Mr A.

du Plessis (671-7457) (telecom mast policy/duplessis)

Portfolio Committee:
HOUSING, CITY PLANNING, LAND AND ENVIRONMENTAL PLANNING
DEPARTMENT
TELECOMMUNICATION MAST MANAGEMENT GUIDELINES FOR THE CITY
OF TSHWANE METROPOLITAN MUNICIPALITY
Report of the Municipal Manager:

1.

INTRODUCTION

There are about 320 telecommunication masts within the Tshwane municipal
boundaries and it is expected that this number will increase steadily over the next
few years. It can also be expected that there will be pressure on the local
authorities in future to improve a large number of the telecommunication masts in
the area, especially as Cell C, the third service provider, has been awarded a
licence. This report concerns a study on the factors that influence the decision
on the placement of telecommunication masts.
2.

PURPOSE OF THE REPORT

Owing to various problems encountered with existing policies, this Division is of

the opinion that a new policy should be adopted to set right the differences
between the existing policies. The aim of this report is to provide guidelines for
the control and management of telecommunication masts in the Tshwane area.
The aim is also to consolidate and expand on the existing policies applicable to
the Tshwane area.
3. BACKGROUND
Cellular mast location can be explained with central place theory and the network
development overlaps with network growth theory in town planning. If the layout
of a cellular network and the problems associated with masts are understood, the
future location of masts can be managed to ensure sustainable development in
the Tshwane municipal area.
Cellular technology has numerous advantages for humans as communicating
beings, but despite these advantages cellular technology poses many problems.

4. PROBLEMS ASSOCIATED WITH TELECOMMUNICATION MASTS

Public health
One of the concerns over cellular masts is the possible health effects of
electromagnetic waves.
Cellular technology operates at ultra-high
frequency (UHF). At this stage there seems to be no clear understanding
of the effects of cellular technology on humans and other species. There
is no proof that cellular technology poses a health risk, but there is also no
proof to the contrary. The World Health Organization is busy with various
studies on the effects of electromagnetic fields. The first results are only
expected in the year 2003.

Resistance from the community

The driving force behind cellular technology is effective communication in
the information society at a lower cost, in a safer way and with more
convenience. At the centre of all this is the community, and therefore their
needs must be met.
The general problems that communities raise are:
-

Masts block their view.

Masts are ugly.
Masts emit radiation.
Masts are used in order to watch them.
They do not want masts in their backyard.

It must be kept in mind that public relations is very important for social
stability and that rebellious communities are difficult to satisfy. That is why
it is important to avoid action that may cause problems in the community.

Public safety
Public safety could be affected if, for example, a telecommunication mast
is placed on flight paths close to airports. Safety could also be a cause for
concern if the structures are not up to standard or are erected without the
necessary permission.

5.

SOLUTIONS TO PROBLEMS

Solution to problem of health effects

Erect the masts away from densely populated and residential areas

Cellular network planning must be effective so that the erection of cellular

masts in densely populated areas can be limited. It is not possible to
prohibit the erection of cellular masts in densely populated areas because
the greatest number of users are in these areas, and therefore these
areas must be covered. It is, however, possible to exercise control over
the masts in these areas by limiting their numbers and having sound
planning regarding location. It is also proposed that applicants provide a
document certifying the predicted radio frequency emission for each
application site, and this must be completed by a qualified person.
Solutions to aesthetic problems

Stealth masts or camouflage

Stealth masts are simply masts that are camouflaged to minimise their
visibility. Service providers have to weigh up the cost of building such
masts (which are often three times more expensive) against
the potential legal and incalculable public relations costs associated
with a dispute with local government approval agencies, property
owners who are affected and neighbourhood associations; and

the revenue that could potentially be lost by each site due to

administrative delays.

Examples:
A.

Building a mast in the form of something out of nature, eg a tree or an

animal. Companies that manufacture these towers are Valmont Industries
in Nebraska, USA, or Brolaz in South Africa. This camouflage method is a
requirement for any cellular mast in the city of Jefferson Parish in the USA.

