Guidance

Building Digital UK - environmental resource guide August 2023

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.

• From: Building Digital UK
• Published: 8 August 2023

1. Purpose

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:

• a breakdown of scope 1 to 3 Greenhouse Gas emissions (see greenhouse gas protocol page 26)
• scientific targets on air quality, water quality and/or conservation, biodiversity, and resource efficiency/waste reduction
• devolved environmental matters to Scotland, Wales or Northern Ireland
• all relevant legislation
• an exhaustive list of links and resources

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.

2. Review period

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 [email protected]. BDUK aims to review this resource every year up to 2030 (the duration of our programme), and update where applicable.

3. Background

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.

4. BDUK’s role

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.

5. Broadband supplier and mobile operator roles

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.

6. Environmental responsibilities

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

Survey, design, build, maintenance approaches	Context and guidance	Lead organisations
	Network planning
Resilience - climate adaptation/ extreme weather events	Consider the resilience of the network and types of infrastructure materials utilised from cascading failures, specifically in regard to a site’s dependency on the electricity network to extreme weather events (see power section below). Consider if the placement and design of the infrastructure is resilient when on/near sites at risk of coastal change, erosion and flooding. Consider if the placement and design of the infrastructure is resilient when on/in bridges or pipelines due to risk of erosion and flooding. Consider if the placement and design of the subterranean and surface infrastructure is resilient from subsidence that may be caused by shrink/swell from weather events. Consider the resilience of the network and types of materials from weather, specifically high and low temperatures, high winds and lightning. See the telecoms technical report - CCRA-3 Infrastructure Technical Report for information on Climate Change risk to Telecoms Infrastructure (Risks I1, I2, I3 I4, I7 and I13).	Met Office Environment Agency DSIT - Digital Infrastructure, Telecoms Security and Resilience Team The local planning authority where works are planned
Access to power and consumption needs	Location and access to power, and the dependency on the energy grid is critical for digital infrastructure. Encourage positioning of required digital infrastructure, such as cabinets, close to power supply. Local Area Energy Plans by local authorities (not mandatory) may give some insights into wider infrastructure networks. Clean and home grown energy supply is the ambition set out in the Powering Up Britain - The Net Zero Growth Plan March 2023 and low carbon ambitions in 2030 and 2035 (subject to supply) are set out in the British Energy Security Strategy April 2022. At present, in some remote locations, off grid infrastructure such as diesel generators is one of the only viable options. Industry is aware that this is a short term solution and attempts for clean, renewable medium-long term options should be (and are) being actively investigated. This may include scoping cleaner on-site generation, and/or micro-grids (a small-scale electrical grid that uses more than one energy source).	Distributed Network Operators Ofgem Department for Energy Security and Net Zero DSIT BDUK
Survey, design, build, maintenance approaches	Context and guidance	Lead organisations
	Existing infrastructure and locations
Use of existing assets Positioning of infrastructure Development on private land	Working with other digital infrastructure networks and other sectors (such as transport, power and water), to safely utilise existing assets to reduce disturbance to land and minimise environmental impacts. The Local Full Fibre Network Programme created shared assets, which can be found in Tameside, Blackpool, Cambridgeshire, Stoke, Mid-Sussex, Portsmouth, Colchester, and for the Trans-Pennine Rail Initiative. Examples of mobile operators coming together can be seen in the shared rural network, where operators share the infrastructure and minimise the need for additional masts and associated energy. Physical Infrastructure Access avoids the need for carbon intensive street works. The use of existing electricity poles rather than building new poles helps too. Refer to the Barrier Busting Handbook for a range of key guidance on positioning of infrastructure and the Code of Practice for Wireless Network Development in England. Operators should also note the Electronic Communications Code (Conditions and Restrictions) Regulations 2003 (as well as the subsequent 2009, 2013, 2016 and 2017 amendments to those regulations), where Regulation 3 sets restrictions such as those requiring existing infrastructure to be shared where practicable. The Cabinet Siting and Pole Siting Code of Practice 2016 also provides guidance relating to the siting of cabinet and pole installations, including sharing. Check for any national or local design guidelines. When delivering in rural areas, on private land, refer to this National Wayleave Framework 2018, updated Feb 2023. The AssetHub includes asset infrastructure data and the National Underground Asset Register includes data on energy, water and other infrastructure in North-east England, Wales and London.	The local planning authority where works are planned Check with other local industry leads, or other sector leads such as Network Rail, Distribution Network Operators (for sharing of power pole infrastructure), and Ofgem Openreach for situations where Physical Infrastructure Access may be used
Survey, design, build, maintenance approaches	Context and guidance	Lead organisations
	Supply chain
Waste reduction	BDUK is technology neutral, provided gigabit-capable speeds are achieved. However, the key principle around waste is to utilise materials and equipment that last longer, and design operational and delivery processes that reduce waste and have lower carbon emissions. Understanding waste impacts can be identified throughout the lifecycle of the infrastructure, and each phase can have elements of reduce, reuse, recycle. Regulation Position Statement (RPS) 211 - as at 28 April 2023. An update to this regulation is pending and anticipated in 2023/2024. We will refresh the guidance at that time. The Environment Agency (EA) has been working with Street Works UK (the national trade association representing utilities) to devise a standard for the classification of street works waste (2023). The EA and the industry are developing a system for the longer term. For example, when any street is excavated, a proportion of the waste will be tested for whether it is hazardous or not. Those results are likely to be recorded using a combination of a) street manager - The Department for Transport’s digital service for recording street works information in England and Wales and/or b) The National Underground Asset Register - A comprehensive digital map of underground pipes and cables (as shown above).	General industry collaboration Environment Agency Street Works UK
Data collection	In the early stages of the development of clear and consistent science-based target initiatives for the telecoms industry, we support suppliers and operators to collect and measure environmental impacts more widely across the supply chain. Industry is collaborating on data standardisation. BDUK will be reporting on environmental benefits of their interventions, and some of this data will provide key insights and learnings. Direct impacts can include disturbance of land, air, or water, and impacts of dust and heat generation on air quality. Indirect impact examples include secondary benefits such as being able to work from home and reducing commute emissions.	BDUK evaluation team Industry led - Digital Connectivity Forum - Climate Change and Sustainability Working Group - established in April 2023

