SPD Consultation Statement - Oxford City Council

Telecommunications Supplementary Planning Document 

Regulation 17 1 Consultation 

The draft supplementary planning document was made available for a sixweek 

period public consultation from 27 th April to 8 th June 2007. 

The draft SPD, its Sustainability Appraisal, Initial Consultation Statement 

(Annex I) and Statement of SPD Matters were made available as follows: 

Oxford City Council Offices 

� Ramsay House, 10 St Ebbes Street, Oxford, OX1 1PT 

Public Libraries 

� Centre for Oxfordshire Studies, 2 nd Floor of the Central Library in the 

Westgate Centre 

� Blackbird Leys Library: Blackbird Leys Road, Blackbird Leys, Oxford 

� Bury Knowle Library: Bury Knowle Park, North Place, Headington, 

Oxford 

� Old Marston Library: Mortimer Hall, Oxford Road, Old Marston, Oxford 

� Littlemore Peers Library: Peers Campus, Sandy Lane West, Littlemore, 

Oxford 

� Summertown Library: South Parade, Oxford 

� Cowley Library: Temple Road, Oxford 

The draft SPD, Sustainability Appraisal, Initial Consultation Statement and 

Statement of SPD Matters were also available on our website. 

We sent a letter and representation form (which included details of where the 

documents were available for inspection) to the specific and general 

consultees in line with Regulation 17(2)(b), and those contacted in the preproduction 

consultation including those bodies who had expressed an interest 

in the project through public consultation on the Statement of Community 

Involvement. The specific consultees potentially affected by the SPD were 

also sent copies of the SPD, its Sustainability Appraisal, Consultation 

Statement and Statement of SPD Matters. 

We received representations from 7 organisations and individuals to the draft 

SPD. A summary of the issues raised and how they were addressed in the 

adopted SPD is provided at Annex II. 

1 The Town and Country Planning (Local Development) (England) Regulations 2004) Part 4 Reg 17. 

1

Oxford City Council 

2 

ANNEX I 

Telecommunications Supplementary Planning Document 

INITIAL STATEMENT OF CONSULTATION (Regulation 17 2 ) 

Pre-prodution Stage 

Before preparing the Telecommunications Supplementary Planning Document 

(SPD), a briefing note was prepared which set out a summary background 

and scope of issues proposed to be addressed. These were sent to over 300 

prospective stakeholders (listed in Appendix A). The Planning Control User 

Group Panel were also informed of the commencement of preparation of the 

SPD. 

Following circulation of the briefing note, two stakeholder workshop sessions 

were held. The first workshop session was for representatives of the mobile 

phone network operators, and was well attended. Invitees to the second 

workshop included all elected City Council members, and community contacts 

who could be identified as having a particular interest in telecommunications 

development. Both workshops provided useful feedback and a further steer 

for preparation of the SPD. See Appendix B for a full list of workshop 

attendees. 

A working draft of the SPD was circulated to the City Council’s six Area 

Committees for comment (although only five commented). The comments 

made, and the lead officer response, are set out in Appendix C. 

These approaches accorded with the methods set out for SPD preparation in 

the adopted Statement of Community Involvement (SCI). 

There was a very low response to the briefing note mail-out, although detailed 

written comments were returned by the Mobile Operator’s Association (MOA) 

on behalf of the mobile operators. A number of key issues were also identified 

from the stakeholder workshops. These are summarised below. The way in 

which these have been addressed in the SPD is also outlined. 

Mobile Operators’ Association (on behalf of the network operators) 

Key issue of concern 

Objection in principle to Health 

and Radiation Impact Analysis 

(HRIA). The term itself is 

considered unhelpful, and 

issues of health relating to 

electromagnetic radiation should 

remain in the hands of the 

experts, which is identified by 

How the issue has been addressed 

The principle of HRIA was considered at 

the Oxford Local Plan Inquiry in 2004. 

The Inquiry Inspector supported inclusion 

of the requirement for HRIA in Policy 

CP.24 of the Oxford Local Plan 2001- 

2016, hence this is now adopted policy. 

The SPD has however been carefully 

drafted to ensure the requirement for 

2 The Town and Country Planning (Local Development) (England) Regulations 2004) Part 4 Reg 17.

Government as ICNIRP. Thus 

HRIA should only make 

reference to technical 

information already submitted as 

a matter of course, although 

submission of information on 

radiofrequency profiles would be 

considered as an informal 

submission, on a case-by-case 

basis. 

Stressed that operators are 

unable to take account of all 

background sources of 

radiofrequency in estimating 

cumulative emission levels near 

base stations, although some 

allowance is made for these in 

considering compliance to 

ICNIRP standards. 

Opportunity for annual rollout 

discussions welcomed, and an 

agreed protocol for preapplication 

discussion also 

supported. 

Comment that it will not always 

be possible to provide written 

confirmation of a landowner’s 

unwillingness to provide a site, 

as part of the alternative site 

assessment. However 

agreement that a robust 

justification for rejection of sites 

is appropriate. 

Comment that mast sharing may 

not always be appropriate in 

terms of design. Similarly, it will 

not always be appropriate to 

provide additional mast capacity 

for future users. 

Community stakeholders 

Key issue of concern 

Comment that Wi-fi, Network 

Rail and TETRA networks 

should also be considered in 


HRIA is a positive tool for addressing 

people’s health concerns. 