B.

Other forms of camouflage include the use of -

neutral colours; or
cylinders, silos, flagpoles and bell towers.

Co-location
A very effective way of camouflaging cellular masts and creating a better
aesthetic appearance is co-locating, ie co-locating the cellular antenna
with satellite dishes and other antennas on one tower. The total cost for
all the service providers is lower as it is divided among them. The main
problem with co-location is usually the unwillingness of service providers
to cooperate.

Proximity to unsightly structures

Erecting cellular masts in close proximity to existing unsightly structures in

the area is an effective way to address the aesthetic problem of a cellular
mast, as no new unsightly structure is created. This is also a very costeffective solution. Problems may occur if the affected parties do not
cooperate. Examples of this type of proximity are cellular masts on power
lines, rooftops, water towers, highway lampposts, overpasses, bridges and
smokestacks.
Solutions to noise problems

Noise reduction panels

The only solution to the aesthetically negative problem of the humming
sound made by power generators is to mute the sound by using fibreglass
panels to cover the generator box. Another effective way of generating
power for cellular masts is the use of windmills, which was developed by
Brolaz, South Africa. Not all cellular masts need generators - only those
that are not powered by the electricity network. In the Tshwane municipal
area this is not seen as a major problem as the majority of the masts have
an electricity supply.

Solutions to the problem of the establishment of industry strategies

Policy
The problems that the cellular industry create through their strategies
should be solved with transparent policies of their own. A policy that
protects the community and the parties involved would have good results
and would be highly recommended.

Solutions to the problem of the resistance of the community

Balance
The best solution to the problems that the community experience is to
ensure that there is a balance between the needs of local government, the
communities and the market forces. It must be kept in mind that these
special needs must be fulfilled within a balanced structure.

Community participation
Another effective solution that ensures that the needs of the community
are fulfilled is community participation.
It is recommended that
educational projects be sponsored and solution teams be formed to relate

infrastructure to the needs of residents and to make residents aware of

their options.
The purpose of public meetings is to get community participation and to
answer the questions of the owners of adjacent properties regarding
cellular communication. Some local authorities do not permit cellular
masts to be put up if a public meeting has not been held and if the owners
of adjacent properties have not been informed.
6.

COMMENTS FORM OTHER DEPARTSMENTS

General Manager: Land and Environmental Planning

This Department has no comments and no objection to this draft policy.
General Manager: Legal Services
This Department has no objection to this draft policy. The comments of this
Division have been incorporated into the policy.
Chief Financial Officer:
General Manager: Environmental Resources Protection
The comments of this division on abovementioned draft policy are as follows:
Public health
It is very difficult to make any policy decisions regarding public health because
there is no consensus between the scientific community, service providers and
the public regarding the relationship between RF emissions and its health
impacts. The general public, especially parents of young children, still feels it is
unsafe to place telecommunication structures close to permanently occupied
residences, schools ect.
Section (4)(a)(vii) of the National Environmental Management Act, (Act 107 of
1989)
Stipulates that:
a risk averse and cautious approach is applied, which takes into account the
limits of current knowledge about the consequences of decisions and actions .
The CTMM must thus treat the matter with caution until detailed and sufficient
evidence about the matter is available.

The Constitution of the Republic of South Africa (Act 108 of 1996) confers a right
to all persons to an environment that is not harmful to their health or well-being.
The community in Tshwane thus has the right to question the safety of
telecommunications structures that has not yet been proven safe.
This division proposes the following:

The applicant should explore all possible alternative site locations other
than schools, permanently occupied residences and any other location as
identified by the community during the public participation process, in
order to minimise possible health aspects in the community.

If no alternative location is available the applicant must ensure that the

structure operate with RF emission levels below the International
Commission on non-ionising Radiation Protection (ICNIRP) public
exposure standard adopted by the South African Department of Health.
The applicant must measure RF emissions on a regular basis and make it
available to the CTMM for cognisance.

If evidence in future link RF emissions with health issues, the CTMM will
have the right to review existing masts, ask for modifications or
demolishment at the cost of its owner if the situation calls for it.

