Evidence base for a telecoms mast under Part 16

A new mast for a mobile operator rarely needs a full planning application. Most of the work sits in Part 16 of Schedule 2 to the Town and Country Planning (General Permitted Development) (England) Order 2015, and what reaches the council is a telecoms mast prior approval application limited to two questions: siting and appearance. That narrow scope is what catches agents out. You cannot argue need, the authority cannot weigh coverage against competition, and health is settled by a declaration rather than by evidence the case officer assesses.

So the evidence base looks nothing like a normal application pack. There is no Planning Statement working through the development plan, no transport chapter, no drainage. There is a short, visual, site-specific case about where the apparatus goes and what it looks like when it is there.

What Part 16 permits and what still needs prior approval

Class A of Part 16 grants rights to an electronic communications code operator, acting under the Electronic Communications Code in the Communications Act 2003, for development needed for its network. That covers masts, antennas, dishes, poles, radio equipment housings, cabinets and the associated works.

The Order sets limits on height, width, volume and position, and those limits were widened by amendment in 2022 to allow taller masts and greater strengthening of existing structures. Read the current consolidated text on legislation.gov.uk rather than a summary, because the figures differ between unprotected land and Article 1(5) land, and between a new mast and the alteration of one that already exists.

Within those limits, a defined set of categories may only go ahead after the authority has given prior approval of siting and appearance. New ground-based masts are the obvious one. Installations on buildings above a certain size come into it too. Everything else in the class proceeds under the conditions attached to Part 16 without any application at all, which is why an operator's programme can look implausibly fast to anyone used to householder timescales.

The siting and appearance test, and nothing else

Two words carry the whole determination. Siting is the location of the apparatus on the ground, including its relationship to buildings, trees, boundaries, footways and sight lines. Appearance covers height, slenderness, colour, finish, the antenna arrangement and the clutter at the base.

The practical consequence is that an alternative site appraisal does most of the persuading. Officers want to see that the operator looked at sharing an existing mast, at an existing tall building, at a site further from housing or a heritage asset, and why each option failed on coverage, landlord refusal, structural capacity or access. Two paragraphs each is enough. What sinks a submission is an appraisal that lists three sites nobody would have chosen and then declares the application site the only option.

Be honest with the photomontages. Use a view from the nearest residential frontage, one from the approach along the highway, and one from any designated area or public footpath that looks towards the site. Winter views matter where screening depends on deciduous trees. If the mast will be visible above a roofline, show it above the roofline.

Where the site sits within or close to a conservation area or the setting of a listed building, the heritage duties under the Planning (Listed Buildings and Conservation Areas) Act 1990 still bite on the prior approval decision. A short Heritage Statement that identifies the assets, describes their significance and explains the effect of a slim monopole will usually be proportionate. Open countryside cases sometimes justify a scoped-down Landscape and Visual Impact Assessment, particularly in a National Landscape where a 20 metre structure breaks a ridgeline.

The ICNIRP declaration

Part 16 requires the application to be accompanied by a declaration that the equipment and installation is designed to be in full compliance with the radio frequency public exposure guidelines of the International Commission on Non-Ionizing Radiation Protection. National policy in the current National Planning Policy Framework, published on 17 August 2026, is that authorities should not question the need for the network and should not set health safeguards different from the ICNIRP guidelines where that declaration is provided.

This is the single most misunderstood part of the process. Objectors write about radiation, and an officer who engages with that debate rather than with the declaration is heading for trouble. A Telecommunications Compliance statement belongs in the pack as the document that carries the declaration and sets out the equipment schedule behind it. Because the underlying numbers come from radio frequency engineering, the sensible route is to have the operator's own radio frequency engineer confirm the content before it is submitted.

Consultation before the application lands

Operators work to a government and industry code on mobile network development in England, and the consultation it sets out is what separates a quiet application from a contested one. In practice that means early contact with the authority's planning and highways teams, contact with the parish or town council, and engagement with any school, college or nursery near the proposed site.

The authority then publicises the prior approval application in the usual way, by site notice, neighbour notification or both. Objections about need and health will arrive anyway. The submission is stronger if it already answers the two questions officers will be asked at the counter: why here, and why this height.

Designations that cut the rights back

Rights are narrower on Article 1(5) land, which takes in conservation areas, National Parks, National Landscapes, the Broads and World Heritage Sites, and narrower again on a site of special scientific interest. An Article 4 direction can remove the relevant rights altogether, in which case the operator needs full planning permission and the whole development plan comes into play.

Listed buildings are a separate matter. Part 16 does not authorise works to a listed building, so apparatus fixed to a church tower or a listed mill needs listed building consent, and the same logic applies to other equipment on a listed building. Scheduled monument consent works the same way for apparatus within a scheduled area.

Check the constraint position from the mapped data before the site is chosen rather than after the landlord has signed. A site 15 metres outside a conservation area boundary is a different application from one just inside it.

Screening, colour and the cabinets at the base

Most refusals on appearance are about the ground level compound rather than the mast. A slim monopole in a hedgerow reads as street furniture. Six cabinets, a palisade fence, a gravel apron and a meter pillar do not.

Reduce the visible footprint where you can. Group cabinets on one side, specify a dark finish that matches the surroundings rather than a standard grey, use timber post and rail with planting instead of steel palisade where security allows, and show the planting on the layout rather than mentioning it in the covering text. Colour choice is a real decision: galvanised steel weathers to a pale grey that stands out against woodland, while a dark olive or matt black monopole disappears against a treeline for most of the year.

Illustrative example: a 20 metre monopole proposed on a wide highway verge at the edge of a village, 40 metres from the nearest dwelling and 60 metres from a conservation area boundary. The appraisal ruled out sharing on an existing 15 metre mast 800 metres away because the operator's own coverage plot showed the target area unserved, and ruled out a roof installation because the tallest building was a two storey village hall with no structural report. The scheme moved the compound behind an existing hedge, dropped the fence to 1.8 metres of timber, and specified a matt dark green finish. That package is the difference between approval and a refusal on appearance.

The 56 day period and how it goes wrong

The authority has 56 days, beginning with the date it received the application, to notify the applicant of its determination. If it does not, the development may be carried out as described. Operators diarise this carefully and authorities sometimes do not.

Two things commonly break it. The first is an incomplete application, because the clock runs from receipt of a valid application and a missing declaration or fee gives the authority an argument. The second is agreeing an informal extension by email while amended drawings are prepared, then treating the original date as still governing. Put any agreed extension in writing and be explicit about the new date.

A fee is payable for telecoms prior approval, and the national fee schedule is indexed annually, so check the current figure on the Planning Portal before submitting rather than copying a figure from an old pack.

Where the authority refuses, the appeal route is the same as for other prior approval decisions, and the only matters in play remain siting and appearance. That is a narrow battleground, which cuts both ways: a well evidenced alternative site appraisal with honest visuals is hard to defeat, and a thin one has nothing else to hide behind.

PlanScope can draft the Telecommunications Compliance statement and the supporting heritage or landscape narrative for a Part 16 submission in minutes, with the site constraints already picked up from the postcode. 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, and the radio frequency content of an ICNIRP declaration belongs with the operator's engineer.

Enter a postcode on PlanScope to see which of all 66 report types a site is likely to need before the operator's programme starts.