Building Digital UK - environmental resource guide August 2023
This guide includes a selection of environmental and climate considerations to support the rollout of digital infrastructure. It is based on England jurisdiction, but has direct relevance across devolved administrations too.
1. Purpose
To provide broadband suppliers, mobile operators and their subcontractors and agents with a key reference point, themed around protecting and improving the environment, when delivering digital infrastructure networks in England. The guide aims to encourage a reasonable standard of environmental awareness and implementation during survey, design, build and operation. There may be additional benefits, such as helping the sector plan and prepare for the impacts of climate change too.
While this guide is for Building Digital UK (BDUK) funded infrastructure 鈥 in the absence of any environmental policy for digital infrastructure networks - it can be a starting point for other digital infrastructure networks, such as those funded through UK Shared Prosperity Fund, and/or commercial rollout (funded privately).
It also supports the rollout of hybrid and standalone satellite solutions, particularly in very remote areas where equipment is likely to have greater exposure to extreme weather events and limited access to the mains power grid. At present, satellite terminals also have higher power consumption requirements than traditional fixed or mobile connectivity making climate resilience and energy access especially important.
Although this guide focuses on England, each devolved administration may have different build requirements in regard to environmental protection and improvements, so please check what the equivalent is in those locations.
It does not include:
- a breakdown of scope 1 to 3 Greenhouse Gas emissions (see page 26)
- scientific targets on air quality, water quality and/or conservation, biodiversity, and resource efficiency/waste reduction
- environmental matters devolved 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鈥檚 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 and Wales, under the Environment Act 2021, the mandatory (effective from 13 April 2023) and the (effective from February 2024) altered 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.听听听听
In addition, the duty to seek to further the statutory purposes of protected landscapes, introduced in late 2023, see ,听means that permitted development rights for digital infrastructure in National Parks, the Broads and National Landscapes (areas of outstanding natural beauty) are subject to strengthened requirements. Development or activities in these locations require further considerations to be met as communication providers are statutory undertakers under the , and consequently subject to the duty.
Many local authorities across England will have local strategies and plans on how they wish to make environmental improvements and therefore there is no one size fits all approach in designing and building digital infrastructure.
Likewise, there is no one standardised approach or single sector lead for non-mandatory environmental improvements on digital infrastructure networks, and we understand not all organisations have access to the same resources or finances to support environmental action. This guide may serve as the impetus for change - supporting improvements and helping the sector with climate adaptation solutions. It is intended to complement existing work by suppliers/groups already leading in environmental best practice, such as the Digital Connectivity Forum.
2. Review period
BDUK aims to review this resource annually over the duration of our programmes. Feedback and suggestions relating to this document can be sent to strategy@bduk.gov.uk.
3. Background
Two main themes that outline why we have this guidance include:
- Environmental protection and improvements
- Wider climate change considerations and net zero emissions
This guidance focuses on the first with regards to delivery of BDUK programmes. It is important to include a snapshot of the broader context on climate change and net zero emissions, which some of the environmental changes stem from.
Environmental protection and improvements
Post-Brexit, the government redefined environmental protection for air quality, water and resource efficiency/waste reduction in the . This includes biodiversity net gain as a mandatory part of the planning permission process. The scrutinises the government鈥檚 environmental performance and can 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鈥檚 25 year environmental plan) sets out how the government will work with landowners, communities and businesses to improve the environment. In 2025, the UK government outlined that protected landscapes are part of the wider vision to reach 30by30 (protecting 30% of UK鈥檚 land and sea by 2030). This includes initiatives to boost nature鈥檚 recovery, increase access to the outdoors and tackle climate change.
Climate change and net zero emissions
The UK was part of the Paris Agreement 2015 to limit global temperature rise to well below 2 degrees and pursue efforts to limit the increase to 1.5 degrees above pre-industrial levels. Following this, the 25 year environment plan: A Green Future 2018听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 ).
With regards to digital infrastructure, recent research commissioned by DSIT and DCMS reports (for the first time) environmental impacts of the digital sector in the UK. The research distributes carbon emissions into user devices (>50%), networks (13%), data centres (35%); and details the projected electricity demand from each of these categories. See webpage for the data report and results.
