ICNIRP declarations for telecoms masts and who signs them

An ICNIRP declaration telecommunications applications rely on is signed by the network operator, not by the architect, the planning agent or the council. It is a statement that the installation, taken together with everything else radiating at that location, has been designed to comply with the public exposure guidelines of the International Commission on Non-Ionizing Radiation Protection. The engineering behind it belongs to a radio frequency engineer working for the operator, and the planning system treats the signed declaration as settling the health question.

Agents get this wrong in both directions. Some try to produce the declaration themselves. Others assume the council will interrogate it.

What the declaration confirms

The declaration is narrow and precise. It confirms that the base station has been designed so that, in normal operation, public exposure at places accessible to the general public stays within the ICNIRP reference levels for the relevant frequency range.

It is a cumulative statement. Where several operators share a mast or a rooftop, the assessment has to account for the combined field from all the apparatus at that site, not only the antennas being added. That is why a declaration is regenerated when a site is upgraded rather than copied forward from the original consent.

What it does not do is measure. The declaration rests on calculation and on the operator's exclusion zone design, with measurement carried out separately under the regulator's own audit regime.

Who is competent to issue it

Responsibility sits with the code operator. In practice the underlying exposure calculation is produced by a radio frequency engineer or an EMF specialist within the operator's radio planning team or a contracted consultancy, and the declaration itself is signed by an authorised signatory for that operator.

Three groups are sometimes assumed to be able to sign and cannot.

• The site provider or landlord, who has no visibility of the transmit power, antenna tilt or exclusion zone geometry.
• The planning agent or architect preparing the application drawings, who is documenting siting and appearance.
• The local planning authority's own officers, who receive the declaration as submitted evidence.

The distinction matters because the declaration carries the operator's liability. If you are drafting the supporting statement, your job is to confirm that a current declaration exists for the configuration being applied for and to reference it, which is the same discipline described in what competent person means in planning legislation.

The guidelines the declaration refers to

ICNIRP published revised guidelines for limiting exposure to electromagnetic fields in the range 100 kHz to 300 GHz in 2020, replacing the 1998 guidelines for that band. A declaration should be written against the current guidelines, and an older form of words referring only to the 1998 document is a sign that the paperwork has been reused.

The guidelines set basic restrictions on the quantities that relate to biological effect, with reference levels derived from them that can actually be measured or calculated at a location. Compliance with the reference levels is taken as compliance with the basic restrictions.

National policy takes the guidelines as the answer to the health question. The National Planning Policy Framework, in its edition published on 17 August 2026, carries the long-standing position that local planning authorities should not set health safeguards different from those in the ICNIRP guidelines, and should not question the need for an electronic communications system. Verify the current wording on gov.uk before quoting it, because the Framework was re-issued with policy-coded chapters in place of paragraph numbers.

Where the declaration sits in the application

Most mast and antenna work by code operators runs through Part 16 of Schedule 2 to the GPDO 2015, either as development that needs no application at all or as development requiring prior approval of siting and appearance. The prior approval application has to be accompanied by the ICNIRP declaration. Where the proposal falls outside Part 16 and needs full planning permission, the declaration is still expected as part of the submitted evidence.

A missing declaration is a validation issue rather than a merits issue. It will hold the application at the front desk, and on a 56 day prior approval clock that is time you do not have. Check it before submission in the same way you would check whether any other piece of evidence is still current, which is the habit set out in checking whether a survey is still valid.

What the declaration does not address

Objectors frequently read the declaration as a claim that the installation is safe in every respect. It is not that broad, and being honest about its limits is better ground to stand on than overstating it.

The declaration addresses public exposure to radio frequency fields against the ICNIRP reference levels. It says nothing about visual impact, nothing about the effect on a conservation area or a listed building's setting, and nothing about noise from cabinet cooling. Those are the matters an authority can and does weigh, and they are where a prior approval refusal on siting and appearance actually comes from.

Occupational exposure inside the exclusion zone is a separate regime again, managed through the operator's access control and permit to work arrangements rather than through planning.

Schools, hospitals and consultation expectations

Proposals near schools and hospitals attract the most correspondence, and the policy position is the same as everywhere else: the ICNIRP declaration answers the health question, and an authority should not apply a different standard because of the receptor.

What does change is the consultation expectation. The government and industry code on mobile network development in England asks operators to consult the relevant body where a site is proposed near a school or a hospital, and to explain the proposal to it before an application is made. That is a process obligation, not a health threshold, and a refusal reason built on perceived health risk is unlikely to survive an appeal.

Officers under pressure from a local petition sometimes look for a condition requiring monitoring. There is no policy basis for one where a current declaration has been provided.

Checking a declaration before submission

Run four checks. Does the declaration name the specific site reference and the configuration you are applying for. Is it dated recently enough to reflect the proposed equipment rather than a previous generation of it. Does it refer to the current ICNIRP guidelines. Is it signed by someone authorised by the operator.

If any of those fails, go back to the operator's radio planning team rather than redrafting the wording yourself. Where a project needs the supporting narrative pulled together around that declaration, a Telecommunications Compliance report gives you the structure, and it is one of the types PlanScope labels as needing a suitably qualified author, with professional review strongly advised. Reviewers who can take on that sign-off can be found through the professional directory.

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.