Select Committee on Trade and Industry Appendices to the Minutes of Evidence


Memorandum submitted by Saleem Shamash BSc (Hons) MRICS MRTPI, National Planning Manager, Crown Castle International


  1.1  I am Saleem Shamash and I am a Member of the Royal Institution of Chartered Surveyors and a Member of the Royal Town Planning Institute. Since August 2000 I have been the National Planning Manager at Crown Castle International. Before that I held senior positions in private practice. I have specialised in planning and telecommunications since 1986 and believe I am the longest established planning professional practising in this specialist field. When in private practice, I advised Mercury Communications Ltd, BT Cellnet, Orange and Vodafone, all telecommunications code systems operators. In addition, I have advised Reuters and INMARSAT on telecommunications installations required by them.

  1.2  I have handled planning applications and appeals throughout the UK sufficient in number to establish at least a first generation network. Last year alone, I handled 13 planning appeals, 11 of which were allowed, two following a public inquiry.

  1.3  I have seen how the legislation and planning policy has evolved since privatisation took place in the telecommunications sector and have advised operators about these changing requirements.

Expert Submissions

  1.4  Through professional experience, I am thoroughly acquainted with the issues of particular concern to this Committee. As a Chartered Surveyor, I have prepared my evidence in accordance with the current Practice Statement and Guidance Notes—Surveyors Acting as Expert Witnesses, issued by the Royal Institution of Chartered Surveyors. To assist the Committee I should emphasise that I have sought to provide objective views, and not an industry stance.

  1.5  My evidence therefore gives my independent expert opinion on the planning issues before the Committee and includes or makes reference to all the facts and matters I consider relevant.


  2.1  Telecommunications development presents a significant challenge in finding an appropriate balance between environmental and operational considerations.

  2.2  The UK wide consultations on telecommunications mast development are ultimately about providing the legislative and planning policy framework to strike that balance. Crown Castle International has submitted comprehensive responses to all the consultation papers and the Committee has seen the response submitted in respect of the Department of Environment, Transport and the Regions (DETR) consultation paper.

  2.3  In the submission to the DETR which I prepared, the Committee will see acknowledgement of the need for change if widespread public concerns over the issues of visual amenity, and health and safety, are to be addressed. However, I am concerned that the proposals could have damaging consequences without properly addressing the concerns which they seek to meet. Hence, I have made alternative suggestions, seeking to deliver appropriate change to a more effective end.

  2.4  In the consideration given by this Committee and the views it might express to the DETR, I would like to emphasise some key factors:

    —  Development of telecommunications infrastructure is vital, in the wider public interest, in order to achieve key economic objectives and provide essential social infrastructure. For example, electronic business cannot function without such infrastructure and if it is to be encouraged so must the physical development of that infrastructure.

    —  Development of telecommunications infrastructure is key to the attainment of sustainable objectives, such as reducing the need to travel. For example, homeworking that is facilitated by modern telecommunications can help reduce commuting by all forms of transport.

    —  The public demand for that communications infrastructure is massive and growing. There are already over 40 million subscribers to mobile phone services. Almost every household has at least one television. Internet access and E-mail is used by most sectors of business and growing numbers of households.

    —  The decision to issue five new licences for 3G mobile telecommunications services has already been taken. It is the proper function of the planning system to help plan and not hinder unnecessarily the development of these networks, as with any other form of public infrastructure.

    —  As there is no such thing as an invisible telecommunications installation, that decision implied the UK will have rapidly to absorb a degree of environmental impact, associated with the development of those networks.

    —  That impact is likely to be great. At present I understand there are around 22,500 telecommunications sites throughout the UK (including radio masts and other high structures, many of which are shared). The first of these sites was developed from about the end of the first quarter of the last century.

    —  Initial operators estimates suggest they require about 50,000 installations by the end of 2003. However, the net increase in new radio masts should be less than 27,500 as some installations will be shared/or sited on existing high structures. That said, the figure is still potentially high.

    —  Beyond 2003 additional installations will be necessary to meet customer demands and to make competition driven improvements, to the benefit of the public. It is not possible precisely to predict the number of sites that might ultimately be required, but self evidently this will be reduced by greater mast or site sharing.

    —  The need to plan ahead is emphasised by the fact that every original forecast on site numbers in the early days of 2G proved to be an underestimate compared to what actually happened.

  2.5  I recognise that the potential scale and pace of new mast development is likely to further alarm the public and cause difficulties for planning authorities. However, with the right legislative and policy framework, it should be possible for Government to help the transition of the UK from one communication era to the next and for the public to tolerate the associated marginal impact on our environment. Without this framework we will not obtain the full and wide benefits of the communications revolution, which is only in its infancy and the operators will not be able to meet their licence obligations.

  2.6  The focus of any change to the legislative and planning policy framework must therefore be targeted at managing and minimising that inevitable impact, and addressing concerns about health and safety. If the Government is to achieve its core objective of making the UK the best place in the world to do electronic business by 2002, it should resist calls unduly to hinder the development of modern telecommunications. Many objectors fail to appreciate the wider environmental and other benefits of modern communications; demonstrate a poor understanding of the difficult operating constraints of telecommunications; and ignore the existence and industry wide adherence to strict health and safety controls. They prefer instead the adoption of arbitrary standards that have no sound basis in established science, and a wholly unrealistic approach to risk.

  2.7  The proper focus should be upon continued greater emphasis on mast or site sharing to help confine environmental impact and greater clarity in dealing with the health and safety.


