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93845 - Planning Statement

Argyll and Bute Council · 14 September 2026
Back to Argyll and Bute Local Review Body — 14 September 2026 and its agenda

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Telent Technology Services Limited
Rutland House
5 Allen Road
Livingston
West Lothian
EH54 6TQ 
Planning and Supporting Statement 
in respect of 
Full Planning Application
On behalf of EE 
At
INVERARAY SHINTY CLUBHOUSE, 
DALMALLY ROAD,
INVERARAY,
ARGYLL AND BUTE,
PA32 8XD.

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Table of Contents 
1.0 Proposed Development ............................................................................. 3
2.0 Planning Policy ......................................................................................... 11
3.0 Access ....................................................................................................... 22
4.0 Regulatory Statement .............................................................................. 23
5.0 Health and Safety ..................................................................................... 24
6.0  Conclusions .............................................................................................. 25 
Rev Originator Date 
Name Day/Month/Year
1 Jamaal Hafiz 17/09/2025   
© Telent Technology Services Limited Group Town Planning.  All rights reserved July 26.  This document is expressly
provided to and solely for the use of EE Ltd and must not be quoted from, referred to, used by or distributed to any other
party without the prior consent of Telent Technology Services Limited Town Planning who accept no liability of
whatsoever nature for any use by any other party.
P10

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Introduction
This Planning and Supporting Statement has been prepared by Telent Technology Services
on behalf of EE Limited. The statement has been prepared in support of the application to
install a 25m high swann column crowsnest headframe supporting 3no. antennas, 2no.
600mm transmission dishes, 3no. RRU’s, installation of 2no. equipment cabinets, palisade
fenced compound and associated supporting apparatus at land at Inveraray Shinty
Clubhouse, Dalmally Road, Inveraray, Argyll And Bute, PA32 8XD. 
In accordance with the Code of Best Practice on Mobile Network Development and published
Government guidance, this proposal was drawn up having regard to the need for good design.
This statement sets out the most relevant considerations in respect of the proposed
development. This provides context for the proposal, reasoning, technical justification and
planning constraints, policy guidance and alternatives. 
In particular:
• Considerations of design and layout are informed by the context, having regard not
just to any immediate neighbouring buildings but the townscape and landscape of the
wider locality. The local pattern of streets and spaces, building traditions, materials and
ecology all help to determine the character and identity of the development.
• The scale, massing and height of proposed development have been considered in
relation to that of adjoining buildings; the topography, the general pattern of heights in
the area; and views, vistas, and landmarks. 
The following general design principles have been taken into account in respect of this
proposed telecommunications development:
• A proper assessment of the character of the area concerned. 
• That the design shows an appreciation of context;

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1.0 Proposed Development
1.1 The Site
The proposed 25m column and associated supporting apparatus will be located on land at
Inveraray Shinty Clubhouse, Dalmally Road, Inveraray, Argyll And Bute, PA32 8XD. 
It is of note that the operator previously progressed a site at Inverary Depot under planning
application ref: 21/02463/PP however the operator cannot impose the planning approval and
proceed to build due to legal issues as such this location cannot be progressed. 
The application site is located at the Inveraray Shinty Clubhouse, situated off Dalmally Road
on the northern approach to Inveraray, Argyll and Bute (grid reference E: 209343, N: 708563).
The site lies within the grounds of the Inveraray Castle designated landscape, a nationally
significant designed setting that contributes strongly to the character and historic context of
the town. The clubhouse is positioned adjacent to established playing fields and recreational
land, with open views towards the surrounding wooded policies and the wider scenic backdrop
of Loch Fyne and the surrounding hills. Access to the site is taken directly from Dalmally Road
(A819), which forms a key route into Inveraray from the north. The immediate area has a
predominantly rural and parkland character, with scattered woodland, open grassed areas,
and designed estate features forming part of the wider Inveraray Castle landscape setting 
Additionally, the presence of the existing telecommunications mast within existing site at
AFAM Services, Dalmaally Road is due to be decommissioned due to operational reasons
and replaced by this proposal, provides an existing context for telecommunications equipment
within the general locale. The relocated site is circa 115m west of the existing infrastructure.
The topography of the site location and surrounding areas is such that the land elevation at
the proposed development location is circa 60m. 
As mentioned at present, there is an existing site located at AFAM Services, Dalmaally Road
that provides network coverage to the area, however, due to operational reasons it cannot no
longer continue to provide coverage nor 5G coverage, there is an urgent requirement to
decommission and remove the existing installation. Therefore, a new location for a
replacement installation in order to maintain and improve coverage to this area is required. 
The replacement site must be in the same geographical area to ensure that the network
coverage is improved effectively. Therefore, the proposal to be assessed in this instance is for
a 25m column and associated supporting apparatus will be located on land at Inveraray Shinty
Clubhouse, Dalmally Road, Inveraray, Argyll And Bute, PA32 8XD.

