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Mobile Communications Policy Statement

Perth and Kinross Council · 16 November 2022
Back to Environment, Infrastructure and Economic Development Committee — 16 November 2022 and its agenda

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PERTH AND KINROSS COUNCIL 
Environment, Infrastructure and Economic Development Committee
16 November 2022
MOBILE TELECOMMUNICATIONS POLICY STATEMENT
Report by Head of Planning and Development
(Report No. 22/279)
1. PURPOSE 
1.1 To update the Committee on the development of mobile phone networks in
the UK and the implications for Perth and Kinross. The paper presents a
policy statement on telecommunications which, it is proposed, should be
adopted to guide the Council’s support for mobile network deployment, in
what will be an intensive period of activity over the coming few years.  
2. RECOMMENDATIONS 
2.1   It is recommended that the Committee: 
(i) approves the Mobile Telecommunications Policy Statement for Perth &
Kinross
(ii) notes there will be a Single Point of Contact on telecommunications with the
responsibility to liaise with Scottish Government, Scottish Futures Trust,
Scotland’s 5G Centre and Mobile Network Operators, to be identified by the
Head of Planning and Development. 
3. STRUCTURE OF REPORT 
3.1 This report is structured over the following sections: 
• Section 4: Background/Main Issues  
• Section 5: Proposals  
• Section 6: Conclusion  
• Appendices 
4. BACKGROUND / MAIN ISSUES 
4.1 Digital connectivity has risen in importance following the Covid-19 pandemic
and will undoubtedly underpin the success of local economies in the future.
Councils have an influence on how mobile networks get built, from a planning,
strategic economic and digital development perspective. Mobile networks are
considered essential national infrastructure but are ultimately delivered locally
with the help of local councils. Mobile Network Operators (MNOs), national
and local government working together is essential if 4G and 5G connectivity
is to be available to as many people and businesses as possible.

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4.2 The Council has a further vested interest in boosting digital connectivity,
because the more people are online, the easier it is to deliver services online.
The fixed line digital connectivity has been boosted in recent years thanks to
the Digital Scotland Superfast Broadband (DSSB) programme, now being
taken forward through the Reaching 100% (R100) programme.  However,
Perth & Kinross superfast broadband connectivity still only reaches 87.9% of
premises. The recent Local Full Fibre Network project, supported by UK
Government and Tay Cities Deal, has seen 136 of the Council’s buildings
connected last year to gigabit capable broadband speeds. 
4.3 Mobile network connectivity is less developed, however, with almost one fifth
of Scotland’s land mass not having 4G coverage from any operator.  Within
Highland Perthshire, there are numerous ‘partial not-spots’ and some ‘total
not-spots’ for mobile network coverage.  This impacts upon quality of life for
residents but also impacts on council service delivery – such as our
Countryside Rangers seeking to manage rural visitor sites; the delivery of
rural public transport services; and, increasingly, the delivery of digital health
and social care services in the form of virtual consultations and remote
monitoring of patients. These, and other services, can be transformed, and
costs reduced through digitalisation, but only if connectivity is improved. 
4.4 The Council’s telecommunications policy dates back to November 2001
(Report No. 01/758 refers). It was developed at a time when mobile telephone
ownership and usage was still low and smart phones were not available (the
first iPhone came out in 2007).  Now 92% of the UK mobile users have a
smart phone, rising to 96% of 16-24-year-olds (Uswitch mobile phone
statistics, 2022) and nearly half the population say they use smart phones
more now than before the pandemic.   
4.5 In 2001, the Committee was informed of the need to update the
telecommunications policy, first set in 1997, which – at that time - restricted
installation of telecommunications masts on Council properties primarily due
to health concerns.  The Committee agreed to remove the then moratorium on
siting of equipment but to continue to take a precautionary approach.  This
was essentially avoiding properties in continuous educational, public or staff
use, and extending to power and signal cables where they served telecoms’
developments adjacent to excepted Council properties. 
4.6 There are now potentially more than 20 more mast (or so called ‘macro’) sites
to be deployed over coming years under the Shared Rural Network in Perth &
Kinross - which is a UK Government initiative to improve 4G coverage in rural
areas - and private MNO investment. Together, these amount to over £1bn of
investment split equally between private and public funding. The Electronic
Communications Code (ECC) also came into force in December 2017 and this
now requires the Council’s telecommunications policy to be reviewed and
updated. The Code brings a significant change to the law in this area, allowing
for the siting of masts and associated infrastructure under permitted
development.

