Scenario Walkthroughs

Walkthrough: a telecoms mast on a school site

8 min readBy PlanScope Editorial Team

Under Part 16 the authority can consider only siting and appearance. In this illustrative case sixty health objections changed nothing, and a playing field consultee moved the mast 60 m.

A telecoms mast on a school site is decided under Part 16 of Schedule 2 to the General Permitted Development Order 2015, and the authority can consider only two things: siting and appearance. The health objections that dominate the public meeting are not matters the authority can refuse on, provided the operator supplies the required declaration about compliance with the international exposure guidelines. The illustrative case below is a monopole on a secondary school playing field, where the objections were about health and the decision turned on a statutory consultee nobody had thought about.

The site, the operator and the coverage case

An operator identified a coverage gap in a suburban area where an existing rooftop installation had been lost when a commercial building was redeveloped. The replacement search area covered roughly 400 m of a residential street and the grounds of a secondary school.

The school held a large playing field with a sports hall at one corner and a maintenance compound beside it. A mast on school land brought the school a rental income, which is why these approaches are made and why they are frequently accepted.

The proposal as first submitted was an 18 m monopole with three antennas, two equipment cabinets and a palisade fenced compound, positioned at the edge of the playing field about 25 m from the rear boundaries of eight houses.

The prior approval route and its limits

Part 16 gives electronic communications code operators permitted development rights for development needed for their network, subject to limits and to a prior approval procedure for certain works, including new ground based masts.

Three features of the route shape everything that follows.

Height limits apply, and they differ between protected land such as conservation areas, National Landscapes and National Parks, and land outside those designations. Those limits were raised by amendments made in 2022, so read the current text of the class rather than any summary written before then.

Prior approval is sought as to the siting and appearance of the development. The authority determines that narrow question.

And the determination period is 56 days. If the authority does not notify its determination within that time, the development may proceed. Operators know this and plan around it, and authorities under pressure occasionally lose a case to the calendar.

Siting and appearance as the only considerations

This is the point that makes these cases so frustrating for objectors, and it is worth stating plainly at the start of any consultation.

The authority is not deciding whether the mast should exist. Permission for it comes from the Order. The authority is deciding whether this position and this appearance are acceptable, and if they are not, what position and appearance would be.

So an objection that engages with siting and appearance has real purchase. Move the compound behind the sports hall. Reduce the pole height. Use a slimline monopole rather than a lattice. Replace palisade fencing with close boarded timber. Paint the shroud a recessive colour. Plant the compound. Those are the arguments that change outcomes, and in this illustrative case most of them succeeded.

An objection about radio frequency exposure, property values or whether the operator should have found somewhere else entirely does not engage the test.

The health objection and how it was answered

Around sixty representations were received and the overwhelming majority raised health, as they always do when the site is a school.

Part 16 requires the application to be accompanied by a declaration that the equipment and installation, taken together with other installations at the site, will comply with the international guidelines on exposure to electromagnetic fields. National guidance is that where such a declaration is provided, authorities should not question the health aspects of the proposal.

The declaration was provided. The officer's report set out the position in a paragraph and the issue went no further, which is the correct handling and feels to objectors like being ignored.

What the school's governing body did achieve was a commitment that the installation would be included in the operator's audit and monitoring arrangements, recorded in the submission rather than by condition. National guidance expects operators to consult the relevant body of a school or college where development is proposed on or near a school, and that consultation is where a school has real bargaining power, because the landlord is the school itself and the lease is negotiated privately. A Telecommunications Compliance document sets out the declaration and the supporting technical position, and councils usually expect it to be prepared or checked by a suitably qualified radio frequency engineer with professional review before submission.

Playing field land and the statutory consultee

Here is the issue that decided the case.

Development affecting land used as a playing field brings in a statutory consultee on sport provision, and that consultee objected. The compound and its access track would have taken a corner out of a marked pitch and created a permanent obstruction within the run off area at one end.

That objection was not about appearance. It was about the loss of playing field land, which engages its own national policy test and its own exceptions, and it carried far more weight than sixty letters about health.