Public safety
The applicant must ensure that:
o Special precaution has been taken to ensure that no airstrip, road
or other public transport structure used by the public are
endangered due to impairment of movement or visibility of aircraft,
vehicles ect.
o All structures are fenced or walled to limit public access to it. If the
base station is a secured building, sufficient precaution must be
made to prevent access to the antenna support structure. Access to
the area must be strictly controlled through a locked gate.
If the structure will be co-used to put up lights for security purposes, written
consent of surrounding land users must be obtained. Lights must be screened in
such a way as to prevent light pollution.
Aesthetical problems

The applicant must proof that all methods available to assimilate the
proposed structure with the environment has been made.

The applicant must ensure that the structure has an ongoing maintenance
schedule to keep it visually attractive.

Lighting of structures must be shielded away from adjacent properties to

prevent light pollution.

Biological concerns

The applicant must ensure that sites with high erosion potential due to
steep slopes, soil type, poor vegetation etc have specific erosion control
measures in place. Erosion control measures apply for the site itself as
well as the access road.

Environmental sensitive construction methods must be applied at all times

to ensure that disturbance of the environment is minimised.

All environmentally damaged areas, in and outside the fenced area must
be rehabilitated to their original condition as soon as possible.

Red data species, if any, must be protected at all times.

All waste generated during construction must be disposed of at licensed

CTMM disposal sites.

The structure and all related elements must be removed from the site
when the structure ceases to be used for telecommunication purposes.
The site must be rehabilitated to a condition that is similar to surrounding
vegetation.

Noise problems
The applicant must take all reasonable steps to ensure that the
telecommunications structure and its equipment do not cause a noise nuisance.
Sensitive areas, rural and natural environment
The applicant must have specific visual and biological mitigation procedures in
place if sensitive land-use areas cant be avoided. Such mitigation procedures
have to be approved by the CTMM before construction commences.
General

The location of telecommunication masts must also be discussed with the

Environmental Resource Protection division prior to approval to clarify any
environmental- and health concerns.

7.

This division will have the right to inspect the site at regular intervals to
determine the state of the environment on and around it and take any
steps it deems necessary if the environment is harmed/neglected in any
way.
POLICIES OF OTHER MUNICIPALITIES IN SOUTH AFRICA

This Division investigated two other local policies in South Africa, namely those of
Cape Town and Johannesburg. The two policies can be summarised as follows:
Cape Town
The Cape Town approach focuses on the following elements:

The Councils legal responsibilities towards the community regarding the

placement of masts.
Close cooperation regarding the EIA (environmental impact assessment)
process.
Co-location of telecommunication infrastructure where at all possible.
Environmental aspects radio frequency emissions; and mental and
visual aesthetics see visual guidelines.
Preferred location on municipal property.
Land-use approval (for 15 years only).

Johannesburg
In 2000 the then Greater Johannesburg Northern Metropolitan Local Council
published by-laws relating to the erection and evaluation of cellular masts and
other antennas. The by-laws determine that application must be made for
antennas higher than 20 m. Certain antennas that are disguised as trees and that
are not higher than 20 m are approved by means of building plans.
The by-laws also provide for certain environmental considerations which are
more or less the same as those stipulated in this report.
Different aspects of each of these policies were incorporated in this report. This
ensures that there is consistency in terms of policy.
8.

MANAGEMENT GUIDELINES

After the problems of telecommunication masts and their solutions had been
studied, the proposed management guidelines for telecommunication masts were
formulated. The proposed management guidelines can be summarised as
follows:
8