This point is recognised in the wording of 

the SPD where it deals with HRIA 

requirements. 

These issues are dealt with in detail in 

Section 3 of the SPD. 

This comment has been noted, and a 

procedure to ensure that alternative site 

assessment information required is 

transparent and fair to all concerned is 

included in Section 4 of the SPD. 

Section 4 of the SPD deals with design 

issues. The advice as drafted takes into 

account design and technical constraints, 

whilst stressing the need to consider 

future network capacity needs, and to 

seek site or mast sharing wherever 

possible, for each proposal considered. 

How the issue has been addressed 

The SPD deals primarily with the 

standard GSM and UTMS networks as 

these systems are responsible for almost 

all submissions to the planning 

department. However reference to these 

additional operating systems is made in 

Section 1 of the SPD. 

3

Comment that re-use of 

redundant sites should be 

encouraged. 

Request that annual rollout 

plans should be publicly 

accessible. 

Comment that community 

consultation is a key issue – this 

should be consistent for all 

applications, including proposals 

which fall under permitted 

development. 

Doubt expressed over 

thoroughness of alternative site 

assessment in practice. 

Proximity of schools etc. should 

be considered at this stage. 

Comment that taller masts may 

be better in some cases if it 

means less of them, thus 

opportunities to mast share 

should be considered on a site- 

by-site basis. 

HRIA should emphasise varying 

vulnerability of different people 

(e.g. children v adults), and 

recognise that the duration / 

timings of exposures may be 

important. SPD must recognise 

uncertainty over the health 

impacts of base stations, and 

highlight the very real concerns 

that exist. 

Comment that ICNIRP standard 

is limited, as it does not deal 

with possible non-thermal 

effects of radiation from masts, 

or deal with the impact over 

time. 

Comment that people can’t 

choose not to be exposed to 

radiofrequency emissions. 

Introduction of ‘radiation-free’ 

zones suggested. 

Site and mast sharing is strongly 

encouraged in the SPD. Assessment of 

alternative sites would include any site 

which had fallen out of use by another 

operator, however this eventuality would 

be unusual. 

Dealt with in Section 3 of the SPD. 

Thoroughness of community consultation 

is a key element running through the 

SPD, although consultation should be 

tailored to the application by agreeing on 

a consultation plan (set out in Sections 3 

and 4). Community involvement in 

permitted development proposals is 

encouraged for applicants, but cannot be 

insisted upon. 

Alternative site assessment is dealt with 

in Section 4 of the SPD. Local political 

and social sensitivities such as schools 

forms an important part of the ‘traffic light 

rating’ which is summarised in Appendix 

3 of the SPD. 

Mast shares and providing for shared 

mast infrastructure is dealt with in Section 

4 of the SPD, which encourages this 

general approach. 

Health concerns are dealt with in the SPD 

in the context of HRIA (Section 4). Gaps 

in evidence on health impacts are 

recognised in the context of the 

independent Stewart Report. The general 

approach encourages applicants to 

ensure all relevant health concerns and 

issues are dealt with as part of the HRIA. 

Gaps in scientific knowledge are 

recognised in the SPD. However the SPD 

must conform with the adopted Local 

Plan policy, which sets HRIA in the 

context of ICNIRP. 

This is a general point that goes beyond 

the scope of what the SPD can or should 

achieve. 

4

List of Initial External Consultees 

Residents’ and amenity group 

representatives 

A J Upstone 

A Joyce 

A K Miller 

A Ludlow 

A Oliver 

Andy Boddington 

Angela Goff 

Arthur Rowe 

Auriol Hammer 

B C Warmington 

B Jamesridge 

B Ledger 

Benson Place Residents’ Association 

Beverly Mills 

Bob Ayres 

C Adam 

C Chubb 

C Howse 

C L Maclean 

C Masri 

Carolyn Culliver 

Catrin Roberts 

Chris Clifford 

Christ Church 

Cirady Reid 

Clive Hambler 

Cynthia Thielker 

D Clark 

D Grieveson 

D Haughan 

D Hedges 

D Lawton 

David Lincoln 

Dermot Roaf 

Diana Snape 

Divinity Road Area Residents’ Association 

Dorchester Court (Summertown) Ltd 

Doreen Douglas 

Dr H Ellis 

E Tyler James 

Elizabeth Stamp 

Ellie Seaborne 

Emma Thompson 

F L Warner 

Fielden Grove Residents’ Association 

Folly Bridge Court Management Committee 

Frank Camilleri 

Frank Dann 

Friends, Families & Travellers Community 

Base 

Geoffrey Dart 

GL Salmon 

Graham MacDonald 

H Macdonald (continues next page) 

5 

APPENDIX A 

Katherine Bradley 

Lawrence Kelly 

Lawrence Reynolds 

M Miles 

M Morris 

Margaret Brown 

Margaret Shannon 

Mark Norman 

Martin J Harris 

Marylin Cox 

Megan Turmezei 

Michael Gardner 

Michelle Robins 

Mr C Wilkinson 

Mr G Fitchew 

Mr P Cullen 

Mrs Kennedy 

Mrs L Hughes 

Mrs Money 

Mrs Spooner 

N Parsons 

Nancy Drucker 

National Association Of Health Workers With 

Travellers 

National Association Of Teachers Of 

Travellers 

National Travellers Action Group 

Neville Buckett 

Oxford Pegasus Residents Association 

Oxford Pensioners’ Action Group 

P Gunn 

PAP Vivant 

Park Close Management Company Ltd 

Pat Clare 

Paul Brame 

Paul Pratley 

Pauline Martin 

Peter Bird 

Peter Collins 

Philip Lafeber 

Ray Clare 

Rob Valentine 

Robert Gullifer 

Robert Timbs 

Rolando Ciaravaglia 

Rosamund Weatherall 

S Honigsberg 

Sarah Wood 

Sharon Gellatly 

Sheila Bradbury 

Shirley Henderson 

St John Street Area Residents Association 

Stephen Road 

(continues next page)

