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]
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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).
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ANNEXURE A APPLICATION FORM
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ANNEXURE B LOCALITY MAP
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ANNEXURE C WINDEED REPORT
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ANNEXURE D POWER OF TTORNEY
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ANNEXURE E ZONING MAP
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ANNEXURE F SURVEYOR GENERAL DIAGRAM
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ANNEXURE G SITE DEVELOPMENT PLAN/ BUILDING PLAN
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ANNEXURE H HEALTH AND SAFETY STATEMENT
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ANNEXURE I NON-LISTED EIA LETTER
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