General
The location of all telecommunication masts must be discussed by the
applicant with the Housing and Land Use Department before any
application is submitted.
Access to the proposed site of the telecommunication mast must be
discussed with the Roads and Stormwater Department prior to the
submission of an application.
The location of telecommunication masts outside residential areas is
preferred.
The future planning of the area around a telecommunication mast site
must be taken into consideration.
Co-location on existing masts must be encouraged and, if co-location is
not possible, evidence must be provided that diligent efforts were made to
co-locate.
Telecommunication mast sites must be located as close as possible to
similar structures such as water towers, high mast lighting and high
buildings.
Natural contours and vegetation must be used where possible to minimise
the visual effects of telecommunication masts.
Building lines as defined in the relevant town-planning schemes and title
deeds must be applicable to all telecommunication structures. The normal
process of building line relaxation and the removal of restrictive title deed
conditions will be applicable.
If the Municipality requires, the applicant must supply at least one
alternative type of or site for the telecommunication structure that has a
lower visual impact.
The permission of the South African Civil Aviation Authority must be
obtained and submitted to the Municipality before a telecommunication
mast is erected.
The local authority may request additional public participation if it is felt
that the participation has been inadequate.
Residential areas
The location of telecommunication antennas and masts on buildings is
recommended. The buildings must be multi-storey buildings.
If it is not possible to locate the antennas and masts on buildings or if it is
not possible to co-locate them with existing antennas and masts, the best
alternative locations are neighbourhood centres or church grounds.
School grounds can be investigated as a location option, but the
public resistance to these locations must be taken into account.
9

Applications regarding school property must be accompanied a power of

attorney from the respective governing body. The placement of
telecommunication antennas on school grounds should be handled with
care and not place in the direct vicinity of any classroom.

The location of antennas and masts on sites such as schools and

churches must take the surrounding uses, e.g. residential use, into
account.
Masts in particular on sports grounds, in formal parks and on golf courses
may be considered if they are placed with care as far as the functions of
the site are concerned and if they are camouflaged so that they blend in
with the surrounding environment. Existing lighting structures can also be
used as masts on sports fields and in residential areas.
Masts may only be permitted on a single residential property in special
circumstances. The special circumstances will be evaluated on merit. If
application is made on a single residential property the applicant must
provide proof that there was no alternative site available.
Commercial, business and industrial areas
The location of telecommunication antennas and masts on buildings is
recommended.
The co-location of antennas on masts of different service providers is
recommended.
The location of telecommunication masts in close proximity to architectural
landmarks, eg national monuments and historic buildings, must be
avoided.
The location of telecommunication masts in town squares and formally
designed open space and cityscapes must be avoided.
Antennas and masts may be disguised with elements such as signage,
lighting and place name boards.
Sensitive areas and rural and natural environments
Telecommunication masts must be located in close proximity to trees
whenever possible to minimise the visual impact of the masts.
Scenic routes must be avoided whenever possible. In instances where it
is not possible to avoid scenic routes, tree-type masts that blend in with
the natural environment are recommended.
Sensitive land-use areas, eg game reserves and game lodges, should be
avoided. A sensitive area can be described as an area with rivers, streams, wetlands and pans;
an area within the 1-in-50 year floodline of a water body;
a bird sanctuary or adjoining properties;
a proclaimed nature reserve or adjoining properties;
10

an environmentally protected area;

an area that is of cultural importance, eg an historical site,
graveyard;
an area with ridges or koppies (particularly if the mast may
break the skyline); or
an area identified as an area of conservation significance or
environmental importance in Gauteng, as defined in the
Open Space Plan of Gauteng, 1999, drafted by the Gauteng
Department of Agriculture, Conservation and Environment.
The grouping of masts is recommended. If masts cannot be shared they
should be placed close to other masts instead of a few hundred metres
apart.
In farming areas, antennas must be placed on farm structures, or farm
structures such as sheds or windmills should be used to protect the masts
from disturbing sensitive views.

RECOMMENDED:
1.

That cognisance be taken of the content of the report.

2.

That the following guidelines be used in the evaluation of applications for

telecommunication masts:

Procedural requirements

If one of the following town-planning schemes applies to the property to which

the application relates, the following clauses apply:

Clauses 17 and 18 of the Pretoria Town-planning Scheme, 1974.

