Reports needed for a telecoms mast under Part 16

A new mast for a mobile network is usually not a planning application at all. It is a prior approval application under Part 16 of Schedule 2 to the General Permitted Development Order 2015, and the local planning authority can consider two things only: siting and appearance. That narrow scope is what shapes the telecoms mast prior approval reports you submit, and it is why an application that reads like a full planning submission wastes everybody's time while one that ignores visual effect gets refused.

The other structural point is timing. The authority has 56 days from receipt to determine a Part 16 prior approval, and if it does not determine within that period the development may proceed. Applicants sometimes rely on that. Authorities are alive to it, so get the submission complete first time.

What Part 16 permits and what needs prior approval

Part 16 grants permitted development rights to electronic communications code operators for installing, altering and replacing apparatus. The rights are subject to dimension and height limits that differ between ordinary land and article 2(3) land, which covers conservation areas, National Parks, National Landscapes, the Broads and World Heritage Sites. Those limits were changed by amendments in 2022 to support network upgrades and mast sharing, so read the current text of the Order rather than an older summary.

Where the proposal exceeds a limit, the right does not apply and a full planning application is needed. Within the limits, most ground-based masts and a range of building-mounted apparatus require prior approval of siting and appearance before installation.

Establish which category you are in before anything else, because the document set differs entirely.

Siting and appearance, and nothing else

The authority cannot refuse on health grounds. It cannot refuse because a different operator has a mast nearby, or because residents object to coverage arrangements, or on the basis of property values. Those points appear in almost every objection and none of them is a reason for refusal under Part 16.

What the authority can assess is where the apparatus goes and what it looks like. In practice that means the relationship to buildings and the street scene, the effect on views into and out of a designated area, the effect on the setting of a listed building, clutter at street level, the colour and finish of the column and cabinets, and whether a less obtrusive position within the search area exists.

Answer those points directly. A supporting statement that explains the technical search area, the sites considered and rejected within it, and why this position was chosen, is the document that decides the application.

The exposure certificate

Part 16 requires the application to be accompanied by a declaration that the equipment, when operational, will comply with the public exposure guidelines issued by the International Commission on Non-Ionizing Radiation Protection.

That certificate is the reason health is not a material consideration here. Where a valid declaration is provided, national policy says authorities should not question the health aspects further. Include it with the submission rather than sending it later, because its absence is a straightforward validation failure.

A Telecommunications Compliance document setting out the compliance position and the technical basis for the site is the standard supporting item, and the technical content is properly a matter for a radio frequency engineer.

Site selection and the alternatives argument

The search area comes from radio planning: the coverage or capacity gap the site exists to fill, within which the position is constrained by height, line of sight and access to power and backhaul.

Set that out plainly. List the sites considered, including existing masts and buildings tested for sharing, and give the reason each was rejected in one line. Mast sharing is expected wherever it is feasible, and an application that has not addressed the nearest existing structure will be asked about it.

Where the preferred site sits in a sensitive location, show the comparison honestly. An assessment concluding that the only workable site happens to be the one the operator wanted is less persuasive than one that names a technically viable alternative and explains why it is worse on siting and appearance grounds.

Designated land, heritage and landscape

On article 2(3) land the limits are tighter and the assessment is harder. Add a Heritage Statement where the apparatus affects a listed building, a conservation area or the setting of either, dealing with significance and the degree of harm rather than simply asserting that the equipment is small.

Where the site is prominent in open countryside or on the edge of a designated landscape, a Townscape and Visual Impact Assessment with photomontages from agreed viewpoints does more than any amount of text. Agree the viewpoints with the officer before the photography.

Listed building consent is a separate application where apparatus is fixed to a listed structure, and Part 16 does not provide it.

Street clutter and the ground level detail

Most objections at street level are about cabinets rather than the column. Equipment cabinets, meter pillars, bollards and the fenced compound take up footway width and accumulate over time.

Show the ground level arrangement on a dimensioned plan with the retained footway width, and address pedestrian desire lines, visibility at junctions and accessibility. Where cabinets can be positioned behind a boundary rather than in the footway, propose that. Colour and finish matter more than people expect, and a column in a finish matched to nearby street furniture attracts fewer objections than a galvanised one.

The document bundle

For a typical ground-based mast outside a designated area, expect to submit the prior approval application form and fee, a site location plan, a site layout plan showing the compound and cabinets with retained footway widths, elevations of the column and equipment with dimensions and finishes, the exposure declaration, a supporting statement covering the technical need and the site selection sequence, photographs of the existing street scene, and photomontages or wireline views where the apparatus is prominent.

Add the heritage assessment and the visual assessment on designated land. Add evidence of any consultation carried out, including with nearby schools where industry practice expects it. The full report index shows where the supporting assessments sit.

Determination periods and what happens if the deadline passes

The 56 day period runs from the date the authority receives the application. Within it the authority must either grant prior approval, refuse it, or tell the applicant that prior approval is not required. If none of those happens in time, the development may proceed in accordance with the submitted details.

Two cautions. The clock runs from a valid application, so an incomplete submission does not start it. And proceeding on the basis of a missed deadline means building exactly what was submitted, since anything else is outside the permission. Keep a dated record of what was sent and when.

Where prior approval is refused, there is a right of appeal to the Planning Inspectorate, and appeals on siting and appearance turn on the same evidence the application should have contained.

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.