NORA members are alarmed at the prospect of broadband cabinets and overhead lines appearing in protected areas other than Sites of Special Scientific Interest without adequate discussion and consultation. The emphasis in the Consultation Paper appears to be primarily with development in rural areas, but the de-regulation would appear to be relevant to urban areas as well. The list of protected areas makes no mention of World Heritage Sites, Conservation Areas and the environment of Listed Buildings, and this has given rise to serious concerns particularly by NORA's urban residents.
It is understood that to provide adequate broadband access to the internet, wired delivery is the preferred communication system, because mobile phone access to fast broadband is considerably more expensive. This applies to small businesses and dwellings in both urban and rural areas. That there is a need for improved communication facilities in rural areas and many urban areas is accepted, but this does not necessarily equate with new cabinets and more overhead lines. We understand that the proposals are specific for cabinets and overhead lines, and improvements to the mobile phone networks are not included in the proposals.
Two issues are particularly worrying. The first is the omission of involvement of the community in discussion regarding any proposed developments for new broadband cabinets and overhead lines in their environment. Secondly paragraph 2.26 states that the sharing or replacement of any existing facilities will not be mandatory although it is the preferred option. This is regretted since duplication of existing visible communication facilities in sensitive areas is generally unacceptable.
In urban areas communication networks are almost universal, so up-grading them by replacing copper wire with fibre optical cabling would seem to present few problems. In rural areas this may also be feasible in villages and large hamlets, but the serious problems arise if the intention is to provide wired connections to isolated business premises and dwellings. To try to do so everywhere would be a mammoth task at considerable expense and surely cannot be cost-effective.
1. Do respondents agree with the proposal to extend the relaxation of the restriction on the deployment of overhead infrastructure to protected areas, and to remove the prior approval requirement for protected areas?
The granting of more Permitted Development Rights, which involves damage to the environment of protected areas, is opposed. The proposed restriction to development for a limited period is bound to lead to possibly offensive overground structures, and once implemented the offending structures will remain until they cease to function, and even then, unless they are removed, they will remain to litter the environment.
To improve the communication network where it is deficient is welcomed, but companies wishing to undertake the task must be obliged to consult adequately with local planning authorities, property owners and guardians, and must be obliged to use any existing communication facilities, such as poles, towers, underground conduits and overhead lines where they exist.
Where the service is deficient, it is essential that the various choices are adequately researched as to the most appropriate method of improving access to the internet in the areas under consideration.
Accordingly the removal of the need for approval is opposed.
2. Approximately how much new network will be built using the overhead line change, in terms of new poles and kilometres of lines? Do you agree with the assumptions and cost savings set out in the consultation stage impact assessment (annex A)? Are there any other costs or benefits that you think should be included in this assessment?
3. Do respondents agree with the proposed consultation arrangements for the deployment of apparatus in protected areas?
YES and NO
The inclusion of property owners in protected rural areas in the consultation process is accepted, but the de-regulation also applies to Conservation Areas, to World Heritage sites and to sites relating to Listed Buildings. It is essential to involve the relevant communities in any proposals for overhead lines and cabinets in these urban areas too.
These urban areas have acquired their protected status as a result of many years of activity by amenity groups, owners of listed buildings and local authorities, and the threat to their integrity is as much a concern for them as it is for those trying to protect their rural environment.
4. Do you agree that the duration of the proposed changes being limited to 5 years?
The implication is that five years of intrusive development in protected areas is acceptable, a policy that cannot be right. The development of new communication networks requires considerable planning, the organisation of new equipment and the testing of its efficacy, tasks that will take several years to achieve. Even five years may not be enough to ensure that a universal system is produced. To believe that a new communications network could be built in less than five years is unrealistic. On that basis, why not ensure in the first place that the system is attractive and not intrusive in our protected areas?
Our protected areas are the most valuable heritage both rural and urban, and in the view of NORA members it is folly to sacrifice them for sake of a short-term benefit.
5. We would welcome feedback on how any aspect of the proposals outlined in this consultation should be achieved.
NORA members have clearly expressed the view that improvements in the communication network must be achieved with the approval of those whose environment is threatened, whether rural or urban. That it needs to take place is accepted, but there must be adequate consultation - with local planning authorities, amenity groups and, where appropriate, those residents most likely to be affected by proposals - and insistence on using existing conduits and overhead line facilities.
The main need for commerce and residents in areas with poor and inadequate communication facilities for broadband is for wired access to built premises rather than in open country. Because the built premises must already have some communication service albeit lacking broadband facilities, the mode of access already in existence needs up-grading rather than another parallel communications network. This should obviate the need for more intrusive development in most protected areas.
NORA accepts that where there are blind spots in the mobile phone network, it may be justified to provide more mobile phone masts, but these merit just the same scrutiny as new overhead lines and cabinets. NORA members are relieved that the proposals only cover the provision of wired access to the internet, and that any improvements to the mobile phone network will still require full planning consent.
Alan B Shrank - NORA chairman