Heather Armitage 

Heather Biswell 

Hinksey Park Area Residents’ Association 

Hobson Road Group 

Iffley Fields Residents’ Association 

Iffley Road Area Residents’ Association 

Irish Travellers Movement In Britain 

J Fisher 

J Mace 

J Rawson 

J Rees 

J Washington 

Jackie Raubenheimer 

Jane M Cox 

Jean White 

Jenny Clamp 

Jill Campion 

John Feetam 

Joy Hossington 

Julia Gaspar 

K J Kiefer 

Kate Warburton 

Kate Williams 

Other organisations 

A H Munsey 

A J Stone 

A R Cooper 

A W Wells 

A Westlake 

A Winter 

A2 Housing Association 

ACERT 

Alan Graham 

Andrew Saunders 

B Hunt 

Banner Homes Group 

Barton Wilmore Planning Partnership 

Blue Sky Planning Ltd 

British Land Properties Ltd 

C E Marshall 

C G L Smith 

C Lister 

C Shaw 

Cala Homes (Midlands) Ltd 

Charlie Cleverly 

Chris Wilkes 

Commission For Racial Equality 

Conal Stewart 

D Ames 

D Bennett 

D C Poole 

D Phillips 

D Stanbridge 

David Coates 

David Edwards 

Derek White 

Douglas Riach 

DPSD Consulting Group 

Drivers Jonas 

E Shatford 

(continues next page) 

6 

Stoke Place Residents’ Association 

Stuart Skyte 

Stuart Williams 

Susan Hallett 

T M J Stevens 

T Walton 

T Williams 

Tanja Zeigler 

Terence J Cudbird 

The Gypsy & Travellers Law Reform 

Coalition 

The Gypsy Council 

The Gypsy Council For Health Education & 

Welfare 

The Gypsy Council For Health, Education & 

Welfare 

Tom Seaman 

Tom White 

Tony Joyce 

Una Brown 

V Alexander 

V Vesudevan 

Voira Carr 

Zoe Teale 

L Goffey 

L M Garner 

Linden Homes (Chiltern) 

Littman & Robeson 

Lucas Land & Planning 

M Rogers 

M Slater 

M Warland 

M Waugh 

Maureen Doherty 

McCarthy & Stone Plc 

Mr John Naish 

Mr Tankard 

N Evans 

National Grid Transco 

Nick Caldwell 

Nigel Eggleton 

Nik Lyzba 

Oxfordshire Chamber of Commerce and 

Industry 

P J Hore 

P Johnston 

P Jones 

P O'Donnell 

P Thompson 

Pete Errington 

Philip Thompson 

R Cunningham 

R Cutler 

R H Buckingham 

R Hampshire 

R Morgan 

Rex Knight 

Richard Glover 

Robert McAlpine Ltd 

Royal Town Planning Institute 

RPS Group Plc (continues next page)

English Churches Housing Group 

Fairview Homes Ltd 

FPD Savills 

G Bird 

G Russell 

G Zanre 

H Shayler 

Hives Planning 

Huw Mellor 

J Gloag 

J M B Young 

J Todd 

J V Barkham 

Jamie Wood 

Jo Rice 

Jock Coates 

John Ashton 

K F Day 

K Thomas 

Kim Webster 

Knight Frank 

L Boyce 

Mobile network operators / agents 

Adrian Read (Orange) 

AWA 

Brian Truman (Vodafone) 

Carolyn Wilson (Mono Consultants) 

Madeline Hutton (3) 

Martin Carroll (T-mobile) 

Statutory bodies 

Countryside Agency (M Chessell) 

English Heritage (S Williams) 

English Nature (H Lancaster) 

Environment Agency (S Smith) 

GOSE (Kevin Bown) 

Highway Agency (P Robinson) 

Network Rail (Mr S Mills) 

Oxfordshire County Council 

SEEDA (Jane Griffin) 

Individuals 

A Hobbs 

Anne Darch 

C Turner 

Councillor S Pressel 

Councillor T Hollander 

D A Eaude 

David Penwarden 

F G Shellard 

G Bourne-Taylor 

I James 

J Barratt 

Jonathon Horbury 

Judith Webb 

Judy Chipchase 

Lee Mikhelson 

7 

S Hanley 

S J Smith 

S Ross 

Secretary of State for Health 

Shaun Whittaker 

Stanlo House 

Stephen Bowley 

Summer Fields School 

Susan Aistrup 

T A Scalan 

T Bowron 

Thames Valley Housing Association 

Thames Valley Strategic Health Authority 

The Leys Linx Information Centre 

Tony Woodward 

Tracey-Ann Scanlan 

University Surveyor’s Office 

V Regoczy 

W Sockett 

Worcester College / Kier Developments 

MMO2 Airwave 

Nicola Davies (Mobile Operators’ 

Association) 