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4.7 Linked to this, the Scottish Government is keen to improve the mobile network
infrastructure and is in the process of working with operators to deploy further
masts across Scotland through the 4G Infill Programme (4GIP). It is also
supporting Scottish Futures Trust who have developed a suite of guidance
and tools to help local authorities with the lease and charging agreements
around the siting of telecoms equipment. The Council has participated in this
‘Infralink’ initiative and helped develop these tools which are now available for
all local authorities to use. A further UK Government supported ‘Infralink
Exchange’ initiative looking at the use of council street furniture for small cells
is currently underway involving all Tay Cities local authorities. 
Mobile Network Technology 
4.8 Mobile communications technology has developed through several
generations (the ‘G’s’) and there are now many 2G, 3G and 4G base stations
installed throughout the UK, providing services to users of mobile phones and
other devices. A fifth generation of the technology (5G) is now well developed
and reflects the latest evolution in mobile communications technology which
will soon move to 6G. 
4.9 Base stations are stationary radio transmitters with antennae mounted on
freestanding masts or on buildings. The largest base stations provide the main
infrastructure for networks and may be up to several kilometres apart.
Antennae tend to be mounted at sufficient height to give them a clear view
over the surrounding geographical area. Smaller base stations tend to be
mounted nearer to ground level and provide additional radio capacity where
there are a high number of users, such as in cities and towns. 
4.10 The radio waves transmitted by base stations are radiofrequency
electromagnetic fields (EMFs), a form of non-ionising radiation, and have
frequencies in the microwave region of the electromagnetic spectrum. More
recently, the masts or macro sites have been supported by ‘micro’ sites such
as ‘small cells’. Telecommunications providers are set to make heavy use of
small cell technology to roll out 5G coverage, particularly in urban areas. 
4.11 Small cells make use of low-power, short-range wireless transmission
systems that cover small geographical areas or small proximity indoor and
outdoor spaces. Small cells have all the same characteristics as base stations
that have been used by telecom companies for years. However, they are
uniquely capable of handling high data rates for mobile broadband and
consumers and, for IoT, high densities of low-speed, low-power devices. 
Health effects 
4.12 Mobile network base stations transmit and receive radio waves to connect the
users of mobile phones and other devices to mobile communications
networks. The strength of the radio waves from base station antennae
reduces rapidly with increasing distance and the levels at locations where the
public can be exposed tend to be small.

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4.13 The health effects of exposure to radio waves have been researched
extensively over several decades and has addressed concerns about rapidly
proliferating mobile communications technologies from around the year 2000.
Independent expert groups in the UK, and at international levels, have
examined the accumulated body of research evidence. Their conclusions
support the view that health effects are unlikely to occur if exposures are
below international guideline levels. The consensus appears to be that it is
unlikely that mobile phones or base stations increase the risk of health
problems, although there is still some uncertainty about the potential for risks
from long-term use over decades. The UK Health Security Agency (UKHSA)
continues to monitor the health-related evidence applicable to radio waves,
including in relation to base stations, and is committed to updating its advice
as required. 
4.14 The Council continues to follow the guidance from the International
Commission on Non-Ionizing Radiation Protection (ICNIRP) in the
accompanying Mobile Telecommunications Policy Statement (Appendix 1). 
The Electronic Communications Code 
4.15 The legal framework underpinning rights to install and maintain electronic
communications infrastructure on private and public land is contained in the
Electronic Communications Code (ECC), which is part of the Communications
Act 2003. A Telecommunications Code was first enacted in the UK in the
Telecommunications Act 1984. In 2003, the Code was extended to cover all
electronic communications and the Digital Economy Act 2017 introduced an
entirely new code – the ECC - on 28 November 2017. The Digital Government
(Scottish Bodies) Regulations 2022 added Scottish Bodies to the schedules of
the Digital Economy Act 2017. The reforms made to the Code in 2017 were
intended to support faster and easier deployment, as well as encouraging
industry investment in digital networks. These changes strived to balance the
need for digital infrastructure with the rights and interests of landowners and
other site providers. The UK Government has been keen to keep the Code
updated so that the potential economic and social benefits of fast and reliable
connectivity can be realised. 
4.16 The Council must comply with the new Code which requires public (and
private) authorities to work with the telecommunications industry in the
deployment of telecommunication infrastructure, equipment and services. This
does not affect statutory and legislative processes in relation to planning, road
safety and closures. OFCOM still enquire, investigate and legislate on safety
standards in relation to utilities, including mobile telecommunications. The
Council is still consulted on all proposed new mast sites and has already
received several as part of the Shared Rural Network deployment of new
masts.

