a special consent application for a proposed ......the application site is known as the erf 2025...

A SPECIAL CONSENT APPLICATION FOR A PROPOSED TELECOMMUNICATION 36M CELL PHONE MAST AND BASE STATION ON

ERF 2025 LOVU SITUATED AT 308 LUCKY DUBE DRIVE, LOVU. IN TERMS OF THE ETHEKWINI MUNICIPALITY: PLANNING AND LAND USE

MANAGEMENT BY-LAW 2016, CHAPTER 8 SECTION 28 SUBSECTION 2 (A) READ IN CONJUNCTION WITH THE SPATIAL PLANNING AND LAND USE MANAGEMENT

ACT, 2019 (ACT 16 OF 2013

PREPARED BY:

HUAWEI TECHNOLOGIES SOUTH AFRICA (PTY) LTD

Westway Office Park 17 The Boulevard

Westville 3630

For Enquiries: Akshay Sukhlal| Cell: 083 650 7496| [email protected]

mailto:[email protected]

SPECIAL CONSENT APPLICATION FOR A 36m CELL MAST INFRASTUCTURE AND BASE STATION ON ERF 2025 LOVU

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Contents

1 INTRODUCTION .................................................................................................................................... 3

1.1 THE APPLICANT ............................................................................................................................. 3

2 THE SITE ................................................................................................................................................ 4

2.1 SITE LOCALITY ................................................................................................................................ 4

2.2 ACCESS ........................................................................................................................................... 5

2.3 OWNERSHIP................................................................................................................................... 5

2.4 POWER OF ATTORNEY .................................................................................................................. 7

2.5 CADASTRAL DESCRIPTION ............................................................................................................ 7

2.6 CURRENT ZONING ......................................................................................................................... 7

2.7 EXISTING AND SURROUNDING LAND USES .................................................................................. 9

2.8 PHYSICAL CHARACTERISTICS......................................................................................................... 9

3 PROPOSAL ........................................................................................................................................... 10

3.1 PROPOSED DEVELOPMENT ......................................................................................................... 10

3.2 ACCESS ......................................................................................................................................... 11

4 LEGISLATION ....................................................................................................................................... 11

4.1 STATUTORY DEVELOPMENT FRAMEWORK ................................................................................ 11

4.2 INTERGRATED DEVELOPMENT PLAN .......................................................................................... 11

4.3 ALIGNMENT TO THE SPATIAL DEVELOPMENT FRAMEWORK .................................................... 14

4.4 SPATIAL PLANNING AND LAND USE MANAGEMENT ACT 16 OF 2013 (SPLUMA) .................... 15

4.4.1 PRINCIPLES OF SPATIAL JUSTICE (SECTION 7 (A)) ................................................................ 15

4.4.2 PRINCIPLES OF SPATIAL SUSTAINABILITY (SECTION 7 (B)) ................................................... 15

4.4.3 PRINCIPLE OF EFFICIENCY (SECTION 7 (C)) ........................................................................... 15

4.4.4 PRINCIPLE OF SPATIAL RESILIENCE (SECTION 7 (D)) ............................................................ 15

4.4.5 PRINCIPLE OF GOOD ADMINISTRATION (SECTION 7 (E)) ..................................................... 15

5 TELECOMMUNICATION INFRASTRUCTURE ....................................................................................... 16

5.1 SOUTH SCHEME OF ETHEKWINI MUNICIPALITY ........................................................................ 16

5.1.1 LOCATIONAL PROVISIONS .................................................................................................... 16

5.2 VISUAL IMPACT ........................................................................................................................... 18

5.3 SECURITY ..................................................................................................................................... 18

5.4 NOISE ........................................................................................................................................... 19

5.5 ELECTRICITY ................................................................................................................................. 19

5.6 HEALTH IMPACT .......................................................................................................................... 19


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5.7 ENVIRONMENTAL ISSUES ........................................................................................................... 20

