Mobile Operators’ response to the Second Deloitte
Implementation Review recommendations

27 January 2005

Detailed responses per recommendation

4.1. General Findings on the Site Selection and Planning Model (Planning Commitments 1,2,7 and 10)

Recommendation:
Guidance should be provided for instances where responsibility for progressing sites is to be transferred from one Agent to another.

Accepted, the Operators have already prepared an internal guidance note for transfer of files between agents involved in shared sites. This guidance will be re-emphasized and extended for all instances where the responsibility for progressing sites is transferred from one Agent to another.

4.1.1 Stage 1 - Area Wide LPA Consultation (Annual and Pre-roll out)

Recommendation:
Consider standardising, across Operators, the scale, style and format of maps as part of the Annual roll out pack.

Accepted, the Operators will review the level of consistency in the format of information and consider, within the limits of their various Information Systems, if more can be achieved.

2.A.1 Information Gathering and Site Identification

‘Number of potential sites identified in search areas’

Recommendation:
Consider providing explanations (both technical and non-technical) that are more clear for proceeding with alternative and/or suggested sites in planning applications.

Accepted. We note the report has found that considerations of alternatives and reasons for choosing the preferred option are now recorded within the Supplementary Information Template. However, the Operators will continue to remind site acquisition agents that they should make the explanations for site choices as clear as possible.

Recommendation:
Consider increasing flexibility in working with local communities to identify mutually acceptable siting options.

Accepted, whilst steps have been taken by the Operators towards a more flexible way of working with communities, the Operators remain open to looking at any new ideas which will improve this process.

Recommendation:
Clarify in the Site Selection and Planning Model, and its footnotes, whether:
· Consultation Plans are required to be completed for Green rated sites; and
· Optional elements under Stage 2 are deemed relevant for Green rated sites.

Accepted, as part of the review of the current definition of the Site Selection and Planning Model, the Operators will review the clarity of the guidance for Green rated sites.

2.A.1 Information Gathering and Site Identification

‘Allocate Initial Traffic Light Model Rating’

Recommendation:
Continue to enforce the use of the MOA standard Traffic Light Model for all potential sites to ensure all sites are consulted on using consistent criteria. Reiterate and reinforce the current version of the Traffic Light Model to Agents for compulsory use. Require Agents to only use the official version of the Traffic Light Model and any versions independently developed should be reviewed for integrity, accuracy and compliance with the official version.

And

Recommendation:
Consider implementing guidance to require accurate completion in full of the Traffic Light Rating form (including the sign-off box).

Accepted. We note the report has found that the standard Traffic Light Rating Form issued last year is now in wide use. However, the Operators will continue to remind site acquisition agents that they should always use the current industry standards for Traffic Light Rating and to ensure the forms are signed and dated.


2.A.2 and 2.A.5 Offer a pre-application meeting

‘Pre-application Meetings and LPA responses’

Recommendation:
Reiterate and reinforce existing internal guidelines over transferring all site file information from the Outgoing Site Share Agent to the Incoming Site Share Agent.

Accepted, see comment on internal guidance note in response to first recommendation above.

Recommendation:
Where deemed useful by Planning Officers and Agents (i.e. urban areas) consider providing drawings (as well as maps) as part of the pre-consultation pack.

Accepted, Operators will continue to remind site acquisition agents that, where helpful, they should consider providing drawings, for example in ‘generic’ form, or photomontages, at an early stage to facilitate the local planning officers’ assessment of the potential impact of a site in an area.

2.B.1 Tour of Options (Optional)

Recommendation:
Consider updating pre-application requirements to include provision of photomontages.

Accepted, see comment on photomontages in response to recommendation above.

Stage 3: Community Consultation

Recommendation:
Reiterate the need for Parish Council clerks to receive consultation letters for all Amber/Red sites unless otherwise advised by the LPA. Reiterate the need to place a file note on the site file if there is no Parish Council to consult.

Accepted. We note the report has found an almost three fold improvement already in this area and that apparent deficiencies may in fact be due to incomplete recording of sites where there is no Parish Council. However, the Operators will continue to remind site acquisition agents that they should always attempt to identify if there is a Parish Council or equivalent in the area and, if so, include them in the consultation for Amber or Red rated sites or otherwise make relevant file notes.

