matter so much?

Because in a village or suburban setting it sits at eye level and attracts more comment than the mast itself. Show the fence type, height and finish, the cabinet positions and any planting with species and sizes, since elements not shown at the outset tend to be installed later without consent.

What happens if the council misses the 56 day deadline?

The development may proceed, subject to the conditions and limitations in Part 16 and to being carried out within the period the Order allows. Record the submission and validation dates, diarise the expiry, and confirm the position in writing with the authority before mobilising on site.

Sources and further reading

telecomspart 16prior approvaldocument bundlesite selection

This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.

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