5.8 CIVIL AVIATION AUTHORITY ....................................................................................................... 21

6 MOTIVATION ...................................................................................................................................... 21

6.1 NEED AND DESIRIBALITY ............................................................................................................. 21

7 CONCLUSION ...................................................................................................................................... 22

Annexures

Annexure A: Application Form

Annexure B: Locality Map

Annexure C: Windeed Report

Annexure D: Power of Attorney

Annexure E: Zoning Map

Annexure F: Surveyor General Diagram

Annexure G: Site Development Plan/ Building Plan

Annexure H: Health and Safety Statement

Annexure I: Non Listed EIA Letter

Compiled By: Date Signature

Akshay Sukhlal

Planning Technician

(SACPLAN C/8640/2018)

09 June 2020

Checked by: Date Signature

Nkosinathi Ngubane

Professional Planner

(SACPLAN A/2088/2015)

09 June 2020

OUR REFERENCE: GYRO 003


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1 INTRODUCTION

Huawei Technologies South Africa (PTY) LTD submits this motivation memorandum together with its

annexures to apply for special consent to construct a 36m telecommunication cell phone mast with

associated infrastructure and base station on the property known as Erf 2025 Lovu situated at 308 LUCKY

DUBE DRIVE, LOVU, located within the eThekwini South Municipality.

Figure 1: Aerial view of the Application Site

1.1 THE APPLICANT

NJAPHA FRANCIS MUZIWAMANDLA is the registered owner of Erf 2025 Lovu. He has appointed Huawei

Technologies who would be exercising power of attorney on his behalf, to lodge a special consent report,

which is in compliance with the provisions of eThekwini Municipality: Planning and Land Use Management

By-Law 2016, Chapter 8 section 28 subsection 2(a), read in conjunction with the Spatial Planning and Land

use Management Act, 2013 (Act 16 of 2013).

The APPLICATION FORM is attached as Annexure A.


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2 THE SITE

2.1 SITE LOCALITY

Illovo is a town in EThekwini in the KwaZulu-Natal province of South Africa. It is a popular coastal resort

on the Natal South Coast, between Winklespruit and Karridene, 34 km south-west of Durban. It takes its

name from the Lovu River.

The LOCALITY MAP is attached as Annexure B.

Figure 2: Locality Map 1

The coordinates for the site are as follows:

Latitude: -30.060790°

Longitude: 30.827731°


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Figure 3: Locality map 2

2.2 ACCESS

Access to the application site is gained directly of Lucky Dube Drive, Lovu. Regardless of the new

development occurring, this access point will continue to be the main access point onto the site.

2.3 OWNERSHIP

According to the Title Deed T2263/1984, and extract from the Windeed Report, Erf 2025 Lovu (hereafter

referred to as the application site), is registered in the name of NJAPHA FRANCIS MUZIWAMANDLA. The

title deed could not be obtained at the time the application was submitted.

Registered Owner Title Deed No. Extent 𝒎𝟐

NJAPHA FRANCIS MUZIWAMANDLA T186/1997

262

The WINDEED REPORT is attached as Annexure C.


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Figure 4: Windeed Report


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2.4 POWER OF ATTORNEY

The application site is owned by NJAPHA FRANCIS MUZIWAMANDLA, who has given Power of Attorney

to Huawei Technologies South Africa (Pty) Ltd

The POWER OF ATTORNEY is attached as Annexure D.

2.5 CADASTRAL DESCRIPTION

The application site is known as the Erf 2025 Lovu, situated at 308 Lucky Dube Drive, Lovu,

2.6 CURRENT ZONING

The subject property is currently zoned as Mixed Use in terms of the South Scheme of Ethekwini

Municipality.

The scheme intention is as follows: To provide, preserve, use land or buildings for a full range of Mixed Use

facilities either public or private. Institutional facilities that to the discretion of eThekwini municipality does

not affect the amenity of the area, recreational facilities ancillary to the Mixed Use establishment and

accommodation of students, educators and other staff of the Mixed Use establishment.

