HUAWEI TECHNOLOGIES SOUTH AFRICA (PTY) LTD
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APPLICATION FOR A SPECIAL CONSENT IN TERMS
OF THE MUNICIPAL BY-LAWS PROVIDED FOR BY
THE SPATIAL PLANNING AND LAND USE
MANAGEMENT ACT, 201 (ACT 16 OF 2013) TO
CONSTRUCT A TELECOMMUNICATION MAST
HUAWEI TECHNOLOGIES SOUTH
AFRICA (PTY) LTD
WESTWAY OFFICE PARK
17 THE BOULEVARD
WESTVILLE 3630
APPLICATION LODGED AT ETHEKWINI CENTRAL MUNICIPALITY IN
TERMS OF THE ETHEKWINI METROPOLITAN MUNICIPALITY SPATIAL
PLANNING AND LAND USE MANAGEMENT BY-LAW, 2017, CHAPTER 8
SECTION 28 (2A), READ IN CONJUNCTION WITH THE SPATIAL
PLANNING AND LAND USE MANAGEMENT ACT, 2013 (ACT 16 OF 2013)
FOR A SPECIAL CONSENT APPLICATION TO CONSTRUCT A
TELECOMMUNICATION 36M MONOPOLE INFRASTRUCTURE (CELL
PHONE MAST) AND BASE STATION ON ERF 330 UMLAZI-H, SITUATED
AT 24 CODESA AVENUE, UMLAZI H, DURBAN, 4066.
Prepared By:
Huawei Technologies South Africa (PTY) LTD
Westway Office Park
17 The Boulevard
Westville
3630
For Enquiries:
Mr Sanele Khumalo | Cell: 079 567 2602 |
Email: sanele.khumalo@huawei.com
Or
Miss. Minenhle Nzimande | Cell: 081 774 4672|
Email: mininhle.nzimande@huawei.com
i|Page
Contents
List of Figures ...................................................................................................................................... i
List of Tables ........................................................................................................................................ i
Annexures ............................................................................................. Error! Bookmark not defined.
Executive Summary........................................................................................................................... ii
1. Introduction ................................................................................................................................. 1
1.1 Application ........................................................................................................................ 1
2. Property Detail ............................................................................................................................ 1
2.1. Ownership Details........................................................................................................... 1
2.2. Power of Attorney ........................................................................................................... 1
2.3. Locality .............................................................................................................................. 1
2.4. Physical characteristics, existing and surrounding land uses .......................... 2
2.5. Current Zoning................................................................................................................. 2
2.6. Land Use ........................................................................................................................... 3
2.7. Restrictive Title Conditions .......................................................................................... 3
3. Development Proposal ............................................................................................................. 4
3.1. Proposed Development ................................................................................................. 4
3.2. Access ............................................................................................................................... 6
3.3. Security.............................................................................................................................. 6
3.4. Noise................................................................................................................................... 6
3.5. Electricity .......................................................................................................................... 7
4. Motivation..................................................................................................................................... 7
4.1. The Spatial Planning and Land Use Management Act, 16 of 2013 (SPLUMA) 7
4.2. EThekwini Municipality Integrated Development Plan ........................................ 9
4.3. The Need and Desirability............................................................................................. 9
4.4. EThekwini Municipality Central Scheme ................................................................ 10
4.4.1 Intention ....................................................................................................................... 10
4.4.2 Site Locational Provisions ...................................................................................... 11
4.4.3. Visual Attributes ........................................................................................................ 13
4.4.4. Health and Safety ...................................................................................................... 14
4.4.5. Environmental Consent/Approval......................................................................... 16
5. Conclusion ................................................................................................................................. 17
List of Figures
Figure 1: Locality Map ............................................................................................................................. 2
Figure 2: Zoning Map .............................................................................................................................. 3
Figure 3: Site Development Plan ............................................................................................................. 4
Figure 4: Building Plan............................................................................................................................. 5
Figure 5: Monopole mast ........................................................................................................................ 5
List of Tables
Table 1: Zoning controls for Residential ................................................................................................. 3
i|Page
Executive Summary
This application is submitted on behalf of Mr Zuma Nhlanhla Vincent and Zuma Gladness
Patricia Jabulile who are the registered owner of Erf 330 Umlazi-H, situated at 24 Codesa
Avenue, Umlazi H, Durban, 4066. Huawei Technologies South Africa intends to submit a
special consent application to construct a telecommunication mast on a portion of the above
mentioned site. The site is approximately 525m2 in extent. There is an existing structure on
site used a dwelling house.