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The image below shows the location of the existing and proposed site locations: - 
Aerial map showing the existing and proposed site locations 
1.2 Application History
As highlighted above, the requirement for a replacement mobile phone base station to provide
coverage to Inverrary, as a result of the proposed removal of the existing EE site at existing
site at AFAM Services, Dalmaally Road. 
The proposed decommissioning of the existing installation is required following the
Landowner’s redevelopment and expansion plans within their land. Therefore, a new location
for a replacement installation in this area is required in order to maintain and improve coverage
to this area. 
As previously stated a site at Inverary Depot under planning application ref: 21/02463/PP was
progressed and approved however, the operator cannot impose the planning approval and
proceed to build due to legal issues as such this location cannot be progressed. 
The proposed new mast will not only service voice calls but will include provision for 3G/4G
and 5G data use which will be of great benefit to all users of the network. As you may be
aware, EE have been awarded the contract to provide network services to the Emergency
Services, which will operate over EE’s 3G/4G and 5G network and as such, this site will also
provide coverage for all the blue light services in this area. 
Existing Site Location
Proposed Site Location

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1.3 The Proposal
The proposed development consists of the installation of: 
• 1 x 25-metre-high swann column with crowsnest headframe
• 3 x antennas fixed to headframe
• 2 x 0.6m transmission dishes 
• 1x GPS Node fixed to proposed antenna pole
• 1 x ORC Cabinet (600x600x2100)
• 1 x MK5B Link AC cabinet (1200x600x1600) 
• 1 x 6m x 5m compound formed from 1.8m high palisade fence with 3m wide
double access gate 
• Other ancillary equipment and cabling 
The proposed structure will be galvanised and the ground-based equipment cabinets
are to be light grey (RAL 7035). 
The principal components of the proposed development are outlined in the Site-Specific
Supplementary Information, and the general layout illustrated on the submitted drawings as
part of this application. 
1.4 Alternative Site Assessment
The information below contains details of the alternative sites that were investigated and
discounted when searching for a viable location. These locations were assessed to ascertain
whether they would provide the technical and operational requirements necessary for the
surrounding area. The search area is particularly restricted by geographical and distance
factors, with close proximity to the target coverage area of major importance. As you can see
from the map below, there are no existing masts/sites, buildings or structures within the search
area suitable to progress. 
1. Fire Station Tower RT - Approx. NGR: 209452, 708571
This structure would not be suitable to accommodate the additional load of the telecoms apparatus.
2. Fire Station GF - Approx. NGR: 209460, 708565
This site would have ICNIRP issues due to the adjacent fire station tower.
3. Inveraray Co-op GF – Approx. NGR: 209393, 708281
Could not get sufficient dish link at this location to support other rural sites around Inveraray.
4. Dalmally Road SW - Approx. NGR: 209373, 708670
This site would have too great a visual impact on the area due to street furniture of significantly less
height and lack of natural screening.
5. Bell Tower RT - Approx. NGR: 209468, 708451
This site was discounted as no stealth design could be implemented which would mitigate the
visual impact given the building listing.
6. The Avenue SW - Approx. NGR: 209524, 708453