Peter Foster (O2) 

Zipcom 

SEERA (C Riddell) 

South Oxfordshire District Council (G Oliver) 

Southern Electric 

Thames Water Property Services (G Cook) 

The Planning Inspectorate (B Linscott) 

Transco Plc 

Vale Of White Horse District Council (K 

Barratt) 

West Oxfordshire District Council (T Rowley) 

Lucy Murfett 

Margaret A Simpson 

Mark Barrington-Ward 

P Mayhew 

Patrick Keiller 

Peter Goodgame 

Philippa Lanchbery 

R H Dalitz 

R J Mansfield 

Sheena Townsend 

Sheila Allen 

Sue Brownhill 

T B DeanM Hobbs 

Wendy Page 

Xanthe Bevis

Workshop attendees 

Workshop 1 – Industry representatives 

Name 

Angela Johnson 

Nicola Whitehead 

Rob Matthews 

Carolyn Wilson 

Nicola Davies 

Andrew Tildesley 

Jane Evans 

Martin Carroll 

Chris Steven 

Workshop 2 – Community representatives 

Name 

Councillor Bob Price 

Tim Treacher 

Jan Treacher 

Garard Van Damme 

Jan Ivimey 

Gaelle Jolley 

8 

Organisation 

O2 

Vodafone 

Vodafone 

Mono Consultants 

Mobile Operators’ Association 

Ericcson Services Ltd (‘3’) 

Ericcson Services Ltd (‘3’) 

T-Mobile 

Orange 

Organisation 

Oxford City Council 

Local resident 


Wolvercote Against Masts 


Oxford Preservation Trust 

APPENDIX B

Comments made at Area Committee 

9 

APPENDIX C 

(Note that the South East Area Committee meeting scheduled for 2 nd April 

2007 was cancelled due to the meeting being declared inquorate.) 

CSW Area Committee (13/3/2007) 

Comment Response 

Cllr Pressell asked whether officers were There are no plans for the Council to regularly 

able to monitor the technical information check or monitor the operation of base 

required of developers and if not, whether stations. The information asked of developers 

this requirement should be included in the is intended to demonstrate transparency, and 


provide a basis for expert checking of 

technical data by outside bodies, should this 

ever be required in future. 

Cllr Price suggested that the need for 

developers to consult with those living near 

sites where it was proposed to locate 

telecommunications equipment should be of 

prime importance. There should be a formal 

commitment on developers to consult with 

residents as well as officers, including 

holding meetings for residents, and this 

should be reflected in paragraphs 21, and 

25-27. 

Cllr Price requested suggested that reference 

should be made in the second sentence of 

paragraph 60 to recreation grounds, play 

areas and similar facilities. 

Cllr Armitage questioned whether the 

following Operators’ 10 Commitments are still 

being complied with: (3) industry’s approach 

to site sharing, (4) develop professional 

workshops, (10) develop standard supporting 

information. 

Cllr Armitage suggested that reference 

should be made in the document to the need 

for operators to share sites as far as 

possible. 

The SPD already encourages pre-application 

discussions with the local community, in line 

with the Statement of Community Involvement 

and the Code of Best Practice on Mobile 

Phone Network Development. Suggest 

however placing greater emphasis on local 

community involvement, to further encourage 

the operators to fully involve local 

communities in pre-application and rollout 

discussions, as editorial changes. 

Suggested amendment will be included in 

final draft. 

The network operators are still publicly 

committed to the 10 Commitments. Some 

operators have indicated their willingness to 

host public ‘drop-in’ sessions, and this could 

be investigated further on Members’ request. 

A standard information form is already 

submitted with all planning applications as set 

out in the Code of Best Practice. 

Suggest that text of SPD could be 

strengthened to further encourage site 

sharing, with particular reference to sharing of 

street furniture (such as monopoles) by more 

than one operator where appropriate. 

North East Area Committee (20/3/2007) 


The Committee asked for the following The Committee’s comments on these points 

comments to be considered by the Executive of clarification will be taken full account of in 

Board: 

making final editorial changes to the SPD 

prior to publication. On the first point relating 

Paragraph 25 – need to enforce adequate to paragraph 25, the Council has no power to 

consultation. 

impose pre-application consultation; it would 

therefore not be appropriate to refer to 

Paragraph 43 – guidelines on mast sharing ‘enforcing’ this (although see response to 

need to be clarified. 

similar point by Cllr Price above).

Paragraph 47 – need to ensure any 

‘technical’ information is properly explained. 

Paragraph 49 – reference to environmentally 

sensitive sites welcomed. 

Paragraph 52 – reference to the need for 

regular maintenance of masts welcomed. 

East Area Parliament (21/3/2007) 


Cllr Simmons said that the SPD should It is the Officers’ view that such a requirement 

include a requirement that the Health and would be unenforceable and potentially 

Radiation Impact Analysis should be 

unreasonable, as it goes beyond Policy CP.24 

commissioned by the City Council from an in the Oxford Local Plan, and applicants 

independent company, and paid for by the would be unlikely to cooperate with such a 

telecoms company. 

request. Suggest therefore that no change is 

made to SPD on this point. 

Cllr Simmons also requested a requirement 

that ongoing monitoring should be 

commissioned by the City Council from an 

independent company and paid for by the 

telecoms company. 

