Building Digital UK - environmental resource guide August 2023
Source: gov.uk (2025-06-19)

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 – 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 greenhouse gas protocol (https://ghgprotocol.org/sites/default/files/standards/ghg-protocol-revised.pdf) 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’s responsibility to satisfy itself on a case-by-case basis that it has complied with all legal requirements.

Why is this resource needed?

In England and Wales, under the Environment Act 2021, the mandatory local nature recovery strategies regulation (https://www.legislation.gov.uk/uksi/2023/341/made) (effective from 13 April 2023) and the biodiversity gain requirements, (https://www.legislation.gov.uk/ukpga/2021/30/part/6/crossheading/biodiversity-gain-in-planning/enacted) (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.

In addition, the duty to seek to further the statutory purposes of protected landscapes, introduced in late 2023, see Levelling Up and Regeneration Act s.245 Protected Landscapes (https://www.legislation.gov.uk/ukpga/2023/55/section/245/enacted), 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 Environment Act 1995 (https://www.legislation.gov.uk/ukpga/1995/25/section/62), 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 xxx@xxx.xx (mailto:xxx@xxx.xx).

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 Environment (https://www.legislation.gov.uk/ukpga/2021/30/contents/enacted) Act 2021 (https://www.legislation.gov.uk/ukpga/2021/30/contents/enacted). This includes biodiversity net gain as a mandatory part of the planning permission process. The Office for Environmental Protection (https://www.theoep.org.uk/) scrutinises the government’s 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 (https://www.gov.uk/government/publications/environmental-improvement-plan) (the first revision of the government’s 25 year environmental plan) sets out how the government will work with landowners, communities and businesses to improve the environment. In 2025, the UK government outlined that protected landscapes are part of the wider vision to reach 30by30 (https://www.gov.uk/government/publications/criteria-for-30by30-on-land-in-england#:~:text=We%20have%20committed%20to%20protecting,can%20contribute%20toward%20this%20target.) (protecting 30% of UK’s land and sea by 2030). This includes initiatives to boost nature’s 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 (https://www.gov.uk/government/publications/25-year-environment-plan) outlined how the government will improve the environment within a generation. The UK was the first parliament in the world (in 2019) to embed 100% net zero carbon emissions by 2050 into legislation. In 2021, the government set an ambitious target to reach a third of this by reducing emissions to 78% by 2035, compared to 1990 levels (see Climate Change Act 2008 (https://www.legislation.gov.uk/ukpga/2008/27/contents)).

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 University of Cambridge repository (https://www.repository.cam.ac.uk/items/06d282c4-ff66-4f7c-a5b5-64184b024830) webpage for the data report and results.

The top three climate risks identified for digital infrastructure (reported in UK Climate Change Risk Assessment 2022) (https://assets.publishing.service.gov.uk/media/61e54d8f8fa8f505985ef3c7/climate-change-risk-assessment-2022.pdf) 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.

Also see section 8 (#section8) for additional information sources.

4. BDUK’s role

BDUK is part of the Department for Science, Innovation and Technology (DSIT), delivering fast and reliable digital connectivity across the UK. It leads two major infrastructure programmes referred to as Project Gigabit, which supports the government’s 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’s 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.

Ministers of the Crown (including the minister responsible for BDUK) “must, when making policy, have due regard to the policy statement (https://www.gov.uk/government/publications/environmental-principles-policy-statement) on environmental principles” 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 – 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 Environment Act 2021 (https://www.legislation.gov.uk/ukpga/2021/30/part/6/crossheading/biodiversity-gain-in-planning/enacted) provisions (including biodiversity gain in planning) and the Levelling-up and Regeneration Act 2023 (https://www.legislation.gov.uk/ukpga/2023/55/section/245/enacted) provisions in protected landscapes which overlap with the Electronic Communications Code (Conditions and Restrictions) Regulations 2003 (https://www.legislation.gov.uk/uksi/2003/2553/made) (as well as the subsequent 2009 (https://www.legislation.gov.uk/uksi/2009/584/contents/made), 2013 (https://www.legislation.gov.uk/uksi/2013/1403/contents/made), 2016 (https://www.legislation.gov.uk/uksi/2016/1049/contents/made) and 2017 (https://www.legislation.gov.uk/uksi/2017/753/contents/made) amendments to those regulations) and the Communications Act 2003 (https://www.legislation.gov.uk/ukpga/2003/21/schedule/3A).

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 . 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 (Climate Change Committee Progress Report June 2023 (https://www.theccc.org.uk/publication/2023-progress-report-to-parliament/#recommendations-to-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 (https://www.gov.uk/government/publications/barrier-busting-handbook/barrier-busting-handbook) 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

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

Suppliers and Operators (and their subcontractors) must, where applicable, comply with the Electronic Communications Code (Conditions and Restrictions) Regulations 2003 (https://www.legislation.gov.uk/uksi/2003/2553/contents/made) (as well as the subsequent 2009 (https://www.legislation.gov.uk/uksi/2009/584/contents/made), 2013 (https://www.legislation.gov.uk/uksi/2013/1403/contents/made), 2016 (https://www.legislation.gov.uk/uksi/2016/1049/contents/made) and 2017 (https://www.legislation.gov.uk/uksi/2017/753/contents/made) 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 ‘duty to seek to further the purposes of’ 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

9. Key definitions

Adaptation (https://apps.ipcc.ch/glossary/) outlined by Intergovernmental Panel on Climate Change, Climate Change 2022: Impacts, Adaptation and Vulnerability Glossary, 2022

Biodiversity (https://jncc.gov.uk/our-work/uk-biodiversity-indicators/#:~:text=Biodiversity%20is%20the%20variety%20of,natural%20systems%20that%20support%20them.) outlined by Joint Nature Conservation Committee (May 2023)

Biodiversity net gain (https://www.gov.uk/government/collections/biodiversity-net-gain) outlined by Department for Environment, Food and Rural Affairs.

Climate change (https://www.theccc.org.uk/what-is-climate-change/) defined by the Climate Change Committee

Environmental effect (https://www.gov.uk/government/publications/environmental-principles-policy-statement/environmental-principles-policy-statement#:~:text=Meaning%20of%20'environmental%20effect'&text=a%20primary%20effect%20or%20secondary,medium%2Dterm%20or%20long%2Dterm) outlined in the Environmental Principles Policy Statement (January 2023)

Environmental protection (https://www.legislation.gov.uk/ukpga/2021/30/section/45/enacted) outlined in the Environment Act 2021

Natural Environment (https://www.legislation.gov.uk/ukpga/2021/30/section/44/enacted) 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 ‘adaptation’