The site is currently zoned as Residential and falls within the eThekwini Central Municipality.
This application entails the special consent application to construct a Base
Telecommunication Transmission Station. The details of the application are as follows:
1. The construction of 36m Monopole with associated infrastructure (cell phone mast)
and base station.
2. The Telecommunication Base Station will consist of:
A 36m telecommunication Monopole;
A 2.4m high steel palisade fence which will run on the boundary of the 8m x
8mbase station site.
A swing gate for access into site
In terms of the site accessibility and locality, the site will be accessed through an access
gate from Codesa Avenue, which will also ensure safety of the residents and isolation from
the rest of the activity on the property.
All relevant authorizations have been obtained such as the environmental authorizations
and the Civil Aviation Authority approval to assess the impacts of the development.
Based on the assessment made in terms of the planning requirements and other pertinent
aspects, the development of a Base Telecommunication Transmission Station will not cause
any negative impacts to human health or the environmental flora and fauna.
ii | P a g e1. Introduction
Huawei Technologies South Africa (PTY) LTD submits this motivation memorandum
together with its annexures to apply for special consent to construct a
telecommunication monopole (cell phone mast) with associated infrastructure and
base station on the property known as Erf 330 Umlazi-H, situated at 24 Codesa
Avenue, Umlazi H, Durban, 4066 located within the eThekwini Central Municipality.
1.1 Application
An application is submitted in terms of the eThekwini Municipality Spatial Planning
and Land Use Management By-Law, 2017, Chapter 9 Section 28 (2a), read in
conjunction with the Spatial Planning and Land Use Management Act, 2013 (Act 16
of 2013) to construct a telecommunication 36m monopole infrastructure (cell phone
mast) and base station.
2. Property Detail
2.1. Ownership Details
As confirmed in the Title Deed T39180/2013, Erf 330, Umlazi H- (hereafter referred
to as the application site), is registered in the names of Mr Zuma Nhlanhla Vincent
and Zuma Gladness Patricia Jabulile. There are no restrictive conditions found within
the title deed that prohibits the construction of a telecommunication infrastructure.
2.2. Power of Attorney
The owner of the property Mr Zuma Nhlanhla Vincent and Zuma Gladness Patricia
Jabulile has given Power of Attorney to Huawei Technologies South Africa (Pty) Ltd.
2.3. Locality
The application site is located on Erf 330 Umlazi-H, situated at 24 Codesa Avenue,
Umlazi H, Durban, 4066.
The coordinates for the sites are as follows:
Latitude: 29°56'54.92"S (S)
Longitude: 30°52'9.07"E (E)
1|PageFigure 1: Locality Map
2.4. Physical characteristics, existing and surrounding land uses
The extent of the application site is 525m2. The area in which the application site is
located is gently sloped. The area is predominantly residential with good
infrastructure.
2.5. Current Zoning
The application site is currently zoned as Residential. The Statement of intent is as
follows:
To provide, preserve, use land or buildings for:
Higher density on all types of residential accommodation.
A wide range of ancillary uses which service the day to day needs of a residential
community
Refer to the table below for permitted land uses and zoning controls.
2|PageFigure 2: Zoning Map
Table 1: Residential Development Parameters
The development parameters for the zone: Residential, in terms of the eThekwini
Central Municipality, is as follows:
Building lines: 1.0m
Side & rear space: 1.0m
Height: 3 Storeys
Coverage: 60%
Floor Area Ratio: Nil
2.6. Land Use
The application site is zoned as Residential. The area is predominantly used as the
mentioned zone. It is surrounded by other residential uses. There are, however,
other land uses that are within close vicinity of the site which is education and public
open space.
Restrictive Title Conditions
There are no restrictive title deed conditions noted that may hinder the proposed
development.
3|Page3. Development Proposal
3.1. Proposed Development
The proposed development is to construct a Telecommunication 36m Monopole with
associated infrastructure (cell phone mast) and base station on Erf 330 Umlazi-H,
situated at 24 Codesa Avenue, Umlazi H, Durban, 4066, located within the eThekwini
Central Municipality (with a 8m x 8m base) which will be situated on the property.
