Telecommunications compliance statement: what goes in it

A telecommunications compliance statement is the document that turns a set of mast drawings into a prior approval application a council can actually determine. It does two jobs. It certifies that the installation will operate within the International Commission on Non-Ionizing Radiation Protection (ICNIRP) public exposure guidelines, and it explains why this apparatus, in this position, with this appearance, is what the operator has settled on. Under Schedule 2 Part 16 of the Town and Country Planning (General Permitted Development) (England) Order 2015, the authority's discretion is deliberately narrow. The statement has to do its work inside that frame.

What the statement has to certify

Part 16 Class A grants permitted development rights to electronic communications code operators, subject to conditions and limitations, and subject in many cases to the developer first applying for prior approval of siting and appearance. The statement is the vehicle for the supporting evidence national policy expects.

Three things belong in it as a minimum. A self-certification that the installation, when operational, will comply with ICNIRP public exposure guidelines. A record of the consultation the operator has carried out. And a justification for the site, covering the coverage or capacity problem being solved and the alternatives that were rejected.

The National Planning Policy Framework has for several editions required applications for electronic communications development to be supported by the evidence needed to justify them, and has told authorities not to set health safeguards different from the ICNIRP guidelines. The Framework was re-issued on 17 August 2026 with policy-coded chapters in place of paragraph numbers, so check the current wording and quote the code from the published edition rather than from an older copy.

The ICNIRP declaration and who signs it

The declaration is a statement by or on behalf of the operator that the base station, when operating, will comply with the ICNIRP guidelines for public exposure as expressed in the EU Council recommendation those guidelines feed into. It is a self-certification. No council officer measures the field strength, and no authority may refuse on the basis that it wants a stricter standard.

In practice the declaration is signed by the operator or by the radio frequency engineer who has modelled the exclusion zones around the antennas. That matters for a reason beyond form. The exclusion zone geometry determines whether maintenance staff, window cleaners, roof plant engineers or neighbouring occupiers can be present in the beam at close range, and it drives the physical barriers, signage and access restrictions that appear on the drawings. Where a rooftop installation sits near a walkway or a plant deck, the declaration and the access strategy have to agree with each other.

An authority cannot reopen the health question. But it can, and often does, ask whether the declaration covers the scheme as drawn, including any sharing operator's equipment on the same structure.

Site selection and the alternatives considered

This is where most compliance statements are thin, and where officers push back. A justification that says "no alternative site was available" without saying what was looked at invites a request for further information and burns the determination period.

Set it out as a sequence. State the coverage or capacity objective in plain terms, such as filling an in-building coverage gap in a defined area or adding capacity to a cell that is congested at peak. Identify the search ring the radio planners worked to, and say roughly how large it is. Then list the candidate sites inside that ring, with the reason each was discounted: no landlord agreement, insufficient height to clear an obstruction, unacceptable visual effect on a listed building, no power or fibre, or an existing structure that could not take the load.

Where the search ring crosses a conservation area, a National Landscape, a National Park or the setting of a designated heritage asset, say so and explain what was done to avoid or reduce harm. The same discipline applies as in any other supporting document, and the exercise reads much like the alternatives narrative in a Planning Statement.

Siting and appearance as the prior approval matters

Where prior approval is required, the authority is considering siting and appearance. Not need. Not competition between operators. Not health. An officer report that strays into those areas is vulnerable, and a statement that addresses them at length wastes space that should be spent on the two matters in play.

Siting arguments worth making include the relationship of the mast to the building line and to the ridge height of nearby buildings, the backdrop against which it will be read from public viewpoints, the distance to the nearest residential window, and the effect on any listed building or conservation area setting. Appearance arguments cover the colour finish, the slimline or shrouded antenna option, cabinet grouping and enclosure, and whether a monopole, a slim column or a disguised design is appropriate in that street.

Illustrative example: a 20 metre monopole proposed on a grass verge outside a 1960s parade of shops reads very differently from the same pole on a residential street of two-storey semis. In the first case the backdrop of flat-roofed commercial buildings and existing street lighting absorbs it. In the second it is the tallest thing for 200 metres. The statement should say which of those two situations it is in, with a photograph and a sightline, and then propose the finish that suits it.

A short table helps officers separate the two matters.

Sharing and mast rationalisation evidence

Policy has long preferred the use of existing masts, buildings and other structures before a new site is built. So the statement should record which existing structures inside the search ring were tested for sharing and why each was ruled out, whether for structural capacity, height, landlord refusal or radio reasons.

Two related points are often missed. First, if the proposal is to strengthen or replace an existing mast so that another operator can share it, say that plainly, because rationalisation of several structures into one is a positive planning consideration. Second, the rights an operator has under the Electronic Communications Code in Schedule 3A to the Communications Act 2003 are separate from planning permission. Code rights govern the relationship with the site provider. They do not create a planning fallback, and a statement that blurs the two loses credibility.

Consulting schools and other sensitive uses

Operators in England work to an agreed code of practice on mobile network development, which sets expectations for community engagement before an application is made. The part that comes up most often is consultation with the governing body of a school or college where apparatus is proposed on or near its site.

Record the consultation properly: who was contacted, on what date, by what means, what was said in response, and what changed as a result. Councillors and parish councils are frequently included too. Where objections raise perceived health effects, the honest answer in the statement is that the ICNIRP declaration addresses exposure and that the authority cannot apply a different standard, said once and without condescension. Some authorities also expect a short note on effects on local amenity and wellbeing, which is a lighter touch version of the reasoning used in a health impact assessment.

The submission pack for a Part 16 application

A complete pack for a prior approval application under Part 16 usually contains:

1. The application form and the correct fee for prior approval under the Order.
2. A site location plan and a block plan showing the apparatus, cabinets, fencing and any exclusion zones.
3. Elevations and sections showing height, antenna configuration and finish.
4. Photographs from agreed viewpoints, with photomontages where the structure is prominent.
5. The telecommunications compliance statement, including the ICNIRP declaration.
6. Evidence of the notice given and of pre-application consultation.
7. A heritage note where a designated asset or its setting is affected.

Part 16 sets height, width and volume limits that were widened by amendment in 2022, and the position on article 2(3) land differs from unprotected land, so read the consolidated text on legislation.gov.uk before assuming a proposal is permitted development at all. The determination period for prior approval under Part 16 is short, and the consequence of the authority failing to determine in time is set out in the Order itself. Diary it from the date of receipt.

Councils usually expect the radio frequency content to come from someone with the relevant engineering competence, and professional review of the statement is strongly advised before submission. PlanScope can draft a Telecommunications Compliance statement structured to UK planning policy, flagging missing site data rather than inventing it, and then send it for review. Enter the site postcode to see which other documents the application is likely to need.

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.