3.A.1 and 3.A.2 Letter to Ward Councillor, Letter to Parish Council Clerk (or appropriate National variations)

Recommendation:
Where LPOs ask Agents not to carry out pre-application, these requests should be recorded and maintained on file.

Accepted, the Operators will continue to remind site acquisition agents that they should make relevant file notes in this situation.

3.B.3 Informal ‘Drop In’ Session

Recommendation:
Ensure all drop in sessions are publicised on an effective basis to allow communities to take advantage of them.

Accepted, the Operators will continue to remind site acquisition agents, when holding ‘Drop in Sessions’, to ensure that the event is publicised effectively to allow communities to attend and participate.

3.B.4 Key Stakeholder Briefing Session

Recommendation:
Reinforce guidance to assist in the identification of key stakeholders for participation in briefing sessions.

Accepted, the Operators will continue to remind site acquisition agents, when holding ‘Briefing Sessions’, to ensure that relevant key stakeholders are identified and invited to the meeting.

3.B.5 Leaflets

Recommendation:
Reinforce need for Agents to maintain evidence of any leaflets circulated to communities on site files.

Accepted, the Operators will continue to remind site acquisition agents to record the actual consultation carried out, including the distribution of leaflets.

3.B.6 Public Notice Placed in Local Press

Recommendation:
Consideration should be given to increasing the use of the local press as a media for communicating Operator site plans to local communities.

Accepted, the Operators will review the effectiveness of current methods of interacting with communities within the Site Selection and Planning Model including the use of local press and consider any improvements needed.

Stage 4 Planning Submission

Recommendation:
Provide Agents with more structured pro-formas for Licence Notification applications, ensuring a minimum set of information is provided with each application.

And

Recommendation:
Consider the continuation and further inclusion of relevant additional documents (e.g. emission profiles, photomontages, site specific Health and Safety Information, maps, radio coverage plots, consultation history and general background information to telecoms developments) with each type of application.

Accepted, the Operators will review the existing guidelines for each type of application or notification and issue further guidance on the standard information to be included as appropriate.

Recommendation:
Clarify in the Site Selection and Planning Model, and its footnotes, whether Standard Planning Application Templates are required for Licence Notifications.

Accepted, as part of the review of the current definition of the Site Selection and Planning Model, the Operators will review the guidance for Licence Notifications.

4.B.3 Attend Planning Committee Meeting

Recommendation:
Consider encouraging Agents to attend Planning Committee meetings as per the requirements of the Site-Selection and Planning Model.

Accepted, the Operators will review the effectiveness of current guidelines on attending Planning Committee meetings and consider, for cases where decisions are not delegated or there is no opportunity to speak, if further guidance is required.

4.2.1. Commitment 3: Publish clear, transparent and accountable criteria and cross industry agreement on site sharing, against which progress will be published regularly

Recommendation:
It is recommended that information is published that will allow Local Planning Officers and interested stakeholders to understand the technical and commercial decision making criteria upon which sites can or cannot be shared.

Accepted, in addition to including site sharing in the ongoing provision of professional development workshops as part of Commitment 4, the Operators are developing and will shortly be issuing a publication outlining the basis for site sharing for Local Planning Officers and other interested stakeholders.

Recommendation:
Consider publishing the site share information to a wider group of stakeholders rather than just the government bodies listed above.

Accepted, the Operators are discussing this recommendation with the third party site providers.

4.2.2. Commitment 4: Establish professional development workshops on technological developments within telecommunications for local authority and elected members

Recommendation:
Consideration should be given to continuing to update the agenda/contents and invitation lists in the light of ongoing changes in the market, perception of risk and/or in regulation.

Accepted, the Operators are committed to maintaining the agenda and contents of the professional development workshops to be continuously relevant to the issues faced by the local authorities and elected members. The invitations will continue to be targeted proactively towards relevant audiences, such as newly elected councillors, as well as responding to requests from all local planning authorities.