The Telecommunication Base Station will consist of:
A 36m telecommunication monopole;
A 2.4m high steel palisade fence which will run on the boundary of the 6.5m
x 10m base station site.
A swing gate for access into site.
Figure 3: Site Development Plan
4|PageThe tree mast will consist of:
36m monopole as per engineering designs and specifications.
New Telecom Antennas (together with space for proposed future antennas).
A lightning spike (1m included in the height) and aviation lights are situated
on top of the monopole.
Figure 4: Building Plan
5|PageFigure 5: Monopole
3.2. Access
Access to the subject property and site will be from the entrance at Codesa Avenue
and the access to the base station will be gained through a swing gate after accessing
the property at 24 Codesa Avenue, Umlazi H, Durban, 4066.
3.3. Security
In terms of security to the base station site, access will be limited to authorised
personnel only, 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.
3.4. Noise
As technology evolves, 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, Gyro endeavours to always deploy containers that
do not generate high noise levels; this is done by using silent air conditioners and
fans where possible and feasible. Generators may be used in the event of power
6|Pagefailures/ outages, however in extreme power failure circumstances they may be
used for a prolonged period of time.
3.5. 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 the
relevant protocol/ processes.
We do not anticipate that power will be an issue to the local authority with regards
to approving this application.
4. Motivation
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.
4.1. The Spatial Planning and Land Use Management Act, 16 of 2013
(SPLUMA)
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. Furthermore this ensures that spatially everyone within the
community has efficient network coverage which betters their connectivity to the
rest of the world.
Principle of Spatial Sustainability (Section 7.(b))
Given that the cellular masts will not be erected on any property which is deemed
environmentally sensitive or any protected areas, 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
7|Pagethat 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.
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.
Furthermore with a more connected city we give rise to the smart cities concept
and bridge the gap between the digital divide where cities are becoming more
globalized.
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.
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 inquiries is undertaken for every site to ensure that an
optimal position for a cellular telephone mast is identified. 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,
8|Pagepublic 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. In cases where building line relaxation is required, an
application is done to obtain approval before any form of construction may
commence.
4.2. EThekwini Municipality Integrated Development Plan
The Municipal Integrated Development Plan using Census 2011 has found that more
than 50% of households do not have access to internet and basic connectivity.
Installing telecommunication masts in areas with poor network coverage therefore
leans towards goals of the Municipal Integrated Development Framework. The
Municipality also has a programme in place (programme 7.11) which is to provide
secure and reliable network connectivity (both voice and data) to areas that require
connectivity. Therefore this will require good connectivity and coverage by service
providers for municipalities to reach their goals.
4.3. The Need and Desirability
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.
9|PageThe 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
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.
4.4. EThekwini Municipality Central Scheme
4.4.1 Intention
Within the eThekwini Municipality Central Scheme there are provisions made
whereby the Municipality takes into consideration the need for a telecommunication
mast in areas to cover the greater community and to make sure everyone is
connected in the virtual world. The Municipality therefore provides for fair
consideration and guidelines for service providers to develop an effective and
efficient communications systems.
The installation of a Base Telecommunications Transmission Stations shall be
undertaken in such a manner that their impact upon the environment is minimized.
The Base Telecommunications Transmission Station shall be as unobtrusive as
10 | P a g epossible through the choice of materials, colour, and depth of silhouette, height,
and design which shall complement the aesthetics of the surrounding built and
natural environment thereby minimizing the impact upon the environment.
In considering the appropriate location of a Base Telecommunications Transmission
Station, we as Gyro are conscious of sites of historic, cultural and architectural
importance. Cognisance is taken of the impacts installations may have upon open
spaces, coastal regions and prominent ridges and this is therefore completely
avoided.
Gyro as the service provider therefore takes all of the above into account and
therefore proceeds to develop with being fully cognisant to the above.
4.4.2 Site Locational Provisions
When evaluating a site, the following is considered:
Agricultural/Business/Industrial/ areas are the most ideal locations and will
always be the first option if they are located within the 200m – 500m radius of
the nominal point and if the Landlord 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.
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.
