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This environmental resource guide seeks to support the rollout of digital infrastructure in England, by providing greater awareness of climate adaptation, environmental improvements (biodiversity gains), and low carbon considerations. The guide is based on England jurisdiction, but has direct relevance across devolved administrations too.
To provide broadband suppliers and mobile operators (and any subcontractors or agents) with a single reference point for environmental requirements and resources, in relation to delivering digital infrastructure in England. It should ensure a reasonable standard of environmental awareness is applied during survey, design, build and operation.
This should also help the sector with climate adaptation solutions.
Whilst this guide is for Building Digital UK (BDUK) funded infrastructure, it can be applied across other digital infrastructure delivery across all government departments, such as the Rural England Shared Prosperity Fund, as well as commercial rollout funded privately.
It will also be able to support the rollout of hybrid and standalone satellite solutions, as many of the terminals are likely to be placed in very remote areas. This means they are likely to have higher exposure to extreme weather events and potentially limited access to the mains power grid. At present satellite terminals also have higher power consumption requirements than traditional fixed or mobile connectivity.
This resource guide can also be utilised as an initial starting point for broadband providers and mobile operators in UK nations with devolved administrations, because of likely parallels in environmental impacts to consider. BDUK is collaborating with each devolved administration and anticipates standalone telecoms environmental guidance in accordance with their legislation, policy and strategic priorities, in due course.
It does not include:
While this document is intended to assist with and illustrate many of the key requirements that will need to be complied with, it is not a comprehensive statement of all relevant environmental regulation. It is not intended as legal advice and as such it remains each organisation’s responsibility to satisfy itself on a case-by-case basis that it has complied with all legal requirements.
Why is this resource needed?
In England, under the Environment Act 2021, the mandatory local nature recovery strategies regulation (effective from 13 April 2023) and the biodiversity gain requirements (expected to be effective from November 2023 at the earliest), are likely to alter how digital infrastructure networks are planned, designed, permitted and delivered. Specifically when full planning permission is required under the Town and Country Planning Act 1990 and the Environment Act 2021.
Some local authorities across England are going further and faster to reach net zero targets, and therefore each area will have varying requirements for suppliers and operators to adhere to. There is no one size fits all approach.
Likewise, there is no one standardised approach or single sector lead for non-mandatory environmental improvements on digital infrastructure networks, and not all in the sector have access to the same resources or finances to focus on the environment to the same degree. This guide (for some) could be the impetus for change and improvements and help the sector with climate adaptation solutions. Noting, some larger suppliers and operators are already demonstrating leadership in environmental solutions, and this resource guide would be complementary to those efforts.
This is only the start to a rapidly changing area, and it is anticipated there will be more changes on environmental improvements over the next few years. BDUK welcomes feedback and suggestions relating to this document at bduk-environment@dcms.gov.uk. BDUK aims to review this resource every year up to 2030 (the duration of our programme), and update where applicable.
The UK was part of the Paris Agreement 2015 to limit global temperature rise to 1.5 degrees above pre-industrial levels. Following this, the 25 year environment plan: A Green Future 2018 outlined how the government will improve the environment within a generation. The UK was the first parliament in the world (in 2019) to embed 100% net zero carbon emissions by 2050 into legislation. In 2021, the government set an ambitious target to reach a third of this by reducing emissions to 78% by 2035, compared to 1990 levels (see Climate Change Act 2008). Post Brexit, the government has redefined environmental protection for air quality, water, and resource efficiency/waste reduction in the Environment Act 2021. The Environment Act 2021 also includes new provisions to include biodiversity net gain as a mandatory part of the planning permission process. The establishment of an Office for Environmental Protection gives this independent public body the discretion to scrutinise the government’s environmental performance and to take enforcement action against ministers, government departments and other public authorities for failures to comply with environmental law.
The Environmental Improvement Plan 2023 (the first revision of the government’s 25 year environmental plan) sets out how the government will work with landowners, communities and businesses to improve the environment. See Other important information sources for additional information sources.
We are supporting the government’s target of at least 85% connectivity by 2025 through a combination of suppliers’ commercial build and subsidised build, and then to nationwide gigabit-capable broadband by 2030. We are also supporting the partnership with mobile network operators to reach the government’s target of 95% 4G mobile coverage from at least one mobile network operator by the end of 2025, with further coverage improvements in the more hard-to-reach areas to continue to be delivered until the start of 2027.
BDUK is an executive agency within the Department for Science, Innovation and Technology (DSIT), that funds digital infrastructure networks by suppliers and operators, outside of commercial rollout plans. This includes the £5 billion Project Gigabit programme and the £1 billion Shared Rural Network 4G mobile partnership programme. None of this funding is allocated to data centres.
As part of its programmes to deliver digital infrastructure, BDUK has an objective to evaluate the benefits and dis-benefits of its interventions. This is the first year BDUK is providing environmental guidance for deployment, and undertaking environmental evaluation. BDUK acknowledges greater clarity is required to inform and support the sector – especially since digital infrastructure networks have a crucial role to play in net zero realisation. Without gigabit-capable infrastructure some sectors may not be able to transform and adapt at the pace anticipated to support challenges of climate change, innovation around carbon reductions and biodiversity improvements.
