Which Reports Do I Need

Evidence for a rural broadband mast on high ground

7 min readBy PlanScope Editorial Team

A hilltop mast is assessed on siting and appearance alone. The alternatives evidence, the photomontages and the access track details decide it inside the 56 day period.

A new broadband mast on high ground is usually a prior approval application rather than a full planning application, and the evidence you submit has to answer a narrow question very well. Part 16 of Schedule 2 to the General Permitted Development Order 2015 grants permitted development rights to electronic communications code operators, including ground-based masts up to stated heights, subject to prior approval of siting and appearance. The limits were raised by amendments in 2022, with lower limits applying on article 2(3) land, so read Part 16 as it stands before fixing the mast height.

Siting and appearance is the whole of the assessment. The authority cannot question whether the network is needed, cannot weigh one operator's commercial case against another's, and cannot determine health safeguards where the proposal meets the international exposure guidelines. What it can do is decide that this mast, in this position, on this skyline, looks wrong. On an exposed upland site that is a real risk, and the submission has to be built around it.

Prior approval under the telecommunications permitted development route

The application goes in on the prior approval form with the required notice and publicity, and the authority has 56 days to determine it. If it does not determine within that period, the development may proceed in accordance with the submitted details.

Do not treat the deadline as the plan. A mast built on a deemed approval with inadequate details invites an argument about whether what was built matches what was submitted, and that argument is expensive on a remote site with an access track already cut.

Three procedural points worth getting right. Serve the required notices on the landowner and any occupier. Provide the publicity the Order requires. And submit drawings that fix the position to a coordinate rather than a sketch, because a mast moved 20 metres up the slope is a different development.

What the authority may and may not consider

Matter Within scope Notes
Siting of the mast and cabinets Yes The core issue on a prominent site
External appearance, colour and finish Yes Including lattice against monopole and cabinet cladding
Landscape and visual effects Yes, as part of siting and appearance The main ground of refusal in open country
Need for the network or coverage No National policy tells authorities not to question the need
Competition between operators No Not a planning consideration
Health effects where exposure guidelines are met No A declaration of conformity answers the point
Highway access and construction traffic Partly Through siting, and through any separate consent for the track

Keep the submission inside the scope. A document that argues at length about coverage need wastes space the landscape case needed, and officers read the landscape section first on sites like these.

Landscape and visual assessment from a prominent site

High ground is where these applications are decided. A 25 metre lattice tower on a ridge is visible across a wide area, and in a National Landscape or National Park the statutory duty to have regard to the purposes of the designation applies to the decision.

A Landscape and Visual Impact Assessment following the recognised guidelines is the right document, scaled to the development. What it needs:

  • A study area defined by a zone of theoretical visibility rather than a guess
  • Viewpoints agreed with the authority in advance, including from public rights of way, settlements and any designated landscape
  • Photomontages from each viewpoint with the mast shown at correct scale and in the proposed finish
  • An assessment of the cumulative effect with any existing masts or wind turbines nearby
  • Mitigation that is real: a monopole instead of a lattice, a matt finish in a colour tested against the backdrop, cabinet grouping and screen planting where planting will survive at that altitude

Galvanised steel reads as a bright vertical line against moorland. A dark grey or matt green finish often performs better, and the assessment should show which was tested rather than asserting that the chosen colour is appropriate.

Siting and sharing alternatives evidence

Policy expects operators to use existing sites and structures where they can, and the question an officer will ask first is why this new mast rather than a shared one.

Answer it with evidence. A list of existing structures within the search area, each with the reason it was discounted: insufficient height, wrong location for the coverage objective, structural capacity, no landlord agreement, or an operator already at capacity. Say which existing masts were approached and when.

The same applies to alternative positions on the same holding. Three or four options, each with a visual appraisal and a short note on why it was rejected, is the single most persuasive part of a hilltop mast submission. An application that presents one position as if it were the only possibility invites the officer to find a better one.

Public exposure declaration requirements

Submit a declaration of conformity with the international exposure guidelines with the application. It is a short document and it closes off the health objection, which will otherwise dominate the consultation responses.