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5. PROPOSALS 
Council Mobile Telecommunications Policy Statement 
5.1 An updated Mobile Telecommunications Policy Statement is needed to align
the Council with current national telecommunications policy in the light of the
ECC and an anticipated intensive period of activities over the coming few
years. The Statement continues to be mindful of unintended locational
consequences for residents, landowners, landscape, townscape and public
health, whilst adopting a constructive approach to the siting of telecoms masts
to support digital infrastructure. There will be a significant number of new
masts being erected over the next few years across the Council area due to
the Shared Rural Network and there will also be new applications for 5G
masts. A planning application for a 20m mast on Dunkeld Road, Perth, was
refused by Committee in December 2021 on grounds of visual impact. A
subsequent appeal was also dismissed by a Scottish Government Reporter.   
5.2 Current mast sites on Perth and Kinross land – five in total - are leased to
telecoms operators and are at varying stages in terms of the lease
agreements.  Often when the lease agreement is due for renewal or
renegotiation, the Council will employ a land agent with specialisms in
telecommunications equipment to act for it so that the best return can be
achieved. These are paid for by the industry but increasingly – because of the
ECC and because of the Councils involvement in Infralink – this role is
becoming less important as the income generated from these leases
diminishes, because as mast sites and coverage proliferates, rental income
also diminishes.   
5.3 Whilst the Council recognises that mobile connectivity and fixed fibre
connectivity are equally important, it is the case that mobile connectivity has
received much less profile nationally and locally. There is an opportunity now,
with the Shared Rural Network impacting on Perth & Kinross, that building
mobile networks should be a key priority in the digital infrastructure strategy
for the region.  This will require a partnership between MNOs and the Council
working together to ensure 4G and 5G connectivity is to be available to as
many people and businesses as possible. 
5.4 The Mobile Telecommunications Policy Statement to update the policy that
was set in 2001 relating to siting equipment near Council buildings is attached
as Appendix 1. It is wider in scope (not confined to telecoms on Council
buildings) and more pro-active in encouraging new telecommunications masts
and equipment across Perth & Kinross. However, it recommends that the
Council should still seek to avoid educational, public or staff use premises
where there may be public concerns.  It should also continue to minimise the
impact on the landscape of masts though the planning process.

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5.5 Appropriate Local Development Plan policies will be considered and consulted
upon to ensure they reflect both the need to roll out mobile networks
alongside fixed fibre networks, while protecting amenity. Operationally, an
officer Single Point of Contact for MNOs will be identified to facilitate the roll
out of the private and publicly funded parts of the Shared Rural Network in
Perth & Kinross and to coordinate the involvement of services in enabling this. 
6. CONCLUSIONS 
6.1 Councils are instrumental in delivering both fixed fibre and mobile networks,
through granting planning permission, ensuring future development is planned
with mobile connectivity in mind, or providing their public assets to host mobile
equipment. How local authorities interpret planning and street works
regulation, and how they design local economic strategies, have a bearing on
how efficiently mobile infrastructure can be deployed. In short, councils
influence the speed and cost of mobile infrastructure being built. Mobile
networks are increasingly a key priority in the digital infrastructure strategy for
the area, as the Council enables more services to be accessed online from
wherever you are and to promote economic development in all areas.  This
requires partnership between MNOs and the Council working together so that
4G and 5G connectivity is available to as many people and businesses as
possible. 
6.2 Councils need to think about their future mobile connectivity needs in the
same way that they think about other types of essential economic
infrastructure like roads, housing, utilities and even fibre broadband.
Improvements to mobile technology often move faster than councils can
update their local development plan policies. Mobile connectivity has become
so vital to everyday life that residents and businesses need to have access to
the best possible mobile connectivity now and in the future.  The Council’s
own LDP policy on telecommunications is proactive and up-to-date and will be
reviewed again in due course. Meanwhile, the Mobile Telecommunications
Policy Statement will put in place a supportive statement for the Council to the
telecommunications industry that the Council wishes to see improved
connectivity in the area and is willing to work with the industry, national
government and agencies such as SFT through the Infralink initiative to
achieve this. 
6.3 With the Policy Statement in place and the areas that it identifies for action -
the Council will be pro-active and supportive in developing digital connectivity,
working with the mobile industry to enable the roll out of networks that are
now essential to life in our rural areas. However, the Council will still place
health concerns as a priority and will seek to avoid educational, public or staff
use premises and consider all applications for equipment in relation to
environmental and health issues to ally public concerns and minimise the
impact on the landscape of masts though the planning process.