The response was to move the whole installation to the maintenance compound beside the sports hall, which was already hard surfaced, outside the marked pitches, and screened on two sides by the building. The pole moved roughly 60 m further from the nearest houses as a result. An Open Space Assessment setting out the pitch layout, the areas affected and the position after relocation was what resolved the objection, and national guidance on open space, sport and recreation sets out the tests the authority applies.

The lesson generalises. On school and sports sites, the sport consultee is usually a stronger ally for neighbours than any amount of correspondence about siting, and a scheme that survives that objection has usually been improved for everyone.

Transport is the other issue that recurs on school sites, and our note on a school expansion and the transport evidence covers how construction and operational access are handled there.

Alternative sites and the evidence of site selection

National guidance expects operators to explore sharing existing masts and using existing structures before proposing a new ground based mast, and to supply evidence of the site selection process.

In this illustrative case the submission listed eleven candidate positions with reasons for discounting each: three rooftops where the landlord declined, two where the building height was inadequate, an existing mast too far outside the search area to close the gap, two positions where the required feeder run was impractical, and three where highway land was unavailable.

That schedule is worth interrogating if you are objecting. Reasons such as the landlord declined and commercially unviable are assertions. Reasons framed in radio terms, such as insufficient height to clear an intervening obstruction, are testable and are usually honest.

What rarely succeeds is arguing that a site somewhere else would be better without evidence that it would deliver the same coverage.

Landscaping and the equipment compound

The compound does more visual damage than the pole. A pole is slim and read against the sky. A compound is a fenced enclosure at eye level with cabinets, a meter box, cable trays and a gate, usually with a hard surfaced apron.

The design that was approved used close boarded timber fencing rather than palisade, cabinets in a recessive colour, a native hedge on the two exposed sides, and the existing building as backdrop on the others. A Landscape Strategy covering species, sizes at planting, protection during establishment and a maintenance period gave the authority something to condition.

Specify planting sizes. A hedge planted as 400 mm whips screens nothing for six years, and a condition requiring planting in accordance with an approved scheme is only as good as the scheme.

The decision and the conditions attached

Prior approval was granted. Because the authority's remit was siting and appearance, the conditions were confined to those matters: development in accordance with the approved drawings showing the relocated compound, the pole and cabinets finished in the approved colour, the fencing as specified, the landscaping to be carried out in the first planting season after the installation is brought into use, and any plant that fails within five years to be replaced.

What the authority could not impose were conditions about emissions, operating power, future equipment upgrades or removal at the end of the lease. Upgrades within the limits of the class are separately permitted development, and the restoration obligation sits in the lease rather than in the planning permission, which is a point for the school's property advisers rather than its planning consultant.

If you are assessing a site of this kind and want to see which supporting documents it is likely to need, enter the postcode on PlanScope and work through the constraints first.

This is general guidance, not legal advice, so check the position with your local planning authority or a qualified professional before relying on it. 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.

Frequently asked questions

Can a council refuse a mast on health grounds?

No. Part 16 requires the application to be accompanied by a declaration that the installation, with others at the site, complies with the international guidelines on exposure to electromagnetic fields. National guidance is that where such a declaration is provided, authorities should not question the health aspects of the proposal.

What can the authority actually decide?

Siting and appearance. The permission for the development comes from the Order, so the authority is deciding whether this position and this appearance are acceptable. Objections about pole height, compound position, fencing type, colour finish and planting engage that test. Objections about emissions or property values do not.

How long does the authority have to determine a Part 16 prior approval?

Fifty six days. If it does not notify its determination within that period the development may proceed, so operators plan around the deadline and hard pressed authorities occasionally lose a case to the calendar. Objectors should therefore respond early rather than waiting for a committee date.

Does a playing field location make a difference?

A substantial one. Development affecting land used as a playing field brings in a statutory consultee on sport provision, and that objection engages its own national policy test with its own exceptions. On school sites it usually carries more weight with the decision maker than correspondence about siting.

Must the operator show it considered other sites?

National guidance expects operators to explore sharing existing masts and using existing structures before proposing a new ground based mast, and to provide evidence of the site selection process. Reasons expressed in radio terms are testable. Reasons such as the landlord declined or it was commercially unviable are assertions.

Sources and further reading

telecoms mastpart 16prior approvalschoolsplaying fieldspermitted development

This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.

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