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This site would have too great a visual impact on the area due to street furniture of significantly less
height and lack of natural screening.
7. Land South of Dalmally Road 2 - Approx. NGR: 209113, 708291
This site would require a very high/ bulky tower due to the surrounding trees and would have a
greater visual impact than that of the proposed.
8. Land South of Dalmally Road - Approx. NGR: 209224, 708487
This site would have too great a visual impact on the area due to the openness of the site and lack
of natural screening.
9. Inveraray Primary School - Approx. NGR: 209412, 708455
This site would have too great a visual impact on the area due the lack of vertical structures to
mitigate the visual impact and lack of natural screening.
10. Cameron Auto Repairs GF - Approx. NGR: 209099, 708124
The site is too far to the southwest of the search area to provide the required coverage to the target
area.
11. The Inveraray Inn RT - Approx. NGR: 209551, 708592
The building is not suitable to host the apparatus due to the pitched roof design.
12. Town House RT - Approx. NGR: 209632, 708561
The building is not suitable to host the apparatus due to the pitched roof design.
13. Main Street SW - Approx. NGR: 209655, 708544
This site would have too great a visual impact on the area due the lack of tall street furniture to
mitigate the visual impact and lack of natural screening.
14. Front Street CP - Approx. NGR: 209667, 708565
This site would have too great a visual impact on the area due the lack of tall street furniture to
mitigate the visual impact and lack of natural screening. 
15. Inveraray Castle RT - Approx. NGR: 209589, 709243
This site is too far to the north of the search area to provide the required coverage to the target
area.
16. Land off Upper Avenue - Approx. NGR: 209076, 708696
This site is too far to the west of the search area to provide the required coverage to the target
area.
17. Inveraray Parish Church RT - Approx. NGR: 209591, 708422
This site was discounted as no stealth design could be implemented which would mitigate the
visual impact.
18.  Inveraray Jail RT - Approx. NGR: 209650, 708393
This site was discounted as no stealth design could be implemented which would mitigate the
visual impact.
19. George Hotel RT - Approx. NGR: 209567, 708347
The building is not suitable to host the apparatus due to the pitched roof.

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20. Inveraray Coach Park GF - Approx. NGR: 209402, 708701  
This site would require a very high/bulky tower due to the surrounding trees and would have a
greater visual impact than that of the proposed.
21. Inveraray TE - Approx. NGR: 209356, 708586  
Unable to agree to a location on the property that works for all parties. 
22. Spoil Heap VF SS - Approx. NGR: 209178, 708304
This site would have to be significantly developed to accommodate both EE and Vodafone. This
would require a very high/bulky tower due to the surrounding trees and would have a greater visual
impact than that of the proposed.
23. Upper Riochan Factory GF – Approx. NGR: 209047, 708115
The site is too far to the southwest of the search area to provide the required coverage to the target
area.
24. Barn Brae SW – Approx. NGR: 209282, 707959
Radio confirmed this site would not work from a coverage perspective. 
25. Inveraray Co-op CP 2 – Approx. NGR: 209358, 708269
This location was not supported by the landowner and current location was agreed. 
26. Inveraray Depot GF – Approx. NGR: 209388, 708467
The operator previously progressed a site at Inverary Depot under planning application ref:
21/02463/PP however the operator cannot impose the planning approval and proceed to build due
to legal issues as such this location cannot be progressed.

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The discounted sites that were identified as potential sites are shown on the map below: 
In terms of how this information on alternative options should be assessed, the following
paragraph from a recent appeal decision 8 should be the starting point: 
“I note the Council’s reservations regarding the appellants’ list of alternative sites, and to
that extent I accept that the appeal site has not been shown conclusively to be the least
environmentally damaging option possible. But the National Planning Policy Framework
(NPPF) does not support that approach. Given that I have found no significant harm, it is
unnecessary to consider other alternatives in any more detail. This appeal decision
confirms the approach in the NPPF which provides policy on this matter in three specific
ways: 
•  That LPAs should determine applications on planning grounds and should not seek to
prevent competition between operators or question the need for the system (para 118)”
_______________________
8 APP/B5480/W/20/3251086 – London Borough of Havering (LPA Ref: M0008.19) 
1.5 Local Engagement 
Please refer to Site Specific Supplementary Information.