The top three climate risks identified for digital infrastructure (reported in are: cascading failures across infrastructure sectors i.e. digital and power dependencies; flooding; and extreme weather events, such as high winds, high and low temperatures and lightning.听
Also see section 8 for additional information sources.
4. BDUK鈥檚 role
BDUK is an executive agency within the Department for Science, Innovation and Technology (DSIT), that funds fast and reliable digital connectivity across the UK. It leads two major infrastructure programmes referred to as Project Gigabit, which supports the government鈥檚 ambition for 99% gigabit-capable broadband coverage by 2032 through subsidised delivery in hard-to-reach areas; and the Shared Rural Network, a joint investment with the UK鈥檚 mobile network operators to improve 4G coverage in the most remote parts of the country.
We evaluate environmental benefits and disbenefits associated with our programmes, including social value outcomes; and have responsibilities to assess climate risk and adaptation. We continue to learn and adapt (alongside the sector) how digital infrastructure networks can support wider environmental and net zero requirements. 听
Ministers of the Crown (including the minister responsible for BDUK) 鈥渕ust, when making policy, have due regard to the policy statement on environmental principles鈥 effective from 1 November 2023, by virtue of the Environment Act 2021. BDUK has taken a proportionate approach to inform suppliers and operators with environmental considerations in delivery 鈥 in line with the prevention principle.
5. Broadband supplier and mobile operator roles
This environmental resource guide helps broadband suppliers and mobile operators who receive government funding to deliver gigabit infrastructure networks in accordance with provisions in contracts, grant agreements, or the terms and conditions, and in accordance with key legislation.
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 provisions (including biodiversity gain in planning) and the provisions in protected landscapes which overlap with the (as well as the subsequent , , and amendments to those regulations) and the .
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 incorporate specific approaches for designated sites and stakeholder engagement as early as possible.
6. Environmental responsibilities
The implementation and maintenance of digital infrastructure contributes to environmental impacts related to disturbance of land, air or water, dust and heat generation听. Emissions are also created from build activities and when in use - noting that gigabit is deemed more energy efficient than former copper technology. 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 (), 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 landowners that installation and maintenance will not affect efforts to protect or enhance biodiversity or conservation.
We encourage meaningful correspondence with key organisations and stakeholders 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 |
---|---|---|
听 | Network planning | 听 |
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鈥檚 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 portal for climate information related to local areas, to help in developing your build, risk assessment and adaptation plans. See the telecoms 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. Refer to Ofcom guidance on ; and . Encourage positioning of 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. Further direction may also be included in the 10 Year Infrastructure Strategy by HM Treasury anticipated in summer 2025.听 Access to renewable cleaner energy via the grid is ideal. Alternative solutions 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 Department for Science Innovation and Technology BDUK Ofcom |
Survey, design, build, maintenance approaches | Context and guidance | Lead organisations |
听 | Existing infrastructure and locations | 听 |
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. Refer to guidance on and the Barrier Busting Handbook for sharing electricity poles and a range of key guidance on positioning of infrastructure. 听See useful . Further guidance on JuPs is likely as access needs increase. avoids the need for carbon intensive street works. Also refer to the Barrier Busting Handbook (as above) and the . Operators should also note the (as well as the subsequent , , and amendments to those regulations), where Regulation 3 sets restrictions such as those requiring existing infrastructure to be shared where practicable. 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 includes asset infrastructure data and the National Underground Asset Register includes data on energy, water and other infrastructure in England, Northern Ireland and Wales. |
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 |
听 | Supply chain | 听 |
Waste reduction Waste classification |
BDUK is technology neutral, provided gigabit-capable speeds are achieved. However, the key principle around material waste is to utilise and share existing infrastructure (poles and ducts). It is important to consider the longevity of materials and equipment, and design operational and delivery processes that reduce waste and have lower carbon emissions. Understand waste impacts throughout the lifecycle of the infrastructure, and the ability to reduce, reuse, recycle in each phase. Follow Regulation Position Statement (RPS) 298 and 299 for excavation waste (January to 30th Sept 2025). From 1st October 2025, either adhere to the or WM3 鈥 waste classification technical guidance. As of 2024, sampling and testing showed approximately 15% of utilities excavation meets one or more criteria to be described as hazardous waste. |
General industry collaboration Environment Agency Street Works UK |
Data collection | BDUK encourages suppliers and operators to collect and measure environmental impacts across the supply chain to assist with environmental evaluation of our programmes. Industry is collaborating on data standardisation. |
BDUK evaluation team Industry led - - established in April 2023 |
In addition, 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.