(Rezoning applications will be needed in cases were not provision
is made for Council Consent for special buildings)
Clauses 15 and 25 of the Centurion Town-planning Scheme, 1992
(for all telecommunication masts higher than 12 m). For all
telecommunication masts lower than 12 m, only written permission
is needed.
Clause 7 of the Peri-urban Area Town-planning Scheme, 1975.
Clause 19 of the Akasia-Soshanguve Town-planning Scheme,
1996.

All rooftop antennas that are not higher than 3 m, as measured from the top
of the roof of a structure, must be exempted from the application process.
(Telecommunication containers and lift structures will not be regarded as
part of the roof of a structure.) Normal building plans processes will be
applicable.

11

The general conditions laid down by the different town-planning schemes

regarding the lapse of time for rights not exercised must apply.

General

The location of all telecommunication masts must be discussed by the

applicant with the Housing and Land Use Department before any
application is submitted.
Access to the proposed site of the telecommunication mast must be
discussed with the Roads and Stormwater Department prior to the
submission of an application.
The location of telecommunication masts outside residential areas is
preferred.
The future planning of the area around a telecommunication mast site
must be taken into consideration.
Co-location on existing masts must be encouraged and, if co-location is
not possible, evidence must be provided that diligent efforts were made to
co-locate.
Telecommunication mast sites must be located as close as possible to
similar structures such as water towers, high mast lighting and high
buildings.
Natural contours and vegetation must be used where possible to minimise
the visual effects of telecommunication masts.
Building lines as defined in the relevant town-planning schemes and title
deeds must be applicable to all telecommunication structures. The normal
process of building line relaxation and the removal of restrictive title deed
conditions will be applicable.
If the Municipality requires, the applicant must supply at least one
alternative type of or site for the telecommunication structure that has a
lower visual impact.
The permission of the South African Civil Aviation Authority must be
obtained and submitted to the Municipality before a telecommunication
mast is erected.
The local authority may request additional public participation if it is felt
that the participation has been inadequate.

Residential areas

The location of telecommunication antennas and masts on buildings is

recommended. The buildings must be multi-storey buildings.
If it is not possible to locate the antennas and masts on buildings or if it is
not possible to co-locate them with existing antennas and masts, the best
alternative locations are neighbourhood centres or church grounds.

12

School grounds can be investigated as a location option, but the public

resistance to these locations must be taken into account. Applications
regarding school property must be accompanied a power of attorney from
the respective governing body. The placement of telecommunication
antennas on school grounds should be handled with care and not place in
the direct vicinity of any classrooms.
The location of antennas and masts on sites such as schools and
churches must take the surrounding uses, eg residential use, into account.
Masts in particular on sportsgrounds, in formal parks and on golf courses
may be considered if they are placed with care as far as the functions of
the site are concerned and if they are camouflaged so that they blend in
with the surrounding environment. Existing lighting structures can also be
used as masts on sportsfields and in residential areas.
Masts may only be permitted on a single residential property in special
circumstances. The special circumstances will be evaluated on merit. If
application is made on a single residential property the applicant must
provide proof that there was no alternative site available.

Commercial, business and industrial areas

The location of telecommunication antennas and masts on buildings is

recommended.
The co-location of antennas on masts of different service providers is
recommended.
The location of telecommunication masts in close proximity to architectural
landmarks, eg national monuments and historic buildings, must be
avoided.
The location of telecommunication masts in town squares and formally
designed open space and cityscapes must be avoided.
Antennas and masts may be disguised with elements such as signage,
lighting and place name boards.

Rooftop antennas

The container of the antenna must be set back as far as possible from the
edges of the roof.
An engineers loading endorsement and appointment form must
accompany the architectural drawings.

Sensitive areas and rural and natural environments

Telecommunication masts must be located in close proximity to trees

whenever possible to minimise the visual impact of the masts.
Scenic routes must be avoided whenever possible. In instances where it
is not possible to avoid scenic routes, tree-type masts that blend in with
the natural environment are recommended.