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1.6 Additional Justification 
Emergency Services Network Requirement (ESN): 
In 2015, EE won the contract from UK Government to deliver a mobile network specifically for
all blue-light emergency services across the country to provide a seamless 4G mobile service.
The communications system will be critical in improving response times and improving
communications between all of the blue-light services and providing critical infrastructure
across the length and width of the United Kingdom. EE have committed to add over 500 new
4G sites to accommodate this commitment in that will eventually replace the existing Airwave
TETRA radio system. This EE proposal will form part of the new 4G emergency services
network and should be considered critical infrastructure within the UK to support the local
community in perpetuity. 
Shared Access – The Benefits of Mobile Technology
Mobile phones and other similar communication devices are ubiquitous both for business and
personal use. Mobile connectivity is now about fast, secure access to the internet anywhere.
People and businesses are increasingly choosing to access the internet using a mobile device,
and the numbers doing so are growing, as ownership of internet-enabled devices rises. 
Smartphones are integral to people’s lives as mobile devices supporting a growing range of
functions from communication to navigation, to use as principle sources of news media,
cameras, diaries and numerous other functions. 
Overall, 94% of adults personally own/use a mobile phone with 52.4 million 4G mobile
subscriptions. The proportion of adults in the UK with a smartphone has now reached 76%
(as of 2017), with 18% of adults living in a mobile phone only home. Increasing coverage and
take-up of higher speed 4G services is driving data use. The average volume of data
consumed per subscriber per month is now 1.9GB.

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2.0 Planning Policy and Planning Assessment 
This section sets out the most relevant national and local planning policy concerning the
proposed development. 
Under Section 25 of the Town and Country Planning (Scotland) Act 1997, the determination
of planning applications are to be made in accordance with the Development Plan unless
material considerations indicate otherwise. National Planning Framework 4 was formally
adopted on the 13th of February 2023 and is now part of the statutory Development Plan.
NPF4 provides the national planning policy context for the assessment of all planning
applications. The adopted The Argyll and Bute Local Development Plan 2 was adopted on
28th February 2024, and replaces the Argyll and Bute Local Development Plan 2015 and its
associated Supplementary Guidance (March 2016), and Supplementary Guidance 2
(December 2016). 
2.1  General Policies  
National Planning Policy 
Scottish Planning Policy (SPP) and the National Planning Framework 4 (NPF4) superseded
NPPG 19. This document condenses the advice outlined previously although the broad
principles of promoting the expansion of electronic communications networks remains the
same: 
National Planning Framework 4 (NPF4) 
The NPF4 was adopted 13th February 2023. It details the Scottish Government’s long-term
plan for what Scotland could be in 2045 and will influence planning decisions. The NPF4
encourages LDP’s to support the delivery of digital infrastructure, including fixed line, and
mobile connectivity, particularly in areas with gaps in connectivity and barrier to digital access.
Policy 24 reads “Development proposals that incorporate appropriate, universal, and future-
proofed digital infrastructure will be supported” 
Part 1– sets out an overarching spatial strategy for Scotland in the future. This includes
priorities, spatial principles and action areas. This should be used to guide the preparation of
regional spatial strategies, local development plans and local place plans. The strategy is
relevant to wider policies and strategies relating to land use. It also sets out aspirations to
stimulate green prosperity, stating that natural assets and environmental quality underpin the
area’s main economic sectors and must therefore be protected, restored and used
sustainably. A flexible approach to planning will help to attract investment, grow and diversify
businesses and enable local entrepreneurship, micro enterprises, self-employment and social
enterprises to flourish. Remote working can be capitalised on to build economically active local
communities. The Plan acknowledges that achieving these aspirations will require the
continued roll out of high-quality digital infrastructure and maintenance and decarbonisation
of transport routes to wider markets. 
Part 2– sets out proposed national developments that support the spatial strategy.