Where PlanScope is used to draft a telecommunications compliance statement, the declaration itself comes from the operator's radio frequency engineer and the draft is a structure for that evidence rather than a substitute for it. Councils expect a suitably qualified author and professional review is strongly advised.

Expect objections on health grounds regardless. The officer report will record them and explain that national policy precludes the authority from determining health safeguards where the guidelines are met. That is not a reason to leave the declaration out.

Access track, compound and power supply

The mast is the visible part and the track is often the bigger landscape intervention. A new hardcore track climbing a hillside is visible for decades, scars peat, and changes drainage.

Deal with it properly. Show the route, the construction detail, the drainage crossings and the restoration proposals. Where the track is for agricultural purposes it may have its own permitted development route, but a track built to serve a mast is not agricultural development and needs its own consent. Say which consent you are relying on.

Power is the other constraint. A grid connection to a remote site means a new line, a pole route or an underground cable, each with its own consent regime and its own landscape effect. Where the site is off-grid, the solar array, battery housing and any generator need to appear on the drawings and in the assessment.

Ecology on moorland or upland sites

Upland sites look empty and are not. Ground-nesting birds, blanket bog, peat depth and designated sites all bear on the scheme.

A Preliminary Ecological Appraisal should establish the habitats present, the peat depth along the track route, and whether any designation applies. Breeding bird surveys run between March and August, which can delay a programme by a season if the appraisal is left late. Where a site of special scientific interest is involved, Natural England's consent is a separate requirement and the LPA will consult.

Protected species surveys need a suitably licensed ecologist under the Wildlife and Countryside Act 1981 and the Conservation of Habitats and Species Regulations 2017, and an AI-assisted draft is a starting point for that ecologist rather than a replacement for their fieldwork.

High ground also carries archaeology. Cairns, field systems and hillforts cluster on ridges, and an Archaeological Desk-Based Assessment is a short document that prevents a late objection from the county archaeologist.

Illustrative example. A 25 metre monopole proposed on a ridge within 400 metres of a scheduled cairn, with a 600 metre access track across shallow peat. Moving the mast 80 metres downslope took it off the skyline from the nearest village, kept it outside the monument's setting, and allowed the track to follow an existing farm route. The same coverage was achieved. Figures are illustrative.

The submission that gets approved in time

  1. Siting and appearance statement with coordinates, height, finish and cabinet details
  2. Alternatives and site sharing evidence, with structures approached and reasons for discounting
  3. Landscape and visual assessment with agreed viewpoints and accurate photomontages
  4. Declaration of conformity with the exposure guidelines
  5. Access track details, including construction, drainage and restoration
  6. Power supply arrangement and any associated infrastructure
  7. Ecology appraisal with survey windows flagged, and an archaeological desk-based assessment
  8. Required notices and publicity evidence

Submit it complete. The 56 day period is short and a request for further information eats it, and the full set of report types is listed on the report index.

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. For specialist technical reports, qualified professional input may be required.

Frequently asked questions

What can the council consider on a Part 16 mast application?

Siting and appearance, which includes landscape and visual effects. It cannot question whether the network is needed, weigh competition between operators, or determine health safeguards where the proposal meets the international exposure guidelines. Keep the submission focused on position, height, finish and visual effect.

How long does the authority have to decide?

56 days from a valid application. If it does not determine within that period the development may proceed in accordance with the submitted details, but relying on that is risky: thin details invite a later argument about whether what was built matches what was submitted.

Do I have to show that site sharing was considered?

Yes, in substance. Policy expects operators to use existing structures where they can, and an officer will ask why a new mast is needed. List the structures within the search area, say which were approached and when, and give the reason each was discounted on height, location, capacity or agreement.

Does the access track need its own consent?

Usually. A track built to serve a mast is not agricultural development, so agricultural permitted development rights do not cover it. Show the route, construction detail, drainage crossings and restoration, and state which consent you are relying on for it.

Which ecology surveys are likely on an upland site?

A preliminary ecological appraisal first, establishing habitats, peat depth along the track and any designation. Breeding bird surveys run from March to August, so leaving the appraisal late can cost a season. Protected species work requires a suitably licensed ecologist, and SSSI land needs Natural England's separate consent.

Sources and further reading

telecoms mastpart 16prior approvallandscaperural broadband

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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