Table 2: Designated site resource guidance
Designated site type | Environmental guidance and context | Lead organisations in England |
---|---|---|
Areas of Outstanding Natural Beauty - national landscapes | Changes to legislation 鈥 renamed as protected landscapes. See section below. | N/A |
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 . The Act also requires the Secretary of State to set a species abundance target. See Biodiversity net gain planning practice guidance 2024; and the England Biodiversity Plan 2020, and the joint review of biodiversity indicators, and 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). 听There are 48 strategy areas in England 鈥 see the Defra Map of local nature recovery strategies which includes 4 published strategies as at May 2025. 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 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 | Changes to legislation - see protected landscapes section below. | N/A |
Protected Landscapes (the collective term for National Parks, National Landscapes 鈥 formerly Areas of Outstanding Natural Beauty, and the Norfolk and Suffolk Broads | There is a legal duty to 鈥榮eek to further the purposes鈥 of protected landscapes under section 245 of the Levelling Up and Regeneration Act 2023. This duty is a requirement upon statutory undertakers (which includes telecommunication providers) which applies to activities undertaken via permitted development rights. Government guidance outlines that telecommunication providers are required to evidence how they have sought to benefit the statutory purpose(s) of protected landscapes, prior to providing telecommunication apparatus and services in these locations. See Guidance for relevant authorities on seeking to further the purposes of Protected Landscapes - 天美影院 For National Parks, the prime statutory purpose is conserving and enhancing natural beauty, whilst the conservation and enhancement of wildlife and cultural heritage are important considerations. They also have a statutory purpose to promote opportunities for public enjoyment. The Broads Authority has an additional statutory purpose which is to protect the interests of navigation. Core engagement principles are outlined in the National Parks Accord - broadband 2023; and mobile, by National Parks England and Mobile Operators Association. National Landscapes have a single statutory purpose to conserve and enhance natural beauty. The includes an overview of local values and what is of importance to an area and useful at early stages of survey and design.br> Refer to local protected landscape management plans and any local nature recovery strategies for scoping ideas. See guidance for relevant authorities (includes statutory undertakers 鈥 telecommunication providers) released Dec 2024; and the targets and outcomes framework January 2024. Look out for integrated or separate climate adaptation management plans to be introduced by 2028, required by the Third National Adaptation Programme. Refer to the Electronic Communications Code (Conditions and Restrictions) Regulations 2003 and amendments below. |
听 The national park authority where works are planned The local planning authority (for national landscapes) where works are planned |
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 and the Defra , and Joint Nature Conservation Committee and . 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 or downloaded 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. |
Defra Joint Nature Conservation Committee |
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 by UNESCO. | UNESCO National Commission for the UK |
Suppliers and Operators (and their subcontractors) must, where applicable, comply with the (as well as the subsequent , , and amendments. 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. When notifying the relevant authority, you should explain how the 鈥榙uty to seek to further the purposes of鈥 has been considered and performed.
7. Network Planning process
The visual and text below shows a simple approach 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.
This image illustrates 7 ways to support delivery of digital infrastructure with biodiversity, environmental improvements and net zero considerations at the forefront.
- Review power needs and access, early. Design with renewable options - where possible.
- 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.
- Review existing and future infrastructure networks. Look at sharing access (includes other infrastructure sectors). Engage with local stakeholders early.
- Consider how the build is designed to be weather resilient and adapt to climate change.
- Design ways to support enhancements ie in biodiversity delivery partnerships, social value, tree planting and peatland restoration, and carbon reduction solutions.