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

Designated site type	Environmental guidance and context	Lead organisations in England
Areas of Outstanding Natural Beauty (AONB)	These are designated exceptional landscapes whose distinctive character and natural beauty are precious enough to be safeguarded in the national interest. As at July 2023, there are 46 AONBs being protected and enhanced for nature, people, business and culture. The National Association’s Landscapes for Life (with interactive maps) includes an overview of local values and what is of importance to an area and useful at early stages of survey and design. Suppliers will need to consider local AONB Management Plans before installing or utilising underground assets in these locations. Refer to the Electronic Communications Code (Conditions and Restrictions) Regulations 2003 and amendments below.	The National Association of AONBs The local planning authority where works are planned Defra
Biodiversity improvements and biodiversity gain	Where full planning permission is required for digital infrastructure, you will need to have a minimum of 10% biodiversity gain included and includes a 30 year maintenance plan (section 100) of the Environment Act 2021. The Act also requires the Secretary of State to set a species abundance target. See the England Biodiversity Plan 2020, and the joint review of biodiversity indicators, and Natural England Bio-diversity Net Gain Brochure 2022 for more details. Check each local area for specifications on percentage of improvement (as this can be more than 10%), and specification on location for improvements e.g onsite or offsite.	Natural England Check with the local planning authority where works are planned
Heritage Assets	Heritage assets may be located within the wider natural environment so the Heritage asset guidance for broadband suppliers may also provide further assistance. The aim is to avoid harm to heritage assets (in, on, under, within).	The local planning authority where works are planned Historic England
Local Nature Recovery Strategies (LNRS)	These are new spatial planning strategies for nature that support the delivery of the mandatory requirement of biodiversity (above). The pilots in 2021 included Cornwall, Buckinghamshire, Greater Manchester, Northumberland and Cumbria, prior to embedding into the Environment Act. As at June 2023, there are 48 strategy areas in England - see the Defra Map of local nature recovery strategies: areas and responsible authorities. There are also opportunities to get involved and be a delivery partner by signing up with Local Nature Recovery Networks/Strategies (LNRS).	The local planning authority where works are planned
Marine Protected Areas, including Marine Conservation Zones (MCZs)	Designated by the government to protect nationally important marine species, habitats, ecological processes and features of geological/geomorphological importance. Find out more about MCZ designations and factsheets at designations in England and Marine Protected Areas conservation advice packages. Works affecting a MCZ may need a licence Make a marine licence application. In addition, the International Cable Protection Committee September 2022 report 5 for environmental updates relating to marine protection zones and environmental concerns for subsea infrastructure may be useful. Refer to the Electronic Communications Code and amendments below.	Marine Management Organisation Environment Agency
National Parks	National Parks Accord - broadband - January 2023 by BDUK. MOA National Parks Accord - January 2023 by National Parks England and Mobile Operators Association. Refer to the Electronic Communications Code (Conditions and Restrictions) Regulations 2003 and amendments below.	National Parks England National Parks Authorities
Protected Nature Sites (PNS) including: Special Areas of Conservation (SAC) Special Protection Areas (SPA)s, Sites of Special Scientific Interest (SSSIs), and Wetlands of International Importance (Ramsar wetlands)	Special Conservation Areas (SAC) are designated to conserve natural habitats and wildlife of European importance. Special Protection Areas (SPAs) are classified to protect bird species of European importance and regularly occurring migratory birds. Sites of Special Scientific Interest (SSSI) are designated by Natural England to protect areas of special interest for its flora, fauna, geological or physiographical features. These are coastal (and terrestrial) designations with some sites protecting marine features. Ramsar sites are internationally significant wetland sites. Find information about Protected Natures Sites at Site Search and the Defra interactive magic map, and Joint Nature Conservation Committee and list of special protected areas. Natural England have developed and published a set of Impact Risk Zones (IRZs) which are a geographic information system tool designed to make a rapid initial assessment of the potential risks posed by particular development proposals affecting all protected nature sites. They define zones around each site which reflect the particular sensitivities of the features for which it is notified and indicate the types of development proposal which could potentially have adverse impacts. The IRZs can be accessed via Magic Maps Application or downloaded here. Natural England offer a pre-application discretionary advice service for proposals which may affect PNS see developers get advice on your planning proposals. Guidance on construction near protected areas and wildlife. Guidance for broadband suppliers working in protected nature sites March 2023. Refer to the Electronic Communications Code (Conditions and Restrictions) Regulations 2003 and amendments below.	Natural England Defra Joint Nature Conservation Committee JNCC - UK Adviser to government on Nature Conservation
Protected Species	You may need a protected species licence if you plan to disturb or remove wildlife or damage habitats. For more details see wildlife licences. Natural England has published a set of Standing Advice which is general advice covering a number of topics including protected species and ancient woodland. See here for guidance on preparing a planning proposal to avoid harm or disturbance to protected species.	Natural England
UNESCO world heritage sites	This includes biosphere reserves, and geoparks. See interactive map by UNESCO.	UNESCO National Commission for the UK

