Telecommunication Mast 54146, Woolley Lane, Charlcombe, Bath

The proposed site of development is located within the Larkhall Sports Ground, between Charlcombe Lane and Woolley Lane to the east of Charlcombe village. Both Charlcombe Lane and Wooley Lane are characterised by narrow, rural lanes and well-screened with mature trees. Whilst not within the Charlcombe conservation area, the site is positioned within Bath’s Green Belt and the Cotswolds AONB, and remains an attractive and significant rural area within the setting of Bath’s World Heritage site, which is recognised to be of Outstanding Universal Value. The site is currently occupied by an existing 14.7m tall monopole with associated ground infrastructure.

BPT originally objected to application 19/05534/FUL for the replacement of the existing monopole with a 20m monopole, on grounds of unmitigated visual harm to the Green Belt and AONB, a lack of considered design, and little demonstrated understanding as to the monopole’s rural, verdant setting. Planning permission has since been granted for a 20m ‘slimline’ monopole in the south-western corner of the sports field.

BPT understands the necessity for the upgrade of the existing provision of access to 5G networks in rural areas that are often not as well serviced as our urban centres; it is an important and positive improvement of public amenity and technological access.

The applicant asserts that “this proposal is to upgrade an existing site and not a new additional mast. A new additional mast to facilitate the upgrade would not be in line with NPPF”. However, in appeal decision APP/F0114/W/21/3277102, the inspector concluded that “the proposal amounts to a new mast at the site” and was therefore assessed as a new development. As this application constitutes the installation of a new, replacement mast, we maintain that this judgement still stands.

We have some concerns that the existing 14.7m mast remains present in proposed elevations, despite being indicated “to be removed”. We emphasise the need to clarify that the existing mast is to be removed as part of this application, and will be removed from the site before the new mast is installed to avoid the visual ‘cluttering’ of the site with redundant infrastructure.

We maintain that the use of a more slender monopole design (“Phase 8”) is preferable to a bulkier, more top heavy design as has previously been proposed on the site (see 19/05534/FUL).

It remains difficult to assess the landscape impact of the proposed installation without appropriate visualisations or a LVIA. Whilst we appreciate that there is already an existing mast on the site, and therefore replacement with a marginally taller mast would not constitute a significant increase in harm, we do maintain some concerns regarding the cumulative impact on the landscape setting of the Green Belt and AONB which should be properly considered as part of proposals.

Further, we emphasise an ongoing concern with the addition of further, larger masts on the site to maximise capacity for different operators, etc. This application does propose the replacement of a pre-existing, now redundant, mast, but we maintain that the presence of other masts in the immediate vicinity should not be considered a precedent for increased density of installation, or a factor from which it could be concluded that that the area is of reduced landscape value.

We note that no tree works have been detailed or appear to be proposed as part of this scheme. We maintain the importance of retaining tree cover in this area to ensure the structure remains appropriately visually screened particularly in views along Charlcombe Lane. We maintain some concerns regarding the exacerbation of future pressure on trees to the south and west boundaries of the playing field site, considering the reduced height of the proposed monopole from the refused 20m (23.4m including antennae) which was originally indicated to be “limited as far as is practical” in height – “for operational reasons, it is imperative that the antennas sit above the tree cover and therefore network signals are not obscured or blocked.”

We therefore question why a 16m height is now considered appropriate, and how the increasing competition between the need for unobscured clearance and the existing tree cover will be appropriately managed without harm to the verdant local character of Charlcombe Lane, and the wider Green Belt and AONB. should the monopole structure be permitted, it would be dependent on the this tree cover to mitigate potential visual harm within short-range and long-range views through the AONB, Green Belt, and wider landscape setting of the World Heritage Site.

BPT continues to reiterate the need for a cohesive city-wide operations plan for the future installation of telecommunications equipment. We maintain concerns that the permit of singular applications would establish a precedent for piecemeal development without consideration of the wider cumulative impact on the character and appearance of the area. We maintain that this increasing trend in telecommunications applications to be accompanied by a cross-operator masterplan that highlights appropriate sites, mast designs, and volume caps across Bath and north-east Somerset to ensure a cohesive and sustainable approach to district-wide upgrades.