The table below indicates the development parameters, as well as confirms that the telecommunications

tower will only be allowed via special consent.


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Figure 5: Development Controls

The ZONING MAP is attached as Annexure E.


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2.7 EXISTING AND SURROUNDING LAND USES

The application site is zoned as Mixed Use and is currently vacant. It is surrounded by a vast majority of

residential homes. Other land uses that are in close proximity to the site are residential, open space areas

and a school.

Figure 6: Land Use Map

2.8 PHYSICAL CHARACTERISTICS

The extent of the application site is 262m2. The area in which the application site is located is relatively flat.

The application site is located on a property zoned as Mixed Use and is owned by NJAPHA FRANCIS

MUZIWAMANDLA.

The SURVEYPR GENERAL DIAGRAM is attached as Annexure F.


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3 PROPOSAL

3.1 PROPOSED DEVELOPMENT

The proposed consent is to construct a Telecommunication Mast with associated infrastructure (cell phone

mast) and base station on Remainder of Erf 2025 Lovu situated at 308 LUCKY DUBE DRIVE, LOVU.,

located within the eThekwini South Municipality (within a 9mx9m base) which will be situated on the

property. An existing MTN telecommunication monopole mast currently exists within the property, however

this will be demolished in order to accommodate the proposed tree mast.

The SITE DEVELOPMENT PLAN/ BUILDING PLANS are attached as Annexure G.


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The Telecommunication Base Station will consist of:

A 36m telecommunication tree mast and equipment cabinet all within a 2.4m high steel palisade fence

which will run on the boundary of the 9mx9m base station site.

Access into the site will be gained through a 3m swing gate.

3.2 ACCESS

Access to the subject property and site will be from the entrance at Lucky Dube Drive, Lovu and the access

to the base station will be gained through a 3m swing gate.

4 LEGISLATION

4.1 STATUTORY DEVELOPMENT FRAMEWORK

The application site falls within the jurisdiction of the eThekwini Municipalities South Entity and is regulated

by the South Scheme of Ethekwini Municipality.

The purpose of this section is to motivate for the approval of this special consent application. The application

makes reference to various legal documents and policy framework, by-laws, and any information that was

considered to be relevant and valid, and was available at the time of compiling the application.

4.2 INTERGRATED DEVELOPMENT PLAN

The Municipal Systems Act No 32 of 2000 requires all municipalities to produce Integrated Development

Plans (IDP). An IDP is a tool used by the Municipality to plan future development within eThekwini. It guides

and informs all planning, budgeting, management and decision-making. It is is a super plan for an area that

gives an overall framework for development. It aims to co-ordinate the work of local and other spheres of

government in a coherent plan to improve the quality of life for all the people living in an area.

The IDP is aligned to various national government policies and guidelines, such as the Provincial Spatial

Economic Strategy and the KwaZulu-Natal Growth and Development Strategy. Due to the proposal being

in line with the eThekwini Municipality IDP, it would therefore be in line with national and provincial

legislation.

The Ethekwini Municipality has organised their delivery plan into eight separate but related plans. They are

interrelated because the plans, programmes and projects are supportive of each other, to ensure greater

impact in delivery. Where contradictions or overlaps are found to exist, these will duly be brought into

alignment.


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As identified by the municipality, Plan 7 is titled as Good Governance and Responsive Local Government

Goal. This plan was put into place to ensure a strong, caring and democratic institution to promote and

support a consultative, effective, efficient and participatory local government.

Under this plan Programme 7.11 was created for Network, Telecommunications and Electronic services.

The purpose of this programme is to provide secure and reliable network connectivity to municipal

applications and telecommunication services both voice and data. To manage the overall network

infrastructure, provide free internet access through municipal libraries and provide public Wi-Fi.

