Documents for a telecoms installation under Part 16

A new telecoms mast on open land is usually dealt with as an application for prior approval of siting and appearance under Part 16 of Schedule 2 to the General Permitted Development Order 2015, and the pack is narrower than people expect. The authority is deciding where the apparatus goes and what it looks like. It is not deciding whether the operator needs the site, and it cannot refuse on health grounds once the exposure declaration is in. What that means in practice is that your supporting material has to work hard on siting alternatives, visual effect and designation constraints, and almost not at all on coverage economics.

What Part 16 permits and where it stops

Part 16 Class A grants rights to electronic communications code operators for development in connection with the operator's network, subject to limits on height, width and location and to a set of conditions. Installations within those limits still need prior approval of siting and appearance in the cases the Order specifies, which covers most new ground based masts.

The height and width limits were raised by amendments in 2022, and they differ between article 2(3) land, which includes conservation areas, National Parks, National Landscapes, the Broads and World Heritage Sites, and everywhere else. Read the current consolidated Part 16 text on legislation.gov.uk rather than a summary, because this part of the Order has been amended repeatedly and older guidance circulates widely.

Three things sit outside Part 16 altogether. Apparatus above the stated limits needs full planning permission. Works to a listed building need listed building consent whatever the Order says about planning. And permitted development rights grant no interest in land, so the Electronic Communications Code, a lease or a wayleave still has to be in place.

Prior approval of siting and appearance only

The scope of the determination is the point most objections miss and most officer reports have to explain. The authority may approve, may refuse, or may approve with conditions, but only by reference to siting and appearance.

That constrains the arguments on both sides. An objection based on property values or on perceived health risk is not a matter the authority can act on. An objection based on the mast appearing above a listed church tower in views from a public footpath is squarely within scope, and so is one about the position of the equipment cabinets relative to a footway.

So the supporting statement should be structured around siting and appearance, with everything else kept short. Set out the search area, the sites considered and rejected with the reason for each, and why the application site is the least harmful option that works technically.

The exposure declaration and what it certifies

Part 16 requires the application to be accompanied by a declaration that the equipment and the installation, when operational, will comply with the public exposure guidelines of the International Commission on Non-Ionizing Radiation Protection. The declaration is the mechanism that takes health out of the planning decision.

It certifies conformity with the guidelines, nothing more. It does not certify that a particular measured field strength will occur at a particular location, and operators will not usually provide site specific measurements at application stage. Where the installation is near a school or college, national policy expects the operator to have consulted the relevant body before submitting, and evidence of having done so belongs in the pack.

Omitting the declaration is a validation failure rather than a reason for refusal, and it is one of the more common reasons a Part 16 submission bounces.

Site sharing and alternative site evidence

National policy expects operators to keep the number of masts to the minimum consistent with the service, so evidence that sharing an existing mast or using an existing building has been explored is part of the submission even though need is not a ground of refusal.

The evidence that works is specific. A list of existing structures within the search area, each with the reason it was discounted, carries weight. A paragraph asserting that sharing was considered and found unsuitable does not, and invites a committee to defer.

Designated land and the tighter limits

On article 2(3) land the permitted limits drop and the appearance test gets harder. Expect to provide more than photographs.

In a conservation area or within the setting of a listed building, the statutory duties under the Planning (Listed Buildings and Conservation Areas) Act 1990 apply to the decision, so a short Heritage Statement identifying the affected assets, their significance and the effect of the installation is worth preparing even for a prior approval. The same applies to a scheduled monument, where consent from the Secretary of State runs separately from planning.

In a National Park or National Landscape, a proportionate Landscape and Visual Impact Assessment with wirelines or photomontages from agreed viewpoints is the normal expectation on a tall mast. Our note on which documents a conservation area application needs covers the general pattern of evidence in designated areas.

Camouflage is a live design question rather than a gimmick. Monopoles with internal antennas, colour treatments matched to a backdrop of trees, and cabinet positions set behind existing walls all reduce visual effect, and offering them in the submission is better than having them imposed by condition.

Trees, access and the ground level detail

Mast sites fail on the small things. The access track, the crane standing area, the cable route and the cabinet compound all involve excavation, and all of it is development that has to sit within the permitted limits or be applied for.

If there are trees near the compound, a survey to BS 5837:2012 and a tree protection plan should be in the pack, because root protection areas and the crane position are usually in conflict. A tree survey and a short arboricultural method statement for the access works is proportionate on a rural site.

Drainage and surfacing of the compound matter where the site is in a flood zone or a source protection zone, and the same logic applies as in our guide to documents for a scheme in a Source Protection Zone.

The pack, the clock and what happens on silence

Part 16 prior approval runs to a 56 day period. If the authority has not notified a decision within that time, and the applicant has complied with the publicity and notification requirements, the development may proceed in accordance with the submitted details. That makes the procedural steps as important as the technical ones.

1. Confirm the land interest and serve any required notice on the owner or agricultural tenant.
2. Check the current Part 16 limits against the proposed height, width and location, including whether the site is article 2(3) land.
3. Assemble the drawings, the ICNIRP declaration, the site selection statement and the visual material.
4. Carry out the required pre-application consultation and record it.
5. Submit with the correct fee and track the 56 day period from the date the authority received the application.
6. Keep a record of publicity and notification, because the deemed consent route depends on it.

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. Enter your postcode on PlanScope to see which supporting documents a mast or cabinet site is likely to need.