  3.1  Encouraging the shared use of infrastructure is easy to say, but often difficult to implement. Such encouragement is a long-standing feature of licence conditions and national planning policy and is echoed at development plan level.

  3.2  However, an expectation gap has arisen in terms of what can be achieved and that will become greater in the future. The planning system has generally pushed operators to develop the minimum structures required to accommodate current requirements. This has resulted in the development of large numbers of slimline lattice and pole structures, often discreetly located in otherwise sensitive locations. Local planning authorities and the public often assume that other operators can share these structures by simply attaching one or two extra antennas. In practice, the consequences of site sharing or even accommodating further equipment for the same operator, often means redevelopment for a larger and higher structure.

  3.3  Such intensification has in many cases been regarded as unacceptable by local authorities, and that in turn has led to unwelcome tension through an appeal, or alternatively the development of yet another site nearby.

  3.4  To date the planning system has failed, in many cases, to enable the provision of infrastructure that can accommodate future, as well as current needs. This is unfortunate, and in stark contrast to the approach that is adopted in planning for a new road or railway line, which has design capacity to take account of future trends.

  3.5  Thus, proper planning principles should be followed, but with the system operating differently, if new sites are to be confined to a level that will minimise public outcry and protect our rural and urban environments from undue visual impact. In particular, I believe the system ought to facilitate the development of infrastructure capable of being shared by several different operators to avoid the unnecessary proliferation of new sites. Hence, in Crown Castle's response to the DETR, we have suggested certain permitted development rights being linked to mast sharing.

  3.6  I emphasise that I believe such an approach would go further in minimising the number of sites, than simply withdrawing permitted development rights. That is because, all things being equal, an operator (now five 3G and two TETRA in mobile communications alone) will require the same number of installations regardless of the planning procedure. However, if the legislative and policy framework were changed to actively facilitate site sharing (with acceptance that this will mean fewer but some larger installations), as distinct from simply voicing general encouragement, that would translate into fewer sites. I hope the Committee is able to support this approach.


  4.1  The planning system is not competent to deal with the issue of health and safety as such, and in any event to try and do so would contravene the usual principle of non-duplication between different areas of legislation.

  4.2  Objections based upon health and safety or related issues and the way in which planning authorities and now some planning inspectors are dealing with those objections, currently represent the biggest threat to the timely roll out of the 3G networks.

  4.3  To illustrate this, in any sample of 10 planning applications I handled five years ago, health and safety was raised as an issue in less than once case. Three years ago that had risen to about three cases. Now it is a major issue in any case that does not involve a remote site. Now also and unlike before, the issue is increasingly likely to be cited in a reason for refusal, notwithstanding the report of the Stewart Group and Government announcements since. Members are also proving more likely to be swayed by public objection on this issue and refuse planning permission in the face of an officer recommendation for approval.

  4.4  Decisive action is therefore required and I have set out in our response to the DETR a clearer policy framework to be included in PPG8, that also covers related issues, such as the perception of risk.

  4.5  However, I appreciate that the public at large and many objector groups and the scientists who support them do not appreciate the distinction between planning control and health and safety guidelines. In our recent response to the White Paper (A new Future for Communications) [3] I have therefore suggested a new certification process to give greater visibility to health and safety controls and the relevant extract is appended for the information of this Committee. I also hope Government can adopt this suggestion.


  5.1  Modern telecommunications are essential public infrastructure and are vital for the delivery of important economic objectives including the Government's core objective of making the UK the best place in the world to do electronic business by the year 2002.

  5.2  Modern telecommunications are also key to the attainment of difficult sustainable objectives, such as reducing the need to travel.

  5.3  Public demand for, and the use of, modern telecommunications is massive and growing. We are only at the beginning of the communications revolution.

  5.4  The further development of existing telecommunications systems and the rollout of the five 3G networks will require large numbers of new sites, many of them in populated areas. As we know this, we should learn from the shortcomings of the planning system to date and plan ahead to facilitate development more effectively, whilst at the same time minimise environmental impact as a whole.

  5.5  That said some environmental impact is inevitable and that is a feature common to all forms of infrastructure. However, given the potential scale of the benefits, the environment impact will be much less by comparison, than that associated with, for example, roads and railways.

  5.6  In developing this new public infrastructure, steps are required to address the concerns held by the public about potential visual impact and on health and safety.

  5.7  Whilst changes to the permitted development rights are necessary, the full extent of the changes proposed by the DETR could be damaging in their consequences without addressing the actual concerns.

  5.8  As alternative and better ways exist to focus the changes on particular concerns, they should be examined in more detail and in preference to the wide-ranging changes proposed.

  5.9  In order to minimise the visual impact associated by a very large proliferation of new masts, consideration should be given to amending the permitted development rights and planning policy to actively facilitate mast or site sharing. This would mean acceptance that cumulatively it would be better to have fewer larger installations.

  5.10  The issue of health and safety now dominates public concerns and the decision-making process. There is therefore a requirement for immediate and decisive action, by clarifying and strengthening the guidance in PPG 8 and introducing a new certification process. Such action would benefit the industry, the public and all decision-makers.

  5.11  If the Government substantially withdraws permitted development rights, fails actively to encourage shared infrastructure and leaves the issue of health and safety unchecked the consequences will be damaging to our economy. Indeed, we would have the worst of all worlds, with delay in rolling out the 3G networks with deferred or lost economic benefits, failure to achieve sustainable objectives which should deliver environmental and other improvements, and an unduly worried and hostile public.

3   Not printed. Back

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2001
Prepared 3 April 2001