Cllr Young requested that the final bullet 

point of paragraph 60 of the draft 

Telecommunications SPD be clarified to 

define what are “reasonable” technical 

constraints, in respect of non technical 

explanation of RF contour, in accordance 

with the national regulations. 

10 

The adopted Policy CP.24 in the Oxford Local 

Plan contains no reference to conditions 

requiring ongoing monitoring of emissions. It 

would not therefore be appropriate to include 

this requirement in the SPD. No change 

suggested. (Note: Executive Project Officer 

has inserted paragraph as an editorial change 

which partially addresses this comment.) 

This point will be clarified as part of the 

editorial changes to the document. 

Cowley Area Committee (4/4/2007) 


Cllr Timbs suggested that the SPD should The suggested change cannot be supported 

state that telecommunications masts should as it would be at odds with national planning 

not be permitted near schools and playing policy (PPG8). The SPD refers to sensitive 

fields. 

siting of antenna in relation to schools and 

nurseries, in paragraph 60. 

The Committee are recommending to 

Executive Board that any proposal / 

application to install telecommunications 

equipment on Oxford City Council owned 

property, should first come to the relevant 

Area Committee to comment on. 

The relevant Area Committee can call in any 

planning or prior approval application to 

determine. However the committee’s 

recommendation is more relevant to Property 

Asset Management officers rather than 

Planning. 

North Area Committee (5/4/2007) 


Cllr Campbell said he was concerned at a Comment will be passed on to Planning 

possible reduction in consultation and keen Control officers. 

for letters sent during the formal consultation 

period to be circulated as widely as possible. 

Cllr Hollander requested that ‘local 

There is no set definition / boundary for

households’ referred to in paragraph 34 of 

the SPD be more clearly defined. 

Cllr Brundin asked for amendment to 

paragraph 34 to state that “the City Council 

may will ask the developer to display a notice 

on site. 

Cllr Armitage made the general comment 

that it would be beneficial to promote this 

document to other Oxfordshire Districts. 

11 

neighbour consultation relating to a given site. 

However paragraph will be further clarified in 

line with the procedure used by Planning 

Control. 

Change will be made as requested to read: 

“the City Council will ensure that a site notice 

is displayed on site…” 

Comment noted.

Table of consultation representations on Telecommunications SPD 

12 

ANNEX II 

Note that some paragraphs in the SPD have been renumbered 

Section/ Objector/ Summary of representation Officer response Change(s) to SPD resulting 

paragraph/ Comment 

Page/ 

heading 

Ref. no 

WHOLE DOCUMENT 

Whole doc. Mobile 

Operators’ 

Association 

TSPD4/1 

Whole doc. Jack Straw’s 

Lane 

Association 


Whole doc. Jack Straw’s 

Lane 

Association 


Generally support Council’s 

commitment to preparation of a 

Telecommunications SPD and 

consider much of its content to be in 

accordance with PPG8 and the Code 

of Best Practice on Mobile Phone 

Network Development. 

Generally agree with good intentions of 

the SPD and OLP Policy CP.24 to 

balance environmental, visual, amenity 

and health concerns with the future 

development needs of the mobile 

technology networks. 

Support mast and site sharing and use 

of existing buildings where appropriate. 

Support noted. 



Whole doc. SEERA The Assembly considers that the SPD Conformity noted.

Whole doc. English 

Heritage 

TSPD7/1 is in general conformity with the 

adopted RSS and also with the 


Whole doc. Oxford Green 

Belt Network 


emerging RSS. 

EH welcomes the production of the 

SPD, which is generally commendably 

clear in its advice. 

Congratulate Planning Policy team on 

producing a very clear, comprehensive 

and useful document. 

Section 2: PROCEDURE FOR NEW PROPOSALS 

Paragraph 

12,19 

Jack Straw’s 

Lane 

Association 


Concerned that justifiable local 

objections to the siting of a mast could 

be overridden by the need to take 

account of national planning policies 

and Government advice. If there is to 

be a progressive relaxation of 

regulations governing the telecoms 

industry, the ‘effective and meaningful 

public consultation’ that the City 

Council hopes to see may well be hard 

to achieve. 

Section 3: PROCEDURE FOR NEW PROPOSALS 

Paragraphs 

21,23,28 

Mobile 

Operators’ 

Association 


In accordance with Reg.5 of the 

Electronic Communications Code 

(Conditions and Restrictions) 2003, a 

code operator must give one month’s 

written notice of permitted 

development works. 

13 



Planning regulations require that 

planning authorities must give 

due weight to national planning 

policies and guidance, and this is 

set out in the SPD to provide 

clarity on the decision-making 

process. 

Relevant wording changed, i.e. 

‘28 days’ substituted for ‘1 month’ 

to align with regulations referred 

to. 

No change. 

Change wording paragraph 21: 

“…the City Council still expects 

28 days’1 calendar month’s 

prior notification…” 

& paragraph 23: “The City 

Council will expect to be 

notified of any such

Paragraph 

28 

Paragraph 

35 

Paragraph 

37 

English 

Heritage 


Oxford Green 

Belt Network 


Mobile 

Operators’ 

Association 


Suggest that reference to the need for 

listed building consent needs to clarify 

that some listed ecclesiastical buildings 

benefit from ecclesiastical exemption. 

An appendix listing these, and detailing 

relevant procedures, would be useful. 

Support statement about Oxford’s 

character, with reference to sensitive 

areas of open landscape, and the need 

to take this into account in the ‘traffic 

light rating’. 

