Which reports a telecoms mast prior approval needs
A Part 16 submission is not a planning application. Here is what the council may consider, what the ICNIRP declaration does, and the visual evidence that decides the 56 days.
A telecoms mast application under Part 16 is not a planning application, and the difference decides what goes in the pack. Where the development falls within Class A of Schedule 2 Part 16 of the General Permitted Development Order 2015, permission is already granted by the Order. What the operator applies for is prior approval of siting and appearance, and those two words limit what the council may lawfully take into account.
The telecoms mast planning reports that matter are therefore visual, not technical. Photomontages, alternative sites and finish specification carry the decision. Coverage need and radio-frequency safety do not.
What prior approval limits the council to considering
Class A of Part 16 permits development by an electronic communications code operator, subject to conditions and limits on height, width and location. Where the limits are met, the operator submits details and the authority determines whether prior approval of siting and appearance is required and, if so, whether it is granted.
The 2022 amendments raised the permitted heights and widths for new and upgraded ground-based masts, with lower limits on article 2(3) land, meaning conservation areas, National Landscapes, National Parks, World Heritage Sites and the Broads. Those figures have changed more than once, so read the current text of Part 16 rather than relying on a note from an earlier scheme.
Two consequences follow for the drafting. Arguments about whether the network needs the site belong in the planning statement only as context, because the council cannot refuse on need. And any refusal has to be grounded in siting or appearance, which means the evidence should meet those grounds head-on.
Where the proposal exceeds the Part 16 limits, the route is a full planning application instead, and the assessment opens up accordingly.
The ICNIRP declaration
Every submission should include a signed declaration that the installation, when operational, will comply with the guidelines of the International Commission on Non-Ionizing Radiation Protection for public exposure to electromagnetic fields.
National policy is clear that local planning authorities should not question the need for an electronic communications system, and should not set health safeguards different from the ICNIRP guidelines where a declaration of conformity is provided. Objections on health grounds arrive on almost every mast application, and the declaration is the answer to them.
Include it as a signed document rather than a sentence in the covering letter. Case officers reproduce it in the report, and objectors sometimes claim it was never provided.
Siting and appearance evidence
This is where the work goes. A submission that treats siting and appearance as a formality invites a refusal that then costs six months at appeal.
The material that persuades has four parts:
- Photomontages from agreed viewpoints, showing the mast and every cabinet, at a consistent focal length with the viewpoint locations plotted on a plan.
- An alternative sites assessment listing the sites considered within the search area, with a reason for discounting each, including sharing an existing mast or building rooftop.
- A finish specification naming the colour and material of the column, the antenna shrouding, and the cabinets, with a note on future proofing so that additional apparatus does not appear later without assessment.
- A ground-level plan showing cabinets, ducting, fencing and any street furniture removed or relocated.
Site sharing deserves its own paragraph in the statement. The published code of practice for wireless network development expects operators to consider sharing existing structures before new masts, and an assessment that dismisses sharing in one line is the point objectors and members press hardest.
Where the setting is a sensitive townscape, a formal visual assessment is worth the cost. A Townscape and Visual Impact Assessment sets out the receptors, the viewpoints and the magnitude of change in a structure a planning committee can follow.
Heritage, landscape and designated areas
Part 16 applies on designated land with tighter limits, and the appearance assessment carries more weight there.
Check four things before fixing the position. Whether the site is in a conservation area, where the duty in section 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 applies to the council's decision. Whether any listed building lies in the setting, which brings the section 66 duty and usually calls for a Heritage Statement. Whether a scheduled monument is affected, which needs separate consent from the Secretary of State. And whether the site sits within an aerodrome or defence safeguarding zone, which requires consultation with the safeguarding authority and is a topic PlanScope does not produce a report for.
Street trees are the constraint people miss on verge sites. Excavation for foundations and ducting within the root protection area of a protected tree needs assessment to BS 5837:2012, and the highway authority's arboriculturist will look for it.
Consultation and the 56-day clock
The determination period for a Part 16 prior approval is 56 days from receipt, and if the authority does not give notice of its determination within that period the development may proceed in accordance with the details submitted. That deadline shapes the whole process.
- Carry out pre-submission consultation in line with the code of practice, including notifying schools and hospitals where the site is near one, and record it.
- Submit a complete pack, since a submission that is incomplete on day one is where most disputes about the start date come from.
- Expect the site notice and neighbour notification during the period.
- Respond to officer queries quickly, because there is no mechanism to extend the 56 days by agreement in the way a planning application allows.
- Keep a dated record of what was submitted and when it was received.
Do not treat the deemed consent route as a strategy. A development that proceeds on a technicality attracts complaints, and the operator carries the reputational cost in that authority for years.
Illustrative submission for a 20 m monopole
This example is illustrative. A 20 m slimline monopole with three cabinets on a highway verge in a suburban street, outside any designated area, would usually be submitted with:
- Covering statement setting out the Part 16 route, the limits relied on and the scope of the prior approval.
- Site location plan, site layout plan and elevation drawings of the column, antennas and cabinets.
- Photomontages from four to six viewpoints with a viewpoint location plan.
- Alternative sites assessment, including sharing options considered.
- ICNIRP declaration of conformity, signed.
- Record of pre-submission consultation.
- Arboricultural information where excavation falls within a root protection area.
- A short statement on siting and appearance responding to the local plan's design policies.
A Telecommunications Compliance report pulls the compliance elements of that pack together, and drafts of this kind still need a radio-frequency engineer to confirm the technical declarations before submission.
For a view of the wider document set on a scheme that falls outside Part 16, the index of report types by category is the place to start. 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.
Frequently asked questions
What can a council consider on a Part 16 prior approval?
Siting and appearance only. Permission is already granted by the General Permitted Development Order where the development meets the limits in Class A of Part 16, so the authority cannot refuse on the need for the network, on coverage, or on health grounds. Any refusal has to be grounded in the siting of the apparatus or its appearance.
How long does the council have to decide?
Fifty-six days from receipt of the submission. If the authority does not give notice of its determination within that period, the development may proceed in accordance with the details submitted. There is no agreed extension of time in the way a planning application allows, so a complete pack on day one matters.
Does the ICNIRP declaration stop health objections?
It answers them in policy terms. National policy says authorities should not set health safeguards different from the ICNIRP guidelines where a declaration of conformity is provided, and should not question the need for the system. Objections will still be made, so include the signed declaration as a separate document that the case officer can quote.
Do I need to show alternative sites?
Yes, in practice. The published code of practice for wireless network development expects operators to consider sharing existing masts and rooftops before proposing new structures. List the sites examined within the search area with a reason for discounting each, because a one-line dismissal of sharing is what objectors and committee members press hardest.
What changes in a conservation area?
The permitted heights and widths in Part 16 are lower on article 2(3) land, which includes conservation areas, National Landscapes, National Parks and World Heritage Sites. The council's decision also engages the section 72 duty to preserve or enhance character, so the appearance evidence, finish specification and viewpoint selection all carry more weight.
Sources and further reading
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.