- Be aware of and comply with the mandatory requirements, such as the Environment Act 2021 for England, and the duty to seek to further the purposes of protected landscapes.
- 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 systems that support them
8. Other important information sources
If new to net zero and carbon reduction or wanting to understand more on biodiversity and the environment, Table 3 includes a few sources as a starting point.
Table 3. Additional information sources for climate awareness and adaptation approaches
Carbon reporting and calculations |
The provides science-based targets for nature: tools, data and guidance on interactions and impacts on the natural world. | 听 |
听 | The provides expertise for climate change and carbon emissions. | 听 |
听 | 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鈥檚 decision-making processes, and to be filed with Companies House. | 听 |
听 | The - telecoms suppliers created a climate and sustainability work group committed to reducing emissions and helping the sector achieve standardisation. See the 2023 Net Zero Guidance for SMEs in the Telecoms Sector ; and the 2025 initiative encouraging those in the supply chain to reduce emissions . | 听 |
听 | The (an international organisation) includes standards and training on corporate accounting and carbon emissions, and corporate value chain. | 听 |
听 | The revised standard and (2023) on carbon management in buildings and infrastructure may assist when undertaking telecoms build within or near large construction projects. | 听 |
听 | The and/or the have free online resources, training, and carbon calculators to help organisations understand their environmental impacts. | 听 |
Government (central) | The Department for Energy Security and Net Zero leads on the government鈥檚 mission to make the UK a clean energy superpower. | 听 |
听 | The 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. | 听 |
听 | (telecommunications regulator) does not have duties to pursue environmental or climate change policy goals, but has a direct interest in ensuring resilience to climate change | 听 |
Industry events (annually) |
Connected North and the sister event Connected Britain led by . | 听 |
听 | 顿别濒辞颈迟迟别鈥檚 , including the May 2023 recording on | 听 |
听 | a subsidiary of Energy Live News Ltd. | 听 |
听 | - the UK鈥檚 technology trade association has a useful page of events covering climate, sustainability and environment. | 听 |
Publications (annually) |
annual progress reports for the UK government. | 听 |
听 | The PwC report , includes leading UK companies in climate change reporting. The announcements occur annually in October. | 听 |
9. Key definitions
outlined by Intergovernmental Panel on Climate Change, Climate Change 2022: Impacts, Adaptation and Vulnerability Glossary, 2022
outlined by Joint Nature Conservation Committee (May 2023)
Biodiversity net gain outlined by Department for Environment, Food and Rural Affairs.
defined by the Climate Change Committee
Environmental effect outlined in the Environmental Principles Policy Statement (January 2023)
outlined in the Environment Act 2021
outlined in the Environment Act 2021
10. Summary of updates from 2023 to 2025 (version 2)
Minor alterations have been made to simplify the document and remove duplication. The impetus for change followed amendments in legislation, regulation, and supporting guidance. Here is a summary of key additions:
- added references to the climate change risk assessment, national adaptation plan and the data report on UK digital sector environmental impacts
- added the duty to seek to further the statutory purposes of protected landscapes, alongside permitted development rights. Includes future climate adaptation management plans
- added the updated guidance on biodiversity duty net gain
- added the latest updates to waste (excavation) regulations and links
- added a link to Ofcom consultation outcome on resilience of networks and their role
- added links to Joint User Pole (electricity network) guidance
- added a link to Local Authority Climate Service (Met Office)
- update government policies i.e. DESNZ role
- added a link to SME IT and Telecom sector guidance/UK Business Climate Hub Net Zero Plan
- added a definition for 鈥榓daptation鈥
Updates to this page
-
Please see the detailed list of amendments in section 10. The updates follow changes to legislation, such as the new protected landscapes duty which places a requirement on telecommunication providers to demonstrate how they have sought to further the purposes for these spaces - alongside permitted development. It also includes updates to wider environmental and delivery guidance, such as biodiversity net gain guidance, joint user pole best practice and waste regulations. We have also included research from 2024 on environmental impacts of the digital sector in the UK.
-
First published.