Strongly object to requirement to 

requirement for HRIA to be submitted 

at pre-application stage, as this is 

unnecessary, has resource 

implications and may not progress to a 

full application. 

14 

Agree that this point needs 

clarifying. The suggested 

appendix however would be too 

detailed and unnecessary for the 

purposes of this SPD. 


Paragraph 37 of the SPD 

expects submission of a draft 

HRIA, to outline the format of 

information to be submitted. This 

allows officers to advise further 

on a specific HRIA at an early 

development at least 28 days’1 

calendar month before it takes 

place…” 

& paragraph 38 (renumbered 

39): “The City Council will 

expect to be informed of all 

permitted development 

proposals at least 28 days1 

calendar month before work 

starts on site…” 

Add new paragraph after 

paragraph 28: “Buildings in 

ecclesiastical use may be 

exempt from requiring Listed 

Building Consent. Prospective 

applicants can consult the City 

Council’s Conservation team 

for further advice.” 

No change.

Paragraph 

37 

Paragraph 

39 

Mobile 

Operators’ 

Association 


Mobile 

Operators’ 

Association 


Provision of site specific plans and 

elevations at pre-application stage is 

inappropriate. To enter into preapplication 

discussion with full plans 

indicates that a decision has already 

been made. 

Requirement for operators to submit 

full list of supporting information 

(Appendix 4 of SPD) for permitted 

development proposals rated red or 

amber under TLM is particularly 

onerous, and exceeds PPG8 and code 

of Best Practice. 

15 

stage, if appropriate, to avoid 

delays at the formal application 

stage due to submission of an 

inadequate HRIA. 

The Code of Best Practice 

(paragraph 34) expects operators 

to provide details at the preapplication 

stage of the location 

and type of telecoms apparatus 

proposed, and design options for 

particular sites. The SPD is in 

line with, and clarifies further on, 

this advice. 

Submission of supporting 

information helps the Council to 

check the permitted development 

status of a proposal. The Council 

is also committed to notifying 

local ward members and 

residents of such permitted 

development. It is therefore 

beneficial for the Council to have 

an appropriate level of 

information, both to assess 

proposals against the GPDO 

(and avoid possible enforcement 

action in future), and to inform 

other interested parties of the 

proposal should details be 

No change. 

Wording changed (paragraph 

renumbered 40): “…The City 

Council will expectencourage 

operators to submit scale plans 

and elevations at the time they 

inform the Council of their 

proposals. Operators shouldare 

further encouraged to submit 

supporting information in 

accordance with checklist in 

Appendix 4, where the 

proposal would be rated amber 

or red under the TLM.

Section 4: SUBMISSION CONTENT 

Paragraph 

50 

Paragraph 

50 

Paragraphs 

57 and 60 

Paragraph 

57 

Paragraph 

58 

Mobile 

Operators’ 

Association 



Belt Network 



Belt Network 



Belt Network 


English 

Heritage 


Although the submission of 

photomontages can be helpful in 

certain circumstances, the need to 

submit these with every planning 

application for telecommunications 

development is onerous to the 

operators. Alternative wording 

suggested. 

Support requirement for applicants to 

submit a photo montage. 

Support statement that mobile phone 

masts should always be located and 

designed to respect their context and 

minimise their visual impact. 

Support reference to the need for a 

design statement to help minimize 

visual impact. 

Suggest that advice on the planning 

tests for conservation areas 

(preservation or enhancement of 

special character) should have an 

explicit reference – a dedicated 

paragraph would be more effective, 

16 

requested. However wording 

changed so as not to mislead. 

Given the highly sensitive nature 

of telecommunications 

development in Oxford, and 

Oxford’s often unique landscape 

character, photomontages are a 

highly valuable tool in this 

context. The wording as drafted 

sets out the City Council’s 

approach clearly and 

unambiguously. 




Reference to impact on 

conservation areas in paragraph 

58. Appendix 2 cross refers to 

OLP Policy HE.7 (Conservation 

Areas and their settings). In 

addition, paragraph 35 refers to 

No change. 

No change.

Paragraph 

58 

Paragraph 

60 

Paragraph 

62 

Paragraph 

62 Practice 

Note: Tree 

masts 

Paragraph 

62 Practice 

Note: Tree 

masts 


Belt Network 



Belt Netowrk 


Highways 

Agency 


Mobile 

Operators’ 

Association 


Mobile 

Operators’ 

Association 


dealing with unlisted buildings in 

conservation areas. 

Pleased to note reference to Green 

Belt as meriting special regard so far 

as siting and design are concerned. 

Hoped that this will strengthen 

Council’s position on this matter. 

Support reference to the importance of 

choosing a colour to suit the 

background surroundings. 

Recommend that line 7 should read: 

“The City Council will consult the 

localrelevant highway authority…” 

Unclear from point 3 whether existing 

trees is required to be protected by a 

TPO, or whether the Council would 

subsequently promote such an order. 

Point 3 contradicts point 4, as condition 

re tree pruning can only be applied 

where trees are within control of 

applicant; furthermore, numerous 

treeworks applications would be 

needed for pruning of TPO trees. 

17 

the importance of conservation 

areas in respect of informal 

consultation (‘traffic light rating’). 

It is considered that further 

reference would only duplicate 

the policies of the OLP. 



Agree to text change, for clarity. Text changed to refer just to 

“the highway authority”. 

Agree that wording needs to be 

made clearer. 

