Distance matters. Don’t allow a ban on distance checks in planning.
People living in the UK have just days to respond to the British government’s proposed changes to the National Planning Policy Framework which include a number that are deeply concerning relating to the siting of 5G masts.
Take 2 Minutes To Assert Your Right to Public Health Protection
Send a quick copy-and-paste email to demand public health protections are strengthened – Deadline: March 10
Below, you will find first a quick copy-and-paste email demanding that public health protections be strengthened for you to use.
And if you are more aware of the science and issues and would like to apply legal accountability, there is a longer template for you to copy, paste and add your concerns to after the shorter version.
Short Version
[Reply to the government consultation by emailing:] [email protected]
[Subject line:] Response to NPPF Consultation – Question 95
[Copy and paste the following:]
‘I strongly disagree with the proposed drafting of CO1 and CO2.
The current wording allows public health compliance to be treated as satisfied by self-certification, without defined evidential standards or scrutiny. Certain risks — including those affecting individuals with metal implants — fall outside the scope of the ICNIRP public exposure guidelines.
A year-long scientific review by the New Hampshire Commission recommended that new wireless antennas be placed at least 500 metres from homes, schools and workplaces, based on the evidence (New Hampshire Commission, 2020 Final Report). Proximity to masts and small cells should not therefore be treated as automatically immaterial at planning stage.’
Longer Version | NPPF Consultation response for people who are more aware of science and issues and want to apply legal accountability
Pasted below the solid line are relevant extracts from both documents, but here are links for your reference:
Official Consultation Main Page
https://www.gov.uk/government/consultations/national-planning-policy-framework-proposed-reforms-and-other-changes-to-the-planning-system
You scroll down to find:
A) National Planning Policy Framework: proposed reforms and other changes to the planning system
- Chapter 9 page 38 policy context and the relevant QUESTIONS 93, 94, 95
- TI1 and TI2 are the Government’s consultation pointers to the changes in policy, but the actual proposed draft wording of the Telecoms NPPF section is CO1 and CO2 on p 45-48 in document B
B) National Planning Policy Framework: draft text for consultation
- This is the document you quote when referring to the actual draft policy wording.
Consultation Questions 93 and 94 relate primarily to rollout and siting mechanics. Our primary concern relates to how environmental and public health impacts are assessed. For that reason, we suggest focusing your detailed response on Question 95.
Suggestion As to How to Respond to Questions 95
While many find it easier to respond by email, you can respond online too.
(To respond online, click https://consult.communities.gov.uk/planning/proposed-reforms-to-the-national-planning-policy-f/ and scroll to bottom of page to start the process)
Email option
[Send EMAIL to:] [email protected]
[Subject line:] Response to NPPF Consultation (Chapter 9 – Telecommunications) – Question 95
[Email content:]
Dear Planning Policy Consultation Team,
Please treat this email as my formal response to
Question 95 of the current NPPF consultation (Chapter 9 – Supporting high quality communications).
I do not respond to all questions. This submission relates specifically to Question 95.
[Copy and paste this verbatim before inserting your own evidence:]
The proposed drafting of CO1 and CO2 alters the mechanism by which environmental and public health impacts of telecommunications infrastructure are assessed. Under environmental law principles, including the Aarhus Convention, the environmental implications of a proposed policy change must be identified and assessed at consultation stage before adoption. Accordingly, the environmental and public health concerns set out below must be considered as part of this policy-level assessment, rather than deferred to individual planning decisions.
If compliance with public health protections is to be demonstrated primarily through self-certification, without defined evidential standards, methodology or scrutiny criteria, this represents a substantive change in how environmental effects are evaluated. That change itself requires assessment.
In responding to Question 95, I therefore set out the environmental and public health risks which I consider must be capable of assessment prior to authorisation, and explain why the current drafting of CO1 and CO2 does not provide adequate mechanisms for that assessment to occur.
[Then add your own evidence]
After the above wording, insert your own evidence and concerns.
This may include (for example):
- Electromagnetic hypersensitivity (EHS)
- Impacts on people with metal implants or medical devices
- ICBE or other scientific critiques of ICNIRP limits
- Impacts on children
- Impacts on elderly or medically vulnerable persons
- Evidence relating to cancer or chronic illness
- Effects on birds, bees, insects, animals or plant life
- Cumulative exposure concerns
- Emerging technology concerns (e.g. standalone 5G)
Explain clearly:
- What the environmental or public health risk is.
- What evidence you believe must be assessed.
- Why the current drafting of CO1 and CO2 does not ensure that this evidence will be properly evaluated before approval.
Note – Why This Framing Matters
It enforces legal obligations without needing to be explicit about the obligations themselves which the drafting is bypassing.
Policy drafting should ensures that environmental and public health risks are properly assessed and weighed before authorisation, rather than being reduced to a certification exercise.
And this consultation stage is the point at which that must be addressed.
There are 2 layers I) this consultation is a doorway to risk assessment and the policy drafting for LPA decision making should itself should include risk assessment.- this has been outlined in our submissions, so doesn’t need repeating.
