Is Planning Permission Required for a WiFi Mast on a Caravan?
We are often asked to form a view on whether planning permission is required to install a WiFi mast or similar electronic communication apparatus onto a caravan.
The answer to this question, as so often in planning, is “it depends”.
Legislative Framework
Whether any structure requires planning permission turns on two primary questions:
- Whether the works constitute “development” under section 55 of the Town and Country Planning Act 1990 (TCPA 1990); and
- Whether the proposal benefits from permitted development rights under the The Town and Country Planning (General Permitted Development) (England) Order 2015
Part 16 of Schedule 2 to the GPDO 2015 sets out permitted development rights for electronic communications development, including the installation of masts, antennae, and associated apparatus used for telecommunications and data transmission.
Nature of the Installation
Typical proposals involve:
- A mast acting as a supporting structure; and
- An antenna or similar transmission equipment;
- Installed on a caravan rather than a freestanding ground-based structure.
For planning purposes, a caravan is generally treated as a “moveable structure” rather than a “building”. This distinction is relevant when assessing the applicability of the individual Classes of permitted development rights within Part 16, and whether a proposed installation is exempt from needing to obtain planning permission.
Assessment of Part 16 Permitted Development Rights
Class A – Code Operators
Class A applies only to development by or on behalf of electronic communications code operators, subject to land control and compliance with the electronic communications code, so is unlikely to apply.
Class B – Masts and Antennae on Buildings or Structures
Class B permits the installation of antennae and supporting structures on buildings or other structures, subject to conditions. A key constraint is that the existing building or structure must be at least 15 metres in height. A caravan will not satisfy this requirement.
Class C – Antennae Only on Buildings or Structures
Class C applies solely to antennae and does not include supporting structures such as masts. Where both are present, the Class cannot be relied upon.
Class D – Driver Information Systems
Class D is limited to operators licensed under the Road Traffic (Driver Licensing and Information Systems) Act 1989. It is not relevant to WiFi or general communications installations.
Class E – Universal Postal Service Providers
Class E applies only to universal postal service providers and is also not relevant to caravan sites.
Position on Permitted Development Rights
None of the Classes within Part 16 are likely to apply to a mast and antenna installed on a caravan. Accordingly, many mast and antenna installations on caravans are unlikely to benefit from permitted development rights under the GPDO 2015 and may therefore require express planning permission.
Whether the Works Constitute “Development”
Planning permission is only required if the works amount to “development” under section 55 TCPA 1990.This includes “building operations”, which extends to physical works normally undertaken by a person carrying on business as a builder. The installation of a mast and antenna typically involves physical attachment and assembly and is therefore likely to fall within this definition. However, some local planning authorities take the view that installation on a caravan—given its mobile and non-permanent character—lacks sufficient permanence or physical attachment to constitute development requiring planning permission.
Part 16 expressly contemplates installation on “buildings or structures”, indicating a broad approach to potential supporting surfaces for electronic communications equipment.
This supports the view that many mast and antenna installations on caravans can constitute development where they involve physical works of sufficient permanence or significance, even where the supporting structure is not a building or dwelling.
Conclusion
Whether planning permission is required for a WiFi mast installed on a caravan involves a two-stage assessment:
- First, whether the works constitute “development” under the TCPA 1990; and
- Second, whether the works benefit from permitted development rights under Part 16 of the GPDO 2015.
In most cases, such installations are unlikely to fall within any of the relevant Part 16 Classes of permitted development. On that basis, express planning permission will generally be required.
Ultimately, the issue is one of planning judgment, and local planning authorities may take a contextual approach depending on the nature, scale, and permanence of the installation.