County of Brant staff presented the final draft of the County’s updated Telecommunication Tower Protocol to councillors during the regular council meeting on Tuesday, February 11, 2025.
What is a telecommunication tower?
Telecommunication towers are structures which support antennas that transmit and receive communication signals. The towers, which are federally regulated by Innovation, Science and Economic Development (ISED) Canada under the Radiocommunication Act, are used for mobile phones, radio, television, and other communication services.
What is the purpose of a Telecommunication Tower Protocol?
To define and outline the local land use authority’s consultation process and to provide guidelines for assessing communication tower and antenna site proposals within the county to determine if approval to move forward should be granted. Overall, it provides guidance to the telecommunications industry, County staff, Council and the public.
The County’s protocol is based on guidelines ISED, which provides rules for siting communication towers and antennas. ISED Canada encourages local authorities to create clear, simple rules that don’t add extra burdens to those proposing tower installations, while still following federal guidelines. ISED also published a guide to help municipalities set their own protocols.
At the provincial and municipal levels, policies require that infrastructure, like telecommunication towers, be planned efficiently to meet needs, including emergency services and public safety.
While the County of Brant adopted the latest version of the Communication Tower and Communication Antenna Preferred Location Protocol in 2020, staff began work to streamline and update the protocol for better efficiency back in 2024. County staff have since reviewed the protocol to make sure it aligns with ISED Canada’s guidelines and addresses public feedback received during the public consultation period in July.
Proposed Updates
A report submitted by Lauren Graham, a Development Planner with the County of Brant, recommended the following updates to the existing Telecommunication Tower Protocol based on industry feedback, technological advancements, and community needs.
Setback Requirements
Currently, a proposed tower is required to have a setback distance that is three times the height of the tower (or at least 120 metres) from sensitive land use.
Staff have suggested that this be reduced down to 1.5 times the height of the proposed tower.
The change not only allows some flexibility for setbacks to be proportional to the height of the tower, but it also ensures that if a tower were to fall or shift, it will still remain within the property limits.
“Sensitive land uses have been more broadly defined and include existing and proposed residential uses, natural heritage areas, and various other community land uses,” reads Graham’s report. “While some municipalities rely on ISED Canada’s default 120m notification radius, others rely on setbacks related to the tower’s height. The proposed changes balance safety considerations in the event of tower failure while also mitigating potential visual impacts by tailoring setbacks to varying tower heights.”
Site Selection/Justification Report
Currently, applications to build a telecommunication tower require a business case. Staff proposed to remove the requirement and instead, applications will now require just the site selection/justification report.
“Since business-related factors fall outside the County’s land use authority, this change ensures that proponents still provide relevant business context without requiring unnecessary documentation,” read Graham’s report.
“The justification report will focus on:
• Identifying potential land use concerns,
• The features and scope of the proposal,
• Alternative locations and options considered, and
• The rationale for choosing the proposed site and tower.
This revision reflects the County’s focus on land use capability at a local level.”
Emergency Access and Maintenance
The existing requirement for one dedicated parking space at the site will be replaced with a broader condition that requires safe access to a public right-of-way for emergencies or servicing needs.
According to Graham’s report, this change prioritizes safety and accessibility while keeping focus on land use considerations.
Lighting Provisions
This requirement has been removed as Transport Canada and NAV CANADA will review and provide comments regarding painting and/or lighting requirements when needed. As well, lighting provisions are under the jurisdiction of .ISED Canada.
Notification Radius
Currently, when a new tower site is being proposed, the residents living within 500m of the site will receive notification through the mail. It was initially suggested that this radius be reduced to a 120 metres, but staff have decided to keep the 500m as is to maintain transparency.
For consistency, the notification radius for nearby municipalities will also be increased to 500m.
Natural Heritage and Hazard Areas
The definition of “Natural Heritage Systems” has been clarified to distinguish natural heritage systems features like woodlands, wildlife and wetlands, from natural hazards (such as. flooding and erosion hazards) in a way that is consistent with the County’s Official Plan.
“In consultation with the relevant Conservation Authority, telecommunication towers may be supported within or near flood-prone areas where no significant natural features exist. These proposals will be assessed on a case-by-case basis, maintaining environmental protections while allowing flexibility,” reads Graham’s report. “The primary intent of environmental setbacks is to protect wildlife, particularly birds and insects, from the impacts of radio frequency and electromagnetic field emissions. The primary intent of setbacks in areas with natural hazards is to ensure life safety measures are in place to reduce potential risks.”
Indigenous Engagement and Archaeological Assessments
As the County remains committed to Indigenous engagement and reconciliation, the newly updated protocol will formally include consultation with Six Nations of the Grand River and Mississaugas of the Credit First Nation.
As well, an archeological assessment will be required for any projects involving ground disturbance (such as digging, excavating, trenching, drilling and landscaping). Not only will this align with the direction of the County’s Official Plan, but it will also address common requests from nearby Indigenous communities.
Strategic Telecommunication Planning
Having consulted with the County’s Manager of Strategic Technology Projects, minor amendments have been made to ensure a coordinated approach that prioritizes the County’s needs, and maximizes community benefits in telecommunications infrastructure.
Delegation of Authority for Issuing Concurrence
Authority to review and issue letters of concurrence or non-concurrence will be delegated to staff, specifically the Director of Development Planning, Development Services Division. Council will continue to provide direction on any applications which do not meet the Protocol.
“This approach allows staff to quickly process compliant applications, while still enabling proponents of non-compliance proposals to seek Council approval on a case-by-case basis, ” read Graham’s report. “This approach incentivizes applications that align with the County’s objectives, while preserving opportunities for public feedback and Council decision-making.”
Following Graham’s presentation, councillors voted to receive the report as information and rescind any previous version of the County’s Telecommunication Tower Protocol, and adopt the updated version in its place.
As part of the vote, staff were also directed to update the County’s Delegation of Authority by-law to grant authority to issue a letter of concurrence for proposals that align with the 2024 Telecommunication Tower Protocol.
Kimberly De Jong’s reporting is funded by the Canadian government through its Local Journalism Initiative.The funding allows her to report rural and agricultural stories from Blandford-Blenheim and Brant County. Reach her at kimberly.dejong@brantbeacon.ca.