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Policy 14 relates to design, quality and place. It aims to encourage, promote and facilitate well
designed development that makes successful places by taking a design-led approach and
applying the Place Principle. 
Policy 14 states: 
a) Development proposals will be designed to improve the quality of an area whether in
urban or rural locations and regardless of scale. 
Part 3– sets out policies for the development and use of land which are to be applied in the
preparation of local development plans; local place plans; masterplans and briefs; and for
determining the range of planning consents. This part should be taken as a whole, and all
relevant policies should be applied to each application. 
Part 3 is also a ‘Planning Policy Handbook’ and covers the following themes: 
• Sustainable Places (Universal policies) 
• Liveable Places 
• Productive Places 
• Distinctive Places 
In respect of ‘Digital infrastructure’, NPF4 states ‘We want our all of our places to be digitally
connected. Digital connectivity has a central role to play in unlocking the potential of our places
and the economy and in opening up more remote parts of Scotland for investment and
population growth. This will play an increasingly important role in supporting essential services
including healthcare and education. We want to ensure that no areas are left behind by closing
the digital divide. The planning system should continue to support the roll-out of digital
infrastructure across all of Scotland, ensuring that policies recognise the importance of future-
proofing infrastructure provision whilst addressing impacts on local communities and the
environment’. 
Policy 24 relates to ‘Digital Infrastructure’ and states: 
a) Local development plans should support the delivery of digital infrastructure,
particularly in areas with gaps in connectivity and barriers to digital access. 
b) Development proposals should incorporate appropriate, universal and futureproof fed
digital infrastructure. This should be done in consultation with service providers. 
c) Development proposals that deliver new digital services or provide technological
improvements, particularly in areas with no or low connectivity capacity, should be
supported. Planning authorities should not question the need for the service to be
provided where proposals are clearly aligned with fulfilling the delivery of local or
national policy objectives which support the roll-out of digital infrastructure in areas
with no or low connectivity where there are benefits of this connectivity for communities
and the local economy.

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d) Development proposals for telecommunications development should be supported
where: 
• the visual and amenity impact of the proposed development has been
minimised through careful siting, design and where appropriate landscaping; 
• it has been demonstrated that all practicable options and alternative sites have
been considered, including the possibility of using existing masts, structures
and buildings and/or site sharing; 
• there is no physical obstruction to aerodrome operations, technical sites or
existing transmitter/receiver facilities. 
e) Development proposals that are likely to have an adverse effect on the operation of
existing digital infrastructure or on the delivery of strategic roll-out plans should not be
supported unless appropriate mitigation measures can be provided. 
In considering the above, as the proposal would in effect see the relocation and upgrading of
an existing telecommunications site within the general locale whereby the council has
accepted the general locale as being suitable, on balance, in terms of siting of such equipment
and of a suitable design, then given the similar nature of the proposal and its location then
there would be little in the way of further consideration in terms of any perceived visual impact
from that previously considered appropriate in this instance. 
Given the relocation of an extant permission and therefore site, while the general local has
been considered as being acceptable the proposed site is the closest to that of the existing
site practicable in this instance. Furthermore, in this instance there is some existing vegetation
to which the revised site would be set behind and would provide some additional screening
that would lessen any visual impact/prominence. 
Scottish Planning Policy 2014 (SPP) 
Scottish Planning Policy published in June 2014, is a statement of Scottish Government policy
on how national important land use planning matters should be addressed across the country.
SPP is supplemented by a series of Planning Advice Notes (PANs). 
Paragraphs 292 – 300 of the SPP relates specifically to Supporting Digital Connectivity,
including telecommunications developments. It highlights the importance of our digital
infrastructure, across the whole of Scotland, including urban and rural areas and confirms that
Scotland’s economy and social networks depend heavily on high-quality digital infrastructure.
To facilitate investment across Scotland, planning has an important role to play in
strengthening digital communications capacity and coverage across Scotland. 
The proposed development accords with all these aspects of the NPF4 and SPP in that it will
provide the wider area with improved network provision, bringing a range of associated
economic and technical benefits. 
Paragraph 295 of the SPP confirms that Local development plans should provide a consistent
basis for decision-making by setting out the criteria which will be applied when determining
planning applications for communications equipment. They should ensure that the following