The proposal will therefore contribute in making this a reality, as it will offer better coverage in this particular

area. It can be considered as a stepping stone to accomplish the goal that has been set out in the Integrated

Development Plan, as it will be taking the municipality one step closer to offering the free internet access

and public Wi-Fi.

The IDP also outlines challenges that are of prime concern. Below is a table identifying these challenges,

together with proposals that contribute towards rectifying some of these problems.

CHALLENGES PROPOSAL ALIGNMENT AND CONTRIBUTIONS TO

RECTIFYING CHALLENGES

High rate of unemployment and

low economic growth

High levels of poverty

The mast will assist in bridging the gap within the digital divide. In

doing so, it will create better opportunities for self-employment, using

the internet.

Surveillance will not be a challenge as security cameras can be

connected via Wifi to an MTN internet connection and provide remote

viewing.

Low levels of skills development

Limited access to basic

household and community

services

Loss of natural capital

Unsustainable development

practices

High levels of crime and risk

Ensuring adequate energy and

water supply

Ensuring food security


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Infrastructure degradation

No permanent structures are being removed. However an existing

mast is being moved. This is limited to the mast infrastructure only.

Therefore infrastructure degradation will not be considered an issue.

The proposal will be in line with all aspects of the National Building

Regulations.

Climate change

Ensuring financial sustainability

Ineffectiveness and inefficiency

of inward-looking local

government still prevalent in the

Municipality


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4.3 ALIGNMENT TO THE SPATIAL DEVELOPMENT FRAMEWORK

According to the Spatial Development Framework, the application site forms part of an Urban Node as per

the 2019-2020 eThekwini Municipality Spatial Development Framework. “Urban nodes are existing and

new and are well located lower order nodes serving the needs of local areas. These nodes are located at

transport interchanges and or at the intersections of development spines. Their role is to provide essential

‘day to day’ commercial needs and social and commercial services to immediately adjacent communities.”

This node contains a mix of low, medium and high densities and lies in close proximity to a school.

THE SITE


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4.4 SPATIAL PLANNING AND LAND USE MANAGEMENT ACT 16 OF 2013 (SPLUMA)

In terms of SPLUMA (ACT 16 of 2013), the following principles apply to spatial planning, land development

and land use management and are hereby applied to this application:

4.4.1 PRINCIPLES OF SPATIAL JUSTICE (SECTION 7 (A))

In terms of the principles of spatial justice, a cellular mast will operate in terms of connecting different

localities via cell network operators whereby people will have access to better communication signals. This

also forms part of the upgrading of an essential infrastructure of an area in terms of the required functional

infrastructure development.

4.4.2 PRINCIPLES OF SPATIAL SUSTAINABILITY (SECTION 7 (B))

Given that the cellular masts will not be erected on any property which is deemed environmentally sensitive,

the mast will be placed strategically in locations where gaps in signals are prominent. In terms of the

longevity of these masts, they will be used as parts of a new and sophisticated type of network. It will provide

better service quality to the surrounding recipients. Given that a great deal of people make use of cellphones

and networks to communicate, this type of infrastructure will allow for a more effective way of

communicating within various cities and towns. The general public expects and demands effective cellular

coverage.

4.4.3 PRINCIPLE OF EFFICIENCY (SECTION 7 (C))

In terms of integrating cities and towns, the strategic location of cellular masts will create an effective

working environment for people. Having such infrastructure in place will then also attract people to cities

and towns where they may engage in business or leisure knowing that no telecommunication disruptions

may occur. Effective cellular telephone coverage is a requirement for daily necessity.

4.4.4 PRINCIPLE OF SPATIAL RESILIENCE (SECTION 7 (D))

Cellular telephone infrastructure forms part of the urban fabric. With more than 32 000 cellular telephone

masts in operation in South Africa today, it can be considered as part of the urban landscape that have

spatial resilience in cities and towns, empirical analysis of real infrastructure networks have indicated that

an optimal infrastructure network is the one with the most short average path length (APL) links between

network receptors. In the case of a technical disruption or electrical outage, other telecommunication

receptors will be able to take over the capacity of that area, and will spring back into shape as soon as the

disruption is gone.