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
11 | P a g erequirements, 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 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. Furthermore, since Gyro is a tower
company we will provide opportunities for all networks to operate, hence all
networks in surrounding areas will be at its optimum.
Another 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.
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,
12 | P a g epopulation 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 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. This site has been specifically selected, as being located in a key
position as it can service both the residential community and is ideally situated
to provide optimum cellular network capacity for the current and future needs
in the area which is not static as technology continues to rapidly evolve.
The area in question is an urban area. 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.
The following special consent application will be submitted to the municipality,
in order to gain permission for construction of the proposed tree mast
infrastructure. The application will undergo the full town planning process
before gaining approval i.e. submission of the application, circulation to the
relevant departments, public participation process and the relevant meetings.
4.4.3. Visual Attributes
The property is zoned Residential with the surrounding area being predominantly
residential, 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, the structure
as recommended in the eThekwini Municipality Central Scheme will not conflict
with any natural aesthetics to the natural environment of the surrounding land
13 | P a g euses. Furthermore, the proposed infrastructure is not in the line of sight of any
monuments or infrastructures 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. The Monopole will be camouflaged
and designed to a colour of the preference of the Landlord so that is fits in with
the surrounding of the property.
The Monopole Mast does not emit extensive lighting, which will conflict with the
security measures set out by the Civil Aviation Authority. Permission is obtained
from the Civil Aviation Authority to ensure that the erection of the 36m tower
does not have any impacts on aviation routes.
With the base station being secure away from the general public no advertising
will therefore occur, The base station will be inaccessible through all areas to
the general public, in addition it will be fenced separately from the property to
provide additional security for first the land owner and secondly the public.
4.4.4. Health and Safety
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
14 | P a g eperson'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.
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 (Please see Annexure J for a copy of the
Health and Safety statement from the National Department of Health):
“The Department is therefore satisfied that the health of the general public is
not being compromised by their exposure to microwave emissions of cellular
15 | P a g ebase 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 South African Civil Aviation Authority has granted an obstacle approval for
the proposed development (Please see Annexure K for a copy of the CAA
Obstacle Approval).
4.4.5. Environmental Consent/Approval
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 Department of
Economic Development, Environmental Affairs and Tourism, the mast
installation will not trigger a need for an EIA authorisation. (Please see
Annexure L for a Non listed EIA Letter)
4.5. Alternative Sites
Alternative sites were considered during the initial stages of the proposal but
this option is deemed the most acceptable option in terms of access, existing
land uses in the area and based on the coverage requirements of Radio Network
Planning, Transmission planning and fibre (Fibre to the Street “FTTS”).
The application site is ideally located to provide assisted coverage and capacity
to the area in question. The existing telecommunication sites on their own are
unable to provide good radio coverage in this area and does not hold enough
capacity to serve the dense population that reside here. This compromised radio
coverage and capacity has resulted in many customer complaints in the vicinity
of the area that is demarcated by the yellow circle. The application site is
16 | P a g elocated at a higher ground elevation and therefore the antennas have the
advantage of transmitting signals into the surrounding valleys.
5. Conclusion
Due to the increasing data demands and technology upgrade requirements,
especially in the urban and built up areas, many more sites are required in order to
accommodate the new users. Sites need to have overlapping coverage with smaller
coverage areas, which means that there are 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. Therefore, moving
locations further from the required areas could create more issues with quality.
As a tower service provider we will provide for cellular network to share which will
benefit the entire community of different range of networks. Aesthetics and mast
placement are carefully considered when a site is being planned/built and this will
therefore not compromise the surrounding or the environment in any way.
It is our submission that the merits of this application signify the need for the
proposed development and that all the aspects that may affect this development
have been thoroughly addressed and motivated for. We, therefore recommend that
the application should receive due support for: Consent in terms of the eThekwini
Municipality Spatial Planning and Land Use Management By-Law, 2017, Chapter 8
Section 28 (2A), read in conjunction with the Spatial Planning and Land Use
Management Act, 2013 (Act 16 of 2013) to construct a telecommunication 36m
monopole infrastructure (cell phone mast) and base station on Erf 330 Umlazi-H,
situated at 24 Codesa Avenue, Umlazi H, Durban, 4066.
Nkosinathi Ngubane
Pr Pln: A/2088/2015
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