13

Sensitive land-use areas, eg game reserves and game lodges, should be

avoided. A sensitive area can be described as
an area with rivers, streams, wetlands and pans;

an area within the 1-in-50 year floodline of a water body;

a bird sanctuary or adjoining properties;

a proclaimed nature reserve or adjoining properties;

an environmentally protected area;

an area that is of cultural importance, eg an historical site,

graveyard;

an area with ridges or koppies (particularly if the mast may break

the skyline); or

an area identified as an area of conservation significance or

environmental importance in Gauteng, as defined in the Open
Space Plan of Gauteng, 1999, drafted by the Gauteng Department
of Agriculture, Conservation and Environment.
The grouping of masts is recommended. If masts cannot be shared they
should be placed close to other masts instead of a few hundred metres
apart.
In farming areas, antennas must be placed on farm structures, or farm
structures such as sheds or windmills should be used to protect the masts
from disturbing sensitive views.

Environmental Conditions applicable

If evidence in future link RF emissions with health issues, the CTMM will
have the right to review existing masts, ask for modifications or
demolishment at the cost of its owner if the situation calls for it.
Special precaution has been taken to ensure that no airstrip, road or other
public transport structure used by the public are endangered due to
impairment of movement or visibility of aircraft, vehicles ect.
All structures are fenced or walled to limit public access to it. If the base
station is a secured building, sufficient precaution must be made to
prevent access to the antenna support structure. Access to the area must
be strictly controlled through a locked gate.
If the structure will be co-used to put up lights for security purposes,
written consent of surrounding land users must be obtained. Lights must
be screened in such a way as to prevent light pollution.
The applicant must ensure that the structure has an ongoing maintenance
schedule to keep it visually attractive.
The applicant must take all reasonable steps to ensure that the
telecommunications structure and its equipment do not cause a noise
nuisance.
The location of telecommunication masts must also be discussed with the
Environmental Resource Protection division prior to approval to clarify any
environmental- and health concerns.

14

The Environmental Resource Protection Division will have the right to

inspect the site at regular intervals to determine the state of the
environment on and around it and take any steps it deems necessary if
the environment is harmed/neglected in any way.
The applicant must give proof that all methods available to assimilate the
proposed structure with the environment has been made.
The applicant must ensure that sites with high erosion potential due to
steep slopes, soil type, poor vegetation etc have specific erosion control
measures in place. Erosion control measures apply for the site itself as
well as the access road.
Environmental sensitive construction methods must be applied at all times
to ensure that disturbance of the environment is minimised.
All environmentally damaged areas, in and outside the fenced area must
be rehabilitated to their original condition as soon as possible.
Red data species, if any, must be protected at all times.
All waste generated during construction must be disposed of at licensed
CTMM disposal sites.
The structure and all related elements must be removed from the site
when the structure ceases to be used for telecommunication purposes.
The site must be rehabilitated to a condition that is similar to surrounding
vegetation.
The applicant must have specific visual and biological mitigation
procedures in place if sensitive land-use areas cant be avoided. Such
mitigation procedures have to be approved by the CTMM before
construction commences.

Information required with applications

Applications must be accompanied by the following:

A site layout plan indicating the location of the proposed infrastructure in

relation to all existing infrastructure, buildings and large trees.
A site plan indicating the surrounding land uses on all sides.
A perspective sketch (A4-size) indicating the impact of the mast on the
skyline, taking into account existing structures and trees.
A document indicating the exact coordinates of the telecommunication
structure (if required by the local authority).
Sufficient photographs of the site clearly illustrating the likely impact of the
proposed telecommunication mast on the site and surrounding properties.
The written authorisation (or exemption) of the Gauteng Department of
Agriculture, Conservation and Environment, as contemplated in section 7
of the Environment Conservation Act, 1989 (Act 73 of 1989), which
authorisation (or exemption) must specify the site on which the antenna is
to be erected. (This must be submitted before the application can be
evaluated.)

15

A document setting out a full radio frequency emission prediction, certified

by a qualified and experienced person.
Building plans are required once the application has been approved. The
normal information as required with building plans will be applicable. The
following information is essential: approval letter and approved layout
plan, Engineers certificate, building line relaxations, sewage approval and
title deed.
End of the Report

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