4.4.5 PRINCIPLE OF GOOD ADMINISTRATION (SECTION 7 (E))

As can be seen from the aforementioned, all of the necessary investigations, i.e. applications, CAA and

EIA is undertaken for every site to ensure that an optimal position for a cellular telephone mast is identified.


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All required permits is then obtained from all relevant departments. When applying for permission/consent

and/or building plan approval from the municipality, the correct channels are followed in terms of obtaining

the necessary comments from the respective departments, notice of new construction is to be placed at the

site in question, public participation is done to ensure that the adjacent land owners are aware of the

proposed development and they have a set period of time in which they may lodge any objections,

construction and building plans are done with reference to relevant restrictions such as servitudes and

building lines. In cases where building line relaxation is required, an application is done to obtain approval

before any form of construction may commence.

5 TELECOMMUNICATION INFRASTRUCTURE

5.1 SOUTH SCHEME OF ETHEKWINI MUNICIPALITY

According to the abovementioned scheme of the eThekwini Municipality, the following applies:

5.1.1 LOCATIONAL PROVISIONS

When evaluating a site, the following is considered:

1. Agricultural/Business/Industrial/ areas are the most ideal locations and will always be the first option

if they are located within the 200m radius of the nominal point and if the lessor is interested. These

sites are in most cases, not found in residential areas. However, some of the basis are debatable

from Town Planning principles, land use zoning and layout planning. These policies and legislation

seek to control and contain the excessive and passive provision of land use zones such as

Agricultural/Business/Industrial/ and Commercial in residential areas. It takes into account the very

nature of these land use zones due to the “relaxed restrictive” conditions and uses permissible on

such properties.

2. The next option is cellular antennas on high-rise buildings. Should there be any available in the

area, there are key factors that would need to be taken into account. These are radio network

planning, intended network coverage in the area and the supporting nature of the new proposed

site in aiding the host of ecosystems for the specific network. There are instances in which sites

within the network planning ecosystem relies on other sites for effective and efficient network

operations.

3. The third option is to identify other masts in the area that can be shared, assuming that they do

meet the particular network operators planning requirements, intended coverage and very

importantly, the existing infrastructure being fit to carry more antenna load and to handle wind-

loading on the mast structure; the mast is not pre-planned for the existing operators future upgrades

radio antennae, or transmission microwave equipment which can be very heavy in many instances.

Sharing of towers are always considered when evaluating a site. It is however not always an option,

since the towers may not have available space to share or have exceeded their design load


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capacity or in some instances, the location of the existing mast is not with line of site, intended

coverage area of the new proposed mast by the specific network operator who is applying for a

new mast.

Ideally, network operators would share infrastructure if the location and structural integrity of the

mast can accommodate more load. The basis of sharing being an option for network operators is

not only regulated by ICASA (Independent Communications Authority of South Africa), it also

makes financial sense for the operators since the cost to build and service the mast is very

expensive. Furthermore, many permitting processes can be relatively lengthy, and costly and can

often be riddled with debatably baseless public objections, which could be due to the lack of public

education and sensitisation, general “mast-phobia” and the NIMBY ("Not In My Back Yard")

syndrome.

4. The fourth option in consideration will be schools or churches. These sites are also, however not

always, to be found within the radius of the nominal point. However, the owner may decline the

proposals due to some of the factors that have been highlighted above, among other reasons.