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options are considered when selecting sites and designing base stations: 
• mast or site sharing;
• installation on buildings or other existing structures;
• installing the smallest suitable equipment, commensurate with technological
requirements;
• concealing or disguising masts, antennas, equipment housing and cable runs using
design and camouflage techniques where appropriate; and
• installation of ground-based masts. 
Paragraph 296 confirms that “Local development plans should set out the matters to be
addressed in planning applications for specific developments, including: 
• an explanation of how the proposed equipment fits into the wider network;
• a description of the siting options (primarily for new sites) and design options which
satisfy operational requirements, alternatives considered, and the reasons for the
chosen solution;
• details of the design, including height, materials and all components of the proposal;
• details of any proposed landscaping and screen planting, where appropriate;
• an assessment of the cumulative effects of the proposed development in combination
with existing equipment in the area;
• a declaration that the equipment and installation is designed to be in full compliance
with the appropriate ICNIRP guidelines for public exposure to radiofrequency
radiation131; and
• an assessment of visual impact, if relevant. 
It is considered that the proposal has address all matters set out in the ‘model’
telecommunications policy. The proposal would result in development that would see the
removal of a previously approved telecommunications site location whereby the suitability in
terms of siting and appearance has already been established and accepted by the Council.
The proposed development will have no significant detrimental or demonstrable effect on the
character and appearance of the local to that previously considered acceptable. 
In assessing applications for telecommunications development, paragraph 298 of the SPP
confirms that “Consideration should be given to how proposals for infrastructure to deliver new
services or infrastructure to improve existing services will contribute to fulfilling the objectives
for digital connectivity set out in the Scottish Government’s World Class 2020 document. For
developments that will deliver entirely new connectivity – for example, mobile connectivity in
a “not spot” – consideration should be given to the benefits of this connectivity for communities
and the local economy”. 
Paragraph 299 then states that. “All components of equipment should be considered together
and designed and positioned as sensitively as possible, though technical requirements and
constraints may limit the possibilities. Developments should not physically obstruct aerodrome
operations, technical sites or existing transmitter/receiver facilities. The cumulative visual
effects of equipment should be taken into account”.

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The scheme has been designed to ensure that it not only meets the technical requirements
but also fully considers the site context and any potential views from outlying areas, which is
why the nearest suitable location to the extant permission site is proposed in this instance. 
Paragraph 300. States that “Planning authorities should not question the need for the service
to be provided nor seek to prevent competition between operators. The planning system
should not be used to secure objectives that are more properly achieved under other
legislation. Emissions of radiofrequency radiation are controlled and regulated under other
legislation, and it is therefore not necessary for planning authorities to treat radiofrequency
radiation as a material consideration”. 
The proposal would be consistent with the aims of the SPP in this instance, particularly when
considering that the application includes ICNIRP certification confirming that any emissions of
radiofrequency radiation are at an appropriate and safe level. 
Planning Advice Note: PAN 62 Radio Telecommunications 
PAN 62 refers to Radio Telecommunications and states that the NPPG (now superseded by
the SPP and FPF3) considers the general siting and design principles for telecommunications.
It states that such development should be undertaken in a manner that minimises
environmental impact and should have a sensitive design in both urban and rural areas. 
Paragraphs 8 – 17 of Planning Advice Note 62: Radio Telecommunications broadly explain
how mobile networks operate. Although the operators’ networks are mature, improvements,
upgrades and new sites are required for their networks for a number of reasons. For example,
to increase capacity in an area of high demand, to provide new or improved network coverage
in terms of quality as well as extent, or perhaps to provide coverage over a new development
area such as a new housing estate or industrial park. 
Paragraph 32 identifies two components associated with minimising the contrast between
telecommunication equipment and its surrounding as; minimising the contrast between
equipment and people’s expectations of a particular scene and minimising the contrast
between equipment and its immediate setting of background. For example, a lattice tower
generally fits the expectations within rural landscapes. 
Paragraph 33 further identifies ways in which to minimise these contrasts as follows; 
• select a shape and material appropriate to the character of the area;
• keep the shape simple with clean lines, and fit all the elements, such as antennas,
cables and ladders within the visual envelope of the basic shape;
• develop a composition where the properties seem in proportion and balanced, for
example masts that taper to the top are usually more acceptable;
• minimise the number of separate visual elements in a base station; and
• use regularity, order and symmetry in positioning equipment.  
Furthermore, para 34 identifies a series of options that should be considered as a guide in
selecting the siting and design of telecommunications equipment in order to minimise any