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.

7. Network Planning process

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.

1. Review power needs and access, early. Design with renewable options - where possible.

2. 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.

3. Review existing and future infrastructure networks. Look at sharing access (includes other infrastructure sectors). Engage with local stakeholders early.

4. Consider how the build is designed to be weather resilient and adapt to climate change.

5. Design ways to support enhancements ie in biodiversity delivery partnerships, social value, tree planting and peatland restoration, and carbon reduction solutions.

6. Be aware of and comply with the mandatory requirements, such as the Environment Act 2021 for England.

7. 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

8. Other important information sources

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

Carbon reporting and calculations	The biodiversity consultancy provides science-based targets for nature: tools, data and guidance on interactions and impacts on the natural world.
	The Carbon Trust provides expertise for climate change and carbon emissions.
	Certified B corporations (B Corp) are companies that are verified by B Lab to meet high standards of social and environmental performance, transparency, and accountability. It includes a B Corp legal requirement to be adopted verbatim within an organisation’s decision-making processes, and to be filed with Companies House.
	The Digital Connectivity Forum - telecoms suppliers created a climate and sustainability work group committed to reducing emissions and helping the sector achieve standardisation.
	The greenhouse gas protocol (an international organisation) includes standards and training on corporate accounting and carbon emissions, and corporate value chain.
	The revised PAS 2080 standard and updated guidance document (2023) on carbon management in buildings and infrastructure may assist when undertaking telecoms build within or near large construction projects.
	The supply chain sustainability school and/or the SME Climate Hub have free online resources, training, and carbon calculators to help organisations understand their environmental impacts.
Government (central)	The Department for Energy Security and Net Zero leads on net zero strategies, energy security and green industry funding schemes. This includes the recent strategies on Powering Up Britain: Energy Security Plan 2023 and Powering Up Britain: net growth plan 2023.
	The National Highways net zero construction and emission plan has a timeline and roadmap to their net zero journey. This may have elements that are useful to digital infrastructure, albeit digital build is at a much more granular scale.
Industry events (annually)	Catapult Network - support for network operators - whole system approaches.
	Connected North and the sister event Connected Britain led by Total Telecom.
	Deloitte’s Media and Telecoms and Beyond Conference, including the May 2023 recording on Business Leadership on Net Zero
	Future Net Zero - Big Zero Show a subsidiary of Energy Live News Ltd.
	Tech UK - the UK’s technology trade association has a useful page of events covering climate, sustainability and environment.
Publications (annually)	Climate Change Committee annual progress reports for the UK government.
	Natural England - preparing for mandatory biodiversity net gain and brochure includes definition on biodiversity.
	The PwC report Building Public Trust Awards: Climate Change Reporting 2022, includes leading UK companies in climate change reporting. The announcements occur annually in October.

Key definitions

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

Published 8 August 2023