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Authors
Name  Designation Contact Details
Graham Pinfield 
Serge Merone
Team Leader Smart Perth &
Kinross 
Climate Change and Smart
Investment Manager 
(01738) 475000
ComCommitteeReports@pkc.gov.uk   
Approved 
Name Designation Date
Barbara Renton  Executive Director
(Communities) 
7 November 2022 
APPENDIX 1 – Mobile Connectivity Policy

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ANNEX
1. IMPLICATIONS, ASSESSMENTS, CONSULTATION AND
COMMUNICATION
Strategic Implications Yes / None
Community Plan / Single Outcome Agreement  None
Corporate Plan  Yes
Resource Implications  
Financial  Yes
Workforce Yes
Asset Management (land, property, IST) Yes
Assessments  
Equality Impact Assessment Yes
Strategic Environmental Assessment Yes
Sustainability (community, economic, environmental) Yes
Legal and Governance  None
Risk None
Consultation 
Internal  Yes
External  None
Communication 
Communications Plan  None 
1. Strategic Implications 
Corporate Plan 
1.1 The Council’s Corporate Plan 2018 – 2023 lays out five outcome focussed
strategic objectives which provide clear strategic direction, inform decisions at
a corporate and service level and shape resources allocation.  They are as
follows: 
(i) Giving every child the best start in life;
(ii) Developing educated, responsible and informed citizens;
(iii) Promoting a prosperous, inclusive and sustainable economy;
(iv) Supporting people to lead independent, healthy and active lives; and
(v) Creating a safe and sustainable place for future generations. 
1.2 This report relates to all of these objectives. 
2.  Resource Implications 
Financial 
2.1 There are no direct financial implications arising from this report other than
those reported above. 
Workforce

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2.2 There are no direct workforce implications arising from this report other than
those reported above. 
Asset Management (land, property, IT)   
2.3 There are no direct asset management implications arising from this report
other than those reported above. 
3. Assessments 
Equality Impact Assessment 
3.1. Under the Equality Act 2010, the Council is required to eliminate
discrimination, advance equality of opportunity, and foster good relations
between equality groups.  Carrying out Equality Impact Assessments for plans
and policies allows the Council to demonstrate that it is meeting these duties. 
3.2. The information contained within this report has been considered under the
Corporate Equalities Impact Assessment process (EqIA) and has been
assessed as not relevant for the purposes of EqIA. 
Strategic Environmental Assessment 
3.3 The Environmental Assessment (Scotland) Act 2005 places a duty on the
Council to identify and assess the environmental consequences of its
proposals. 
3.4 The information contained within this report has been considered under the
Act.  However, no action is required as the Act does not apply to the matters
presented in this report.   
Sustainability 
3.5 Under the provisions of the Local Government in Scotland Act 2003 the
Council has to discharge its duties in a way which contributes to the
achievement of sustainable development. In terms of the Climate Change Act,
the Council has a general duty to demonstrate its commitment to sustainability
and the community, environmental and economic impacts of its actions.   
3.6 The information contained within this report has been considered under the
Act.  However, no action is required as the Act does not apply to the matters
presented in this report.   
4. Consultation 
Internal 
4.1 The Executive Directors and Chief Operating Officer have been consulted in
the preparation of this report. In addition, Planning, Estates and Corporate

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Property Asset Management have also been consulted and comments
received and incorporated.   
2. BACKGROUND PAPERS 
2.1 No background papers, as defined by Section 50D of the Local Government
(Scotland) Act 1973 (other than any containing confidential or exempt
information) were relied on to any material extent in preparing the above
report.