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resultant visual contrast. The implementation of telecommunications equipment is site-specific
and therefore should be considered against the site conditions and coverage capacity
requirements in addition to technical constraints and landscape character. The series of
options is therefore a guide or checklist rather than a sequence to be rigidly followed. The
options are: 
• installing small scale equipment;
• concealing or disguising equipment;
• mast sharing;
• site sharing;
• installing on existing buildings or other structures; and
• erecting a new ground based mast. 
As can be seen from the above, the proposal would result in the removal of an existing site
within the area, and the new base station proposed at land at Shinty Clubhouse will remain in
an area whereby the acceptability on matters regarding siting and appearance has already
been accepted, would be consistent with both the aims of national and local policy. The
proposal would therefore be consistent with National policy guidance as set out above. 
The special operational and technical factors that require specific siting of base stations should
be balanced by the need to minimise environmental and visual impact. However, there is now
far greater emphasis that visual impact should not override significant radio planning
requirements to achieve mobile coverage to a particular area, particularly with the need to
support the massively growing and intensifying demand for mobile communications across
the UK.

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2.2 Local Planning Policies 
Under Section 25 of the Town and Country Planning (Scotland) Act 1997, the determination
of planning applications are to be made in accordance with the Development Plan unless
material considerations indicate otherwise. National Planning Framework 4 was formally
adopted on the 13th of February 2023 and is now part of the statutory Development Plan.
While NPF4 provides the national planning policy context for the assessment of planning
applications, the The Argyll and Bute Local Development Plan 2. 
ARGYLL AND BUTE LOCAL DEVELOPMENT PLAN 2 (February 2024) 
The following policies are of relevance: 
Policy 10 – Design: All Development 
The design of any development must: 
• Demonstrate an understanding of and appropriate response to the proposed development
site and wider context including consideration of character and, where applicable, urban grain;
and 
• Acknowledge the scale, mass and spirit of nearby buildings but steer clear of mimicry and
pastiche; and • Incorporate existing and enhancing features where applicable; and • Avoid
falsification of period details; and 
• Use appropriate proportions for building elements and details including, where applicable,
massing and fenestration; and 
• Use materials that are harmonious with the context but embody honesty and legibility of
contemporary design; and 
• Consider the embodied energy and durability of proposed materials; and 
• Incorporate the use of flood resistant and resilient materials and construction methods. 
Policy 20 – Gardens and Designed Landscapes 
Development proposals affecting nationally important Gardens and Designed Landscapes will
be supported where they protect, preserve or enhance their cultural significance, character
and integrity and where proposals will not significantly impact upon important views to, from
and within the site, or its setting. 
Development proposals should protect and preserve in situ regionally or locally important
Gardens and Designed Landscapes and their settings, wherever feasible. All proposals
affecting designated or non-designated Gardens and Designed Landscapes or their settings
shall be accompanied by an assessment that follows the principles set out in the most up-to-
date relevant guidance published by Historic Environment Scotland. 
In assessing proposals for development in or adjacent to gardens and designed landscapes
particular attention will be paid to the impact of the proposal on all of the following: 
• The artistic, historical, horticultural, architectural, scenic, and nature conservation interest of
the site, AND

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• The site’s original design concept, overall quality and setting, AND 
• Trees and woodlands and the site’s contribution to local landscape character within the site
including the boundary walls, pathways, garden terraces or water features. 
Policy 44 – Telecommunications 
There is a presumption in favour of proposals for telecommunications development provided
that all the following criteria are met: 
a) the siting and appearance of the proposed apparatus and associated structures should
seek to minimise impact on the visual amenity, character or appearance of the surrounding
area; 
b) if located on a building, apparatus and associated structures should be sited and designed
in order to seek to minimise impact on the external appearance of the host building; 
c) if proposing a new mast, it should be demonstrated that the applicant has explored the
possibility of erecting apparatus on existing buildings, masts or other structures. Such
evidence should accompany any application made to the Planning Authority; 
d) the development should not have an unacceptable impact on areas of ecological interest,
Areas of Wild Land, National Scenic Areas, historic gardens and designed landscapes, other
areas of landscape importance, the Green Belt, the coast, archaeological sites, conservation
areas, areas of townscape quality or buildings of architectural or historic interest. Special care
should be exercised in these locations. 
When considering applications for telecommunications development, the Planning Authority
will have regard to the operational requirements of telecommunications networks and the
technical limitations of the technology. Applicants will be expected to demonstrate compliance
with ICNIRP guidelines. 
Policy 17 – Conservation Areas 
Development: There is a presumption against development that does not preserve or enhance
the character or appearance of an existing or proposed conservation area or its setting. New
development within these areas and on sites affecting their settings must respect the
architectural, historic and other special qualities that give rise to their actual or proposed
designation and conform to the following national policies and guidance including, but not
limited to, those detailed as ‘Related Documents’ under section 4.39 above and the area’s
Conservation Area Appraisal and Management Plan (if in place). 
The developer is expected to satisfactorily demonstrate to the planning authority that the effect
of a proposed development on a conservation area and its wider setting has been assessed
and that measures will be taken to preserve or enhance the special interest of the area. The
use of appropriate design statements, character appraisals and conservation plans are
expected to facilitate this assessment. Applications for planning permission in principle will not
normally be considered appropriate for proposed development in conservation areas. The
contribution which trees make towards the character or appearance of a conservation area
will be taken into account when considering development proposals.

