© Friends of Ingrebourne Valley and Hornchurch Country Park

Mast Planning Application Update

“The proposed development does not constitute one of the specific forms of development referred to in the NPPF or Policy DC45 as appropriate. Consequently, it must be considered as inappropriate development in principle within the Green Belt. It is for the applicant to demonstrate that very special circumstances exist to outweigh this in principle harm, as well as any other harm arising from the proposed development. The proposal is also located within a Site of Nature Conservation Importance and Policy DC58 states that planning permission for development that adversely effect any of these sites will not be granted unless the economic or social benefits of the proposals clearly outweigh outweigh the nature conservation importance of the site and only then if adequate mitigation can be provided and no alternative site is available. Officers do not consider the applicant to have sufficiently demonstrated that no other site is available. As part of the pre-application discussions officers have advised that a site in close proximity to the bus lay-by would be the preferred position as any impact would be partially mitigated by closer proximity the built environment, existing streetlights as well 2 directional floodlights on either side of the lay-by. No evidence was provided by the applicant to suggest that a site close to the lay-by would not be a viable option.

GREEN BELT IMPLICATIONS Policy DC64 of the Core Strategy and Development Control Policies Development Plan Document states that planning permission for telecommunications development will only be granted where it does not have an unacceptable effect on the character and appearance of the surrounding area or in other respects unacceptably harm the amenity of occupiers of neighbouring sites. The policy goes on detailing that proposals should be sufficiently screened, should not have an undue effect on the skyline and not cause an adverse effect on local conservation value. The applicant should furthermore demonstrate the significance of, and the need for the proposal as part of the national network; demonstrate that the proposal is the least environmentally intrusive option of all technically feasible alternatives; and compliant with the ICNIRP guidelines for public exposure. Expanding on the above, in respect of design, policy CP17 aims to ensure that new development maintains or improves the character and appearance of the local area. This application is for a streetpole with a height of 14m combined with 6 no. antennas on a phase 4.5 head-load. The proposed mast would be significant wider and with the addition of the external antennas would represent a substantially larger development than that of the commonly used Elara streetpoles. It is considered that an installation of this height and size would represent a significant visual intrusion within this part of the Metropolitan Green Belt. Whilst there are existing trees close to the southern boundary of the St. Georges Hospital site, (approximately 18m from the subject site) they are of a lesser height than the proposed mast and deciduous. This means that the tower has a prominent and exposed position against the skyline, particularly during the winter months, to an extent which is considered to result in a visually intrusive form of development, which harms the predominantly open character of the surrounding Green Belt. It is therefore considered that the applicant must demonstrate very special circumstances exist to overcome the harm to the Green Belt arising from the proposed installation. The proposal includes cabinets and a 1.8m high palisade compound fence. This has a lesser impact on the Green Belt due to its reduce height and the greater benefit of tree screening at ground level. IMPACT ON AMENITY The proposed location of the mast does not lie adjacent or encroach upon any residential property. Officers do not consider the mast to have an unacceptable impact on neighbouring amenity as the nearest residential dwelling is situated approximately 70m away. With regard to the actual operation of the development, and potential noise impacts, the Council's Environmental Health department have been consulted and have raised no objection to the proposal. Such issues nevertheless fall outside the direct scope of consideration of this application. The Council is only permitted, with such an application, to determine if the siting and appearance of the development is satisfactory or not. Other issues: In respect of health issues a Certificate has been submitted with the application which confirms that the proposal complies with ICNIRP guidelines. Government advice within the NPPF states that local planning authorities must determine applications on planning grounds. They should not seek to prevent competition between different operators, question the need for the telecommunications system, or determine health safeguards if the proposal meets International Commission guidelines for public exposure. In this case, an ICNIRP Certificate has been submitted. It is not therefore considered that there are any justifiable grounds to refuse the proposals on health grounds.

OTHER ISSUES It falls to be considered whether there are any very special circumstances which would justify the harm caused by the proposed development to the Metropolitan Green Belt. The applicant has indicated that there is a requirement for the proposed development to meet an identified need in the locality. The applicants states that this proposal would replace the coverage from the previous mast which was located within the grounds of St Georges Hospital. The St. Georges Hospital site is is due for re-development and the operators were therefore served with a Notice to Quit. Supporting information indicates that a number of alternative sites were considered locally but were unsuitable for the proposal. Staff have considered whether this amounts to the very special circumstances necessary to justify the development and have had regard to the guidance set out in NPPF. However, in this case it is considered that the extent of harm to the character and appearance of the Green Belt would outweighed the very special circumstances case. Moreover, officers are not convinced that a site closer to the bus lay-be would not be a viable option as discussed earlier in this report.


The proposed development is considered to be unacceptable in terms of siting and appearance and, in respect of this, it is recommended that the prior approval of the local planning authority, pursuant to Part 16 of Schedule 2 of the Town & Country Planning (General Permitted Development) Order 2015, therefore be refused.

1. Reason for refusal - Metropolitan Green Belt The site is within the area identified in the Havering Unitary Development Plan as Metropolitan Green Belt. The Unitary Development Plan and Government Guidance as set out in Planning Policy Guidance Note 2 (Green Belt) is that in order to achieve the purposes of the Metropolitan Green Belt it is essential to retain and protect the existing rural character of the area so allocated and that the new development will only be permitted outside the existing built up areas in the most exceptional circumstances. No special circumstances have been submitted in this case and the proposal is therefore contrary to Policy DC45 of the Development Control Policies Development Plan Document Policy and the provisions of the NPPF.

2. REFUSAL - Non Standard The proposal, by reason of its height and size and prominent location, would appear as an unacceptably dominant and visually intrusive feature, harmful to the rural character of the Green Belt, contrary to Policies DC45,DC61 and DC64 of the LDF Core Strategy and Development Control Policies Development Plan Document and the provisions of NPPF. INFORMATIVES

1. Refusal - Amendments requested not made.   Statement Required by Article 35 (2) of the Town and Country Planning (Development Management Procedure) (England) Order 2015: In accordance with para 186-187 of the National Planning Policy Framework 2012, improvements required to make the proposal acceptable were negotiated with Ms Ginny Hall on 11/01/16. The revisions involved proposed a site closer to the bus lay-by. The applicant declined to make the suggested revisions.”

Jeff Stafford.


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