Ministers of the Crown (including the minister responsible for BDUK) “must, when making policy, have due regard to the policy statement on environmental principles” effective from 1 November 2023, by virtue of the Environment Act 2021.
To date, BDUK has incorporated key procurement policy notes into its bid evaluation process for contracts on social value (and environment) PPN06/20 and net zero carbon reduction plans for contracts valued over £5 million per annum in PPN06/21. We have also published key guidance documentation to enhance awareness and support the sector in their delivery.
We continue to support broadband suppliers and mobile operators to remove barriers for digital infrastructure build alongside government-wide strategies and manifestos.
This environmental resource guide is applicable for broadband suppliers and mobile operators that receive government funding to deliver digital infrastructure networks in accordance with provisions in contracts, grant agreements, or the terms and conditions, and in accordance with key legislation. It could also be applicable for commercial funded rollout.
As indicated in Section 1, the rights given to broadband suppliers and mobile operators are subject to other legal duties, obligations and changes. Specifically the Environment Act 2021 provisions (including biodiversity gain in planning) overlap with the Electronic Communications Code (Conditions and Restrictions) Regulations 2003 (as well as the subsequent 2009, 2013, 2016 and 2017 amendments to those regulations) on conservation areas and protected areas, which interact with the Electronic Communications Code.
Broadband suppliers and mobile operators are expected to conduct due diligence during survey, design, build and maintenance phases to find the best practicable solution that balances the need for their delivery approach, proportionally with the need for environmental protection and enhancement. It is recommended that broadband suppliers and operators regularly check the latest environmental provisions in the local area to help them take into account and give early consideration to designated sites and stakeholder engagement.
The implementation and maintenance of digital infrastructure contributes to carbon emissions related to disturbance of land, air or water, and dust and heat generation can result in air quality impacts. BDUK and industry need to be measuring and evaluating some of these impacts, and make improvements where possible.
The sector may find it useful to know that agriculture and land use changes are key areas that acceleration is recommended to the government Climate Change Committee Progress Report June 2023, specifically tree and woodland planting (afforestation) and peatland restoration to help reach net zero targets across the UK (among many other matters).
A key supporting document is the barrier busting handbook April 2023 which includes guidance on legislation, the supplier delivery pledge, and tools for delivery (also referenced in Tables 1 and 2 below). Broadband suppliers should check regularly with local authorities and land owners that installation and maintenance will not affect efforts to protect or enhance biodiversity or conservation.
We encourage meaningful correspondence with key organisations and stakeholders ahead of approaching BDUK for funding and or delivery, in order to help broadband suppliers and operators to gain greater clarity and collaboration during the design process. Table 1 below, provides initial guidance to support design, build and maintenance of the network.
Table 1: Environmental design and operational considerations
There are certain locations that are particularly important for nature-rich habitats or for species that are afforded higher environmental protection and require careful consideration associated with delivering on, near or surrounding them. See Table 2 below for information to assist with designing a network that incorporates biodiversity and environmental improvements.
The core documents applicable for most digital infrastructure networks in England include the Guidance for broadband suppliers working in protected nature sites – March 2023 by Natural England and BDUK Barrier Busting Handbook, alongside additional guidance below.
Table 2: Designated site resource guidance
Suppliers and Operators (and their subcontractors) must, where applicable, comply with the Electronic Communications Code (Conditions and Restrictions) Regulations 2003 (as well as the subsequent 2009, 2013, 2016 and 2017 amendments to those regulations). Amongst other things, Regulations 8 and 8A set requirements for the notices which must be provided to interested organisations when an operator intends to conduct certain works in specified locations, such as Areas of Outstanding Natural Beauty, National Parks, Marine Nature Reserves and/or National Nature Reserves.
The visual and text below shows some key ways to deliver digital infrastructure with greater awareness of climate adaptation/weather resilience, environmental improvements (biodiversity gains), and low carbon/net zero considerations.
This image illustrates 7 ways to support delivery of digital infrastructure with biodiversity, environmental improvements and net zero considerations at the forefront.
Review power needs and access, early. Design with renewable options – where possible.
Review local plans and contact the local planning authority to confirm if any current or planned protected natural sites are in the area i.e. biodiversity and local nature recovery sites.
Review existing and future infrastructure networks. Look at sharing access (includes other infrastructure sectors). Engage with local stakeholders early.
Consider how the build is designed to be weather resilient and adapt to climate change.
Design ways to support enhancements ie in biodiversity delivery partnerships, social value, tree planting and peatland restoration, and carbon reduction solutions.
Be aware of and comply with the mandatory requirements, such as the Environment Act 2021 for England.
Regularly undertake due diligence and inform those designing and building the networks on the latest environmental requirements.
Please note:
There is no one size fits all approach
Biodiversity includes all species of animal and plants, and the natural system that support them
If new to net zero and carbon reductions, or wanting to understand more on biodiversity and the environment. Table 3 includes a few sources as a starting point.
Table 3. Some information sources for digital infrastructure networks
Biodiversity outlined by Joint Nature Conservation Committee (May 2023)
Biodiversity net gain outlined by Department for Environment, Food and Rural Affairs
Climate change defined by the Climate Change Committee
Environmental effect outlined in the Environmental Principles Policy Statement (January 2023)
Environmental protection outlined in the Environment Act 2021
Natural Environment outlined in the Environment Act 2021
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