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B. Demolition: Proposals for the total or substantial demolition of a building within or affecting
the character or appearance of a conservation area or its setting will be considered as if the
structure was listed – as set out in Policy 16 – Listed Buildings (B). 
Assessment against Policy 
It is considered that the proposal has address all matters set out in the ‘model’
telecommunications policy as above. The proposal would result in development that would fit
in with the overall site context, not be viewed as being visually incongruous and will not cause
any undue harm when viewed from outlying areas including that of the Inveraray Castles
designated landscape and nearby Inveraray Conservation Area. The proposed development
will have no significant detrimental or demonstrable effect on the character and appearance
of the existing site or indeed its setting when considering the immediate and surrounding
locale. 
In assessing applications for telecommunications development, paragraph 298 of the SPP
confirms that “Consideration should be given to how proposals for infrastructure to deliver new
services or infrastructure to improve existing services will contribute to fulfilling the objectives
for digital connectivity set out in the Scottish Government’s World Class 2020 document. For
developments that will deliver entirely new connectivity – for example, mobile connectivity in
a “not spot” – consideration should be given to the benefits of this connectivity for communities
and the local economy”. 
The mast will provide an essential improvement to the service for the Emergency Services
through as well as maintaining coverage loss from an existing site that is to be removed and
also improve providing 5G coverage and capacity. 
Paragraph 299 then states that. “All components of equipment should be considered together
and designed and positioned as sensitively as possible, though technical requirements and
constraints may limit the possibilities. Developments should not physically obstruct aerodrome
operations, technical sites or existing transmitter/receiver facilities. The cumulative visual
effects of equipment should be taken into account”. 
In consideration of the NPF4 and the local development plan, it is our belief that the
development proposal meets the requirements of national and local policy whilst having regard
to technical and operational factors and maintaining the necessary level of coverage to this
area of Inveraray.   
The scale and design of the telecommunications tower will not detract from the local area
given its careful siting on private land that to the further surrounding area contains semi-mature
trees that will partially shield the installation from certain vantage points. This would ensure
there would be no impact in terms of the amenity of residential properties given the
location/We would again reiterate that we believe that we have demonstrated that the
telecommunications development, having regards to the technical and operational constraints,
has been designed to minimise environmental and visual impacts upon the Inveraray
designated landscape and the setting of the Inveraray conservation area through careful sitting
and design choices in line with the NPF4 and local policies 10, 17, 20 and 44 of the Argyll and
Bute LDP.

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The proposed mast has been specifically selected for deployment due to its design and is
regularly positioned away from the built up residential area. The monopole design is of a
slimmer appearance to alternative designs that could have been deployed such as lattice
towers which would of be significant impact, the monopole is to be a galvanised finish, allowing
the mast to assimilate with the existing skyline. The requirement of this design including that
of the headframe is to ensure it can host the operators equipment. Furthermore, the design is
the safest for supporting antenna at the required height of 25m in this instance, as it is the
most structurally sound design when taking into account natural forces such as wind load at
this height. It is not therefore considered that the proposal would have any detrimental or
demonstrable visual impact in respect of the existing area including the Inveraray designated
landscape and the setting of the Inveraray conservation area to any significant degree in line
with NPF4 and local policies 10, 17, 20 and 44 of the Argyll and Bute LDP. 
The application site has been specifically selected to assimilate into the existing character of
the area and utilise