Agree that approach needs 

clarifying. However TPOs for 

screening are legitimate as 

described in Government 

guidance: “Trees may be worthy 

of preservation… because they 

(Paragraph renumbered 64) 

Change wording of point 3: 

“The City Council may apply a 

tree preservation order (TPO) 

to surrounding trees, to ensure 

appropriate screening.” 

Change point 4: “The Council 

will apply conditions to 

subsequent TPO treeworks 

applications to ensure 

appropriate pruning.”

Paragraph 

63 

Paragraph 

67 

Highways 

Agency 


Mobile 

Operators’ 

Association 


Hence TPO should only be promoted 

to protect trees that significantly 

contribute to character of the area, not 

just as screening. 

Recommend that line 6 should read: 

“…and subject to the legal, technical 

and policy requirements of the 

localrelevant highway authority.” 

Should reiterate full Government 

advice in PPG8 on health issues, that it 

is ultimately a matter for the courts 

whether this consideration is material, 

and that it is for the decision maker 

(planning authority) to determine what 

weight to attach to such considerations 

in any particular case. Should also 

state that it is the Government’s firm 

view that the planning system is not 

the case for determining health 

safeguards, and it remains the 

Government’s responsibility to decide 

what measures are necessary to 

protect public health; if a mobile phone 

base station meets the ICNIRP 

guidelines for public exposure it should 

not be necessary for a local planning 

authority to consider further health 

aspects and concerns about them. 

3 See paragraph 3.2 of Tree Preservation Orders: A Guide to the Law and Good Practice (DTLR, 2000) 

18 

serve to screen an eyesore or 

future development.” 3 

Agree to text change, for clarity. Text changed to refer just to 

“the highway authority”. 

(Paragraph renumbered 65) 

PPS12 makes clear that local 

development documents should 

not merely repeat national 

planning policy statements. The 

SPD states the Council’s 

approach taking due account of 

Government guidance contained 

in PPG8, and explicitly accepts 

ICNIRP guidelines as an 

appropriate precautionary 

standard. However it is not the 

purpose of the SPD to reproduce 

the Government’s detailed views 

as stated in PPG8. 

No change.

Paragraphs 

67-71 

Paragraph 

68 

Prargraph 

69 

Paragraph 

69 

Jack Straw’s 

Lane 

Association 


Mobile 

Operators’ 

Association 


Mobile 

Operators’ 

Association 


Mobile 

Operators’ 

Association 


This view is supported by the National 

Radiological Protection Board. 

We would like to draw attention to the 

opinion of Prof. Challis, chairman of 

the Mobile Telecommunications Health 

Research Programme, that further 

research is needed before mobile 

phone technology can be declared free 

from any health hazard. 

We welcome the Council’s statement 

in paragraph 68 that the City Council 

accepts ICNIRP guidelines as an 

appropriate standard. 

Operators were not afforded 

opportunity to provide a generic 

example of a proposed HRIA prior to 

issuing of draft SPD. 

Strongly object to requirement for 

applicants to state how, and to what 

degree, the proposal complies with 

ICNIRP standards by submitting a 

HRIA. It is not appropriate for planning 

authorities to accept or reject planning 

applications based on their perspective 

of perceived health risk. 

19 

Comment noted. No change. 


The MOA have submitted their 

suggested HRIA template on 16 th 

July 2007, to feed into the final 

draft. 

The adopted OLP states in 

paragraph 2.22.4 “[Additional 

information] should be submitted 

in the form of a HRIA which 

provides details on the expected 

microwave and other radiation 

from the proposed equipment 

and how this relates to the EU 

ICNIRP guidelines” Therefore the 

guidance on HRIA contained in 

the SPD as drafted is in 

conformity with the adopted 

No change. 

No change.

Paragraph 

69 

Paragraph 

69 

Paragraph 

71 

Mobile 

Operators’ 

Association 


Mobile 

Operators’ 

Association 


Mobile 

Operators’ 

Association 

It is not the place of operators to 

collate and summarise current 

scientific research on the effect of RF 

exposure. It is certainly not the place of 

local authorities to assess such 

information and set their own exposure 

limits. 

The requirement for an RF contour plot 

on an OS base map would be 

extremely difficult for the operators to 

comply with and should be removed. 

This may serve to increase, rather than 

address, community concerns. 

Reference in SPD to optimum beam 

pattern for addressing health concerns 

is likewise inappropriate and should be 

removed. 

Strongly object to paragraph 71 in the 

SPD, this paragraph should be 

removed. As this requirement 

20 

development plan. 

The SPD as drafted states that 

HRIA should include reference to 

appropriate up-to-date scientific 

research on RF exposure and 

health. This is important to 

ensure applicants provide a 

balanced context to site specific 

information on RF emissions, 

and constitutes knowledge with 

which operators should be 

entirely familiar. 

The City Council understands 

that the RF contour plot is a 

readily available and commonly 

used software tool, and 

considers this appropriate for 

providing information on RF 

emission in a transparent and 

easily understandable way. 

However wording of SPD 

amended to recognise that a 

text-and-table RF Profile may be 

acceptable in some cases. 

References to optimum beam 

pattern also amended for clarity. 

The City Council considered this 

request at its Council Meeting on 

3 rd September 2007 and decided 

No change. 