5. The final option is residential erven and are only considered when all above mentioned options

have failed. Mobile network operators do however use small towers as discussed in previous

paragraphs to mitigate the visual impact of the mast on the surrounding neighbourhood. This option

is often seen to be the last resort and are opted for, among other factors, because the line-of-site,

network planning requirements and predictions do highlight such areas (radius) as the most

suitable for network planning and rollout. To this effect, a Radio Network Plan motivation is usually

attached as a supporting annexure to motivate for the choice of location and how such affects the

decision process in planning for network site build in such locations (radius).

To ensure optimal network coverage to customers who, utilise either voice services, mobile data services

and fibre as a suitable means of connectivity, cellular towers should ideally not be more than 500m apart

in terms of radius and distance, taking into account factors such as natural obstruction (Vegetation – trees,

terrain – mountains/hills) and artificial obstructions such as buildings and other structures. Site distance

can be very subjective and objective in nature taking into account the intended coverage of the network,

technology, population densities and general network demand pressures, including but not equally

restricted to technologies deployed on the mast in terms of connectivity such as 3G, 4G, LTE and in the not

so distant future, 5G which is based on latency of short wave lengths and close proximity site ecosystems

for high data demand, artificial intelligence and overall quality of latency and speed.

The application site has been specifically selected, as being located in a position ideally suitable to provide

optimal cellular network capacity for the current and future needs in the area which are not fixated as

technology is on a high pace of evolution.


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The site chosen for this application falls within an urban location and falls within the eThekwini Municipality

Planning and Land Use Management Scheme. It is zoned as Worship. This site has been specifically

selected, as being located in a key position as it can service both the residential community. As per the

South Scheme of Ethekwini Municipality, the site is suitable for the following reasons:

It does not pose any negative impacts on other developments and natural features,

There are no existing masts within close proximity to the site,

The application site does not contain any building or structures that is of historical, architectural,

cultural or artistic importance, nor has it been set aside for conversation purposes.

The proposed mast and equipment are located at the rear end of the site.

The above reasons provide a basis for this site being selected. Further to this, the application site will

provide optimum cellular network capacity for the current and future needs in the area which is not static,

as technology continues to rapidly evolve. Masts are needed in order to assist in servicing the ever-growing

urban community. Access to telecommunication services will assist in bridging the digital divide and

connecting the surrounding people to relatives, assistance, knowledge and other opportunities that are

associated with the fourth industrial revolution.

5.2 VISUAL IMPACT

The eThekwini Municipality Spatial Planning and Land Use Management By-Law 2016 (municipal notice

114 of 2017) and applicable scheme, makes provision for a development such as the proposed. The

property is zoned Worship, the proposed development is anticipated to gain due support without any

prejudice. In general, such infrastructure are becoming more common in various communities as the

general public becomes increasing aware of the significance of these infrastructure in providing a basic and

critical network services, thereby enhancing effortless connectivity and communication.

In addition, the tower type proposed has no extensive and intrusive detrimental visual impact to the extent

to warrant refusal of the application. Further, the proposed infrastructure is not in the line of sight of any

monuments or infrastructure deemed to be a landmark to which the nature of such landmark is anticipated

to unduly inhibit the purpose to which such monument or landmark is meant to serve.

5.3 SECURITY

In terms of security to the base station site, access will be limited to authorised personnel and the access

point will be kept locked at all times for security purposes. The equipment located inside the operator

container will be secure as it will be locked at all times. These measures rule out and minimise the possibility

of any public/unauthorised access to the site.


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5.4 NOISE

As technology is ever evolving, the development proponent is always striving to utilise the latest equipment

and technologies on the base station that seeks to eliminate noise levels as much as possible. Thus, MTN

endeavours to always deploy containers that do not generate high irritating noise levels; this is done by

using silent air condition and fans where possible and feasible. Generators may be used in the event of

power failures/ outages, however in extreme power failure circumstances, they may be used for a prolonged

period of time.

5.5 ELECTRICITY

Whilst the infrastructure is not power intensive, the mobile network operator will source electricity at its own

cost from the relevant service provider, following relevant protocol/ processes.