FOR your reference to save you looking it up, please see below the wording of the relevant sections of the 2 NPPF relevant consultation documents:
DOC A containing the consultation Questions
Chapter 9: Supporting high quality communications
This section is intended to replace Chapter 10 of current Framework on supporting
high-quality telecommunications infrastructure. It does not include plan-making
policies, as we consider that the relevant considerations can be addressed sufficiently
through national decision-making policies. The decision-making policies largely
comprise a redraft of the current Framework provisions, to reflect the policy-based
approach to the draft Framework, although it has also been updated to reflect changes
in telecommunications technology.
The government’s 10 Year Infrastructure Strategy (UK Infrastructure: A 10 Year
Strategy – GOV.UK) sets out how the delivery of high-quality digital infrastructure is
essential to the UK’s growth, productivity, and the resilience of public services. The
upgrade to 5G Standalone (5GSA) represents a critical step in meeting the capacity
required to support public use, businesses, and data-intensive technologies such as
artificial intelligence. By setting clear expectations for how planning decisions should
support network expansion and upgrades, the revised policies provide the foundation
for achieving nationwide coverage of 5G and gigabit broadband. In doing so, they
underpin the government’s ambition for world-class digital connectivity and securing
the economic and social benefits that depend on it.
National decision-making policies
TI1: Proposals for Telecommunications Infrastructure
This policy consolidates aspects of current Framework paragraphs 119-123. The
redrafted policy makes clear that existing sites should be considered before new
infrastructure is proposed on undeveloped sites. It also emphasises that infrastructure
should be sited and designed to minimise adverse impacts and that additional
requirements should not be imposed on applicants where these do not relate to
planning matters.
TI2: Telecommunications Infrastructure – Supporting Information
This policy also draws together elements of paragraphs 119–123 of the current
Framework. It sets out clear expectations for the supporting information that should
accompany a planning application, without introducing any new requirements for
applicants.
93) Do you agree that the updated policies provide clearer and stronger support
for the rollout of 5G and gigabit broadband? Strongly agree, partly agree,
neither agree nor disagree, partly disagree, strongly disagree.
a) Please provide your reasons, particularly if you disagree.
59
94) Do you agree the requirements for minimising visual impact and reusing
existing structures are practical for applicants and local planning
authorities? Strongly agree, partly agree, neither agree nor disagree, partly
disagree, strongly disagree.
a) Please provide your reasons, particularly if you disagree.
95) Do you agree the supporting information requirements are proportionate and
sufficient without creating unnecessary burdens? Strongly agree, partly agree,
neither agree nor disagree, partly disagree, strongly disagree.
a) Please provide your reasons, particularly if you disagree
B Proposed NPPF policy wording
- 9. Supporting high quality communications
The objective of the policies in this chapter is to enable the expansion and upgrading of telecommunications infrastructure to meet changing technological, social, business and security requirements (including securing coverage of standalone 5G in all populated areas, and nationwide gigabit-capable broadband), in ways which limit an unnecessary proliferation of equipment and respect important environmental safeguards.
National decision-making policies
CO1: Proposals for telecommunications infrastructure
- Development proposals for the expansion or upgrading of electronic telecommunications networks, including (but not limited to) next generation wireless technologies (such as standalone 5G), gigabit-capable broadband connections and supporting infrastructure such as fibre exchanges, should:
a. Use existing masts, buildings and other structures already employed for this purpose, unless there is no reasonable opportunity to do so (taking into consideration meeting consumer needs, the efficient operation of the network and providing reasonable capacity for future expansion);
b. Be sited and designed to minimise the visual impact of the proposals, especially in situations where a new site or structure is proposed;
c. Not result in cumulative exposure to non-ionising radiation exceeding International Commission guidelines37 when the development is operational; and
d. Not cause significant and irremediable interference with other electrical equipment, air traffic services or instrumentation operated in the national interest.
- In assessing proposals for telecommunications infrastructure, local planning authorities should not require minimum distances to be maintained between telecommunications infrastructure and other development, seek to prevent competition between different operators, question the need for the expansion or upgrading of telecommunications networks, or use health safeguarding standards different from the International Commission guidelines on non-ionising radiation protection.
Page 48
CO2: Supporting information for telecommunications infrastructure proposals
- Development proposals for electronic telecommunications infrastructure (including applications for prior approval under the General Permitted Development Order, as amended) should be supported by the following, where relevant:
a. Information on the outcome of pre-submission consultation with organisations with an interest in the proposed development (in particular with the relevant body where a mast is to be installed near a school or college, or within a statutory safeguarding zone surrounding an aerodrome, technical site or military explosives storage area), summarising the issues raised and how these have been addressed;
b. Where a new site or structure is proposed, evidence that the applicant has sought to keep the number of these to a minimum in accordance with policy CO1(1)(a). This should include evidence that the possibility of erecting any antennas on an existing building, mast or other structure has been explored; and
c. Evidence in support of the requirements in policy CO1(1)(c) and (d), including a statement that self-certifies that the cumulative exposure, when operational, will not exceed International Commission guidelines on non-ionising radiation protection.
37 International Commission on Non-Ionizing Radiation Protection guidelines.