Paragraph 69 has been 

amended by new paragraphs 

71-74, to refer to RF Profile as 

possible alternative to RF Map 

Plot, only if agreed with the 

Planning department. New 

paragraph 73 clarifies that the 

City Council will expect 

submission of an RF Map Plot 

alongside applications on or 

near a school and its grounds. 

Retain paragraph 71 

(renumbered 75) amended to 

read:

TSPD4/15 duplicates the effects of other controls, 

and is not consistent with national 

planning policies, it contradicts Circular 

11/1995: Use of Conditions. It would 

also impose an unnecessary financial 

burden on the operator. 

21 

to keep this paragraph in the 

SPD, amended to remove 

reference to regular monitoring in 

recognition that regular 

monitoring may be onerous. 

APPENDIX 2: SITING AND DESIGN: RELEVANT OXFORD LOCAL PLAN (OLP) POLICIES 

Appendix 2 Natural 

England 


Support references to Oxford’s 

watercourses, trees and hedgerows, 

biodiversity value, SACs, SSSIs, 

SLINCs, LNRs and wildlife corridors in 

considering siting and design. However 

it is recommended that reference is 

also made to OLP Policy NE.21 – 

Species Protection. 

Agree that reference to this 

additional OLP policy would be 

beneficial. 

APPENDIX 3: SUMMARY OF TRAFFIC LIGHT MODEL FOR PUBLIC CONSULTATION 

Appendix 3 Natural 

England 


Natural England would be concerned 

about any proposals for ground-based 

towers close to or within statutorily 

designated nature conservation sites 

(SSSI/SAC) which could have an 

adverse impact. Would wish to be 

consulted at an early stage for such 

proposals. 

Information in Appendix 3 

reiterates national advice the 

Code of Best Practice on Mobile 

Phone Network Development 

(Annex D), and should not 

therefore be altered. However 

suggest additional sentence at 

end of paragraph 34 to clarify 

role of other bodies in preapplication 

discussions. 

“Conditions may, in certain 

cases, be imposed on a 

planning permission for 

telecommunications 

development to require 

regularadditional monitoring of 

electromagnetic frequency 

emissions.” 

Add to table column 2 row 2 

“Species Protection (NE.21)”. 

Add sentence after end of 2 nd 

sentence in paragraph 34 

(renumbered 35): “Developers 

should also consult statutory 

and other expert bodies at the 

pre-application stage as 

appropriate.”

SUSTAINABILITY APPRAISAL 

SA 

Paragraphs 

5,6 

Natural 

England 


SA Table 3 Natural 

England 



England 



England 

Recommend adding objective to 

maintain and enhance biodiversity and 

sites of importance for nature 

conservation. 

Makes no reference to possible 

conflicts with nature conservation. 

Some types of telecommunications 

facilities could potentially involve loss 

of wildlife habitat or species – should 

be acknowledged in table. 

Sites should not be targeted for new 

development without a prior survey of 

their biodiversity potential, to avoid 

excessive impact or mitigation 

incorporated. We would advise that full 

species surveys should be undertaken, 

together with methodology and 

mitigation strategies, with 

recommendations for licensing if 

required for protected species. 

The selection of any greenfield 

locations should only be made after a 

22 

The objectives set out in 

paragraph 6 of the SA are drawn 

from the OLP and SPD project 

mandate. It would be inconsistent 

to change these objectives at this 

stage of producing the SPD. 

Table 3 identifies where the SPD 

objectives could conflict with SA 

objectives, including SA 

Objective 13 – to conserve and 

enhance biodiversity. The 

purpose of this table is not to 

identify the negative effects of 

the development itself; impacts 

on nature conservation are dealt 

in the SPD (paragraph 58). 

Appendix 2 cross-refers to 

potentially relevant policies in the 

OLP, including on impact on the 

natural environment. 

Appendix 2 cross-refers to 

potentially relevant policies in the 

No change. 

No change. 

See changes made to 

paragraph 34 (renumbered 35) 

of the SPD to encourage preapplication 

consultation with 

expert bodies, and to Appendix 

2 – additional reference to OLP 

Policy NE.21 – Species 

Protection. 

No change.

TSPD5/6 survey and evaluation of each site’s 

nature conservation value. Particular 

concern over ground-based towers 

close to or within SSSIs or SACs which 

could have adverse impact on their 

Natural 

England 


List of Respondents 

nature conservation. 

Should note British and European 

legislation to protect bats and their 

breeding and resting places. 

23 

OLP, including on SSSIs and 

SAC (Policy NE.18), and change 

proposed to refer to Policy 21 

(species protection). 

This point in the SA will be 

carried through as an addition to 

the SPD. 

New paragraph 60 added: 

“Any proposal affecting a roof 

structure should be 

accompanied by an 

independent ecological survey, 

unless the applicant has 

otherwise satisfied the City 

Council that no bats are 

present. The survey should 

assess impact on any bat 

population, and demonstrate 

full mitigation.” 

Our reference Respondent (Agent) Our reference Respondent (Agent) 

TSPD1 English Heritage (South East Region) TSPD5 Natural England 

TSPD2 Highways Agency TSPD6 Oxford Green Belt Network 

TSPD3 Jack Straw’s Lane Association TSPD7 South East England Regional Assembly 

TSPD4 Mobile Operators’ Association* 

*The Mobile Operators’ Association represents the five main UK telecommunications operators:T-Mobile, Orange, O2, Vodafone and 3

SPD Consultation Statement - Oxford City Council

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