We do not anticipate that power will be an issue to the local authority with regards to approving this

application

5.6 HEALTH IMPACT

A common concern about telecommunication masts relates to the possible long-term health effects that

whole body exposure to the RF signals may have. To date, the only health effect from RF fields identified

in scientific reviews has been related to an increase in body temperature (> 1 °C) from exposure at very

high field intensity found only in certain industrial facilities, such as RF heaters. The levels of RF exposure

from telecommunication masts are so low that the temperature increases are insignificant and do not affect

human health. The strength of RF fields is greatest at its source, and diminishes quickly with distance.

Unauthorised access near base station antennas is restricted where RF signals may exceed international

exposure limits. Recent surveys have indicated that RF exposures from telecommunication masts in

publicly accessible areas, including schools are normally thousands of times below international standards.

In fact, due to their lower frequency, at similar RF exposure levels, the body absorbs up to five times more

of the signal from FM radio and television than from telecommunication masts. This is because the

frequencies used in FM radio (around 100 MHz) and in TV broadcasting (around 300 to 400 MHz) are lower

than those employed in mobile telephony (900 MHz and 1800 MHz) and because a person's height makes

the body an efficient receiving antenna. Further, radio and television broadcast stations have been in

operation for the past century without any adverse health consequence being established.

While most radio technologies have used analogue signals, modern wireless telecommunications are using

digital transmissions. Detailed reviews conducted so far have not revealed any hazard specific to different

RF modulations.


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Scientific evidence on the distribution of cancer in the population can be obtained through carefully planned

and executed epidemiological studies. Over the past 15 years, studies examining a potential relationship

between RF transmitters and cancer have been published. These studies have not provided evidence that

RF exposure from the transmitters increases the risk of cancer. Likewise, long-term animal studies have

not established an increased risk of cancer from exposure to RF fields, even at levels that are much higher

than produced by telecommunication masts and wireless networks.

According to the World Health Organization and from all evidence accumulated so far, no adverse short or

long-term health effects have been shown to occur from the RF signals produced by base stations. Since

wireless networks produce generally lower RF signals than base stations, no adverse health effects are

expected from exposure to them.

There has been an increase in public concern with regards to the health risks associated with possible

Radiation Exposure from Telecommunication Infrastructure and Base Stations. Scientific research is yet to

provide conclusive evidence that suggests the Telecommunication Infrastructure (Cell Phone Mast) have

adverse health effects on people living close to – or working with – cellular technology. Although antennae

and base stations emit radio waves, their frequency is not considered high enough to pose a health risk.

Furthermore, regular tests regarding compliance to safety regulations add to reducing the health risk factor.

The Department of Health released a statement on the Health Effects of Base stations, which states the

following:

“The Department is therefore satisfied that the health of the general public is not being compromised by

their exposure to microwave emissions of cellular base stations. This also means that local and other

authorities, in considering the environmental impact of any particular base station, do not need to and

should not attempt, from a public health point of view, to set any restrictions with respect to such parameters

such as distance to the mast, duration of exposure, height of the mast, etc.”

In addition, South Africa’s Department of Health has published EMF exposure limit guidelines. These are

based on guidelines endorsed by the International Commission of Non-Ionising Radiation Protection

(ICNIRP), of which the emissions from these base stations and antennae are in compliance with.

The HEALTH AND SAFETY STATEMENT FROM THE NATIONAL DEPARTMENT OF HEALTH is

attached as Annexure H.

5.7 ENVIRONMENTAL ISSUES

The proposed development does not trigger any activity based on the fact that the proposed

telecommunication mast is in compliance with all regulation that have been set out by the relevant

department. As per the Economic Development, Environmental Affairs and Tourism, the mast installation

will not trigger a need for an EIA authorisation.


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The NON LISTED EIA is attached as Annexure I.

