Telecommunications declarations and who signs them

The declaration that accompanies a telecommunications prior approval application is a one-page document, and it is the only part of the submission that touches public health. It states that the installation is designed to be in full compliance with the public exposure guidelines of the International Commission on Non-Ionizing Radiation Protection. The question developers and site providers keep asking is who is entitled to sign it.

The short answer is the code operator, or someone authorised to act on the operator's behalf, on the basis of radio frequency engineering work carried out to the operator's standard. The signature is an operator liability, not a consultant's opinion offered at arm's length.

What the declaration certifies

Part 16 of Schedule 2 to the General Permitted Development Order 2015 governs development by electronic communications code operators, and prior approval applications for the siting and appearance of installations must be accompanied by a declaration of conformity with the ICNIRP public exposure guidelines.

Read carefully, the declaration is about design rather than measurement. It certifies that the installation as designed, with the equipment specified and the power levels and antenna patterns assumed, will keep public exposure within the guideline levels. It does not certify post-installation measurements, and it is not a certificate of ongoing compliance.

That distinction matters when objections arrive. A declaration cannot be contradicted by pointing at a different site, and it can only be tested by engaging with the design assumptions: equipment type, effective radiated power, antenna height and downtilt, and the location of any accessible area within the compliance boundary.

The current guidelines are the ICNIRP 2020 guidelines for limiting exposure to electromagnetic fields in the 100 kHz to 300 GHz range, which replaced the 1998 guidelines for that frequency range. A declaration citing the 1998 guidelines without explanation is a reason to ask a question.

Radio frequency engineering competence

There is no statutory register of radio frequency engineers and no protected title, so competence is demonstrated rather than certified. What a case officer or a reviewer should look for is a named individual with specific experience in electromagnetic field exposure assessment, working to a documented method, with chartered status in electrical or electronic engineering as the usual professional backstop.

The underlying work is a compliance assessment: calculating exposure levels around the antennas, establishing the compliance boundary within which public access must be restricted, and confirming that the boundary falls inside the operator's controlled area rather than across a footway, a balcony or a rooftop used by maintenance staff.

Competence questions are the same ones that arise for other specialist disciplines where the planning system relies on a declaration rather than a licence. The approach set out in our note on acoustician qualifications in planning transfers directly: look for the individual, the method and the professional body, in that order.

Operator responsibility and the signatory

The operator holds the Ofcom wireless telegraphy licence, and licence conditions require compliance with the ICNIRP general public exposure levels. That is the real enforcement route for exposure, and it sits outside the planning system entirely.

In practice the declaration is signed by an authorised officer or agent of the operator, relying on internal radio frequency engineering records and the manufacturer's data for the equipment. On shared sites it is signed by the operator making the application, which creates the cumulative question dealt with below.

A planning agent should not sign it. Nor should a site provider, a landlord or a tower company that does not hold the licence and does not control the radio configuration. Where an agent submits the application, the declaration should still be executed by or for the operator and included as a separate document rather than absorbed into the covering statement.

Where the declaration sits in the application

Three routes exist, and the declaration follows the equipment rather than the route:

On a prior approval application the authority has 56 days to determine, and the matters for consideration are siting and appearance. Health is not among them, because national policy has for many years directed authorities not to set their own health safeguards where a declaration of ICNIRP conformity is provided. Verify the current wording in the Framework published on 17 August 2026 before quoting it, since the chapters were recoded in that edition.

PlanScope drafts a Telecommunications Compliance report that sets out the policy position, the site context and the structure the declaration sits within. Councils usually expect a suitably qualified author for this work, and professional review is strongly advised; the declaration itself must come from the operator.

Challenges to the declaration and their weight

Objections on health grounds are common and rarely succeed. Inspectors have consistently treated a properly executed declaration as answering the exposure question, and have declined to go behind it on the basis of general concern or contested research. Those decisions are indicative of the approach rather than binding precedent.

What does get traction is a challenge to the completeness of the submission. If the declaration is missing, unsigned, undated, made by the wrong party, or refers to a different site or a superseded equipment specification, the application has a problem the authority can act on. The same applies where the compliance boundary plainly overlaps publicly accessible space and nothing in the submission addresses access control.

So the defensive work is clerical as much as technical. Check the site reference, the date, the signatory's authority and the guideline edition before submission. Those four checks remove most of the ground an objector can stand on.

Keeping the record for later sites

Operators and site providers accumulate declarations across hundreds of sites, and the records matter at three later points: a site upgrade that changes the radio configuration, a dispute with an occupier about rooftop access, and a renewal or variation application years later.

Keep the declaration with the radio configuration data it relied on, the equipment datasheets, the compliance boundary drawing and the access control arrangements. A declaration filed alone, without the assumptions behind it, cannot be reused when the equipment changes. The discipline is the same one that applies to lighting evidence, where the guidance edition and the modelled assumptions have to travel with the result, as our note on the guidance councils cite for lighting design sets out.

Record the date of any post-installation audit separately. Audits are not what the planning declaration certifies, and conflating the two creates a gap when someone asks for evidence of as-built compliance.

Appointing for a shared site

Site sharing is normal, and it is where the single-operator declaration gets uncomfortable. Each operator's declaration covers its own installation. Public exposure at a shared mast is the sum of contributions from every operator present.

The way this is handled in practice is a cumulative assessment, prepared for the site as a whole, with each operator's declaration referencing it. When appointing for a shared site, make that explicit in the brief:

• scope the assessment to all existing and proposed transmitters on the structure, not only the new one
• require the compliance boundary drawing to show the cumulative result
• require the assumptions for other operators' equipment to be stated and sourced
• set out who updates the assessment when any operator changes configuration
• identify the access control measures and who maintains them

The last point is the one that gets forgotten and the one that causes problems on rooftops, where a maintenance contractor working on plant can end up inside a compliance boundary nobody told them about.

Where a reviewer with the right competence is needed for the planning documents that sit around the declaration, the professional directory is the route to a sign-off. For specialist technical reports, qualified professional input may be required. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.