6 MOTIVATION

6.1 NEED AND DESIRIBALITY

Over the years, telecommunication has changed from merely being a convenience to being essential for

business and communication purposes, including for emergency and safety purposes. The demand for

access to network coverage and data have increased vastly over the last decade and is anticipated to

continue growing. The high surge in data traffic is already a strain on the existing cellular network

infrastructure. To put this into perspective, there are currently estimated 24,000 cellular towers in South

Africa and it is anticipated that this number will increase to 74,000 by 2021. It is therefore undebatable that

there is a high and increasing need for more cellular towers. Cellular communication and connectivity is

seen as a basic and necessary infrastructural need.

The demand for access to network coverage and data have increased vastly over the last decade and is

anticipated to continue growing. The high surge in data traffic is already a strain on the existing cellular

network infrastructure as the Mobile Network Operator seeks to maintain quality standards to ensure value

for money to subscribers and the general public.

The proposed development will increase the level of coverage and capacity to all consumers in the

catchment area which will benefit the community by having access to improved internet connection,

communication facilities and services. It is important to note that as the proposed cellular tower is built

specifically to accommodate more than one operator through co-location/sharing, a fair mix of cellular users

will benefit from the proposed development and not only those using MTN as a specific cellular network

operator.

The increase in network strength brought by the proposed telecommunication mast and base station will

aid the local business and can unlock growth potential which will have a positive economic impact and

effortless ease to the means of doing business in the city and the global digital connected world at large.

The proposed development will have no negative impact on the external engineering services, transport or

traffic related considerations or on the biophysical environment. Every possible measure will be taken to

ensure that the design is aesthetically pleasing, where feasible taking into account various criteria based

on the site build, infrastructural engineering and design conditions which are site specific.

We are of the opinion that the proposed use will have no detrimental impact on the surrounding properties

and will provide an essential service to the surrounding community.


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7 CONCLUSION Due to the increasing data demands and technology Upgrade requirement especially in the urban and built

up areas, many more sites are required within an area to meet user requirements. Sites need to have

overlapping coverage with smaller coverage areas, which means more sites required in an area.

Capacity sites are sites that are intended to cover a small area (< 500m) but accurately positioned to relieve

existing sites that are congesting. So at time moving locations further from the required areas could create

more issues with quality.

MTN will always look at utilising third party mast/buildings to meet coverage requirements before opting to

build a mast. This is also a cheaper option for MTN, but no 3rd party sites available at planned location.

Aesthetics and mast placement are carefully considered when a site is being planned/built.

It is therefore recommended that the proposed application be submitted as follows:

The application submitted is a special consent application to the Ethekwini South Municipality for Erf 2025

Lovu, situated at 59 Lucky Dube Drive, Lovu, Lovu.

The purpose of the application is as follows:

1. A SPECIAL CONSENT application to construct a telecommunication 36m MAST

INFRASTRUCTURE (CELL PHONE MAST) AND BASE STATION, made in terms of CHAPTER

8 SECTION 28 SUBSECTION 2(A) of the eThekwini Municipality: Planning and Land Use

Management By-Law 2016 read in conjunction with the Spatial Planning and Land Use

Management Act, 2013 (Act 16 of 2013).


23 | P a g e

ANNEXURE A APPLICATION FORM


24 | P a g e

ANNEXURE B LOCALITY MAP


25 | P a g e

ANNEXURE C WINDEED REPORT


26 | P a g e

ANNEXURE D POWER OF TTORNEY


27 | P a g e

ANNEXURE E ZONING MAP


28 | P a g e

ANNEXURE F SURVEYOR GENERAL DIAGRAM


29 | P a g e

ANNEXURE G SITE DEVELOPMENT PLAN/ BUILDING PLAN


30 | P a g e

ANNEXURE H HEALTH AND SAFETY STATEMENT


31 | P a g e

ANNEXURE I NON-LISTED EIA LETTER

a special consent application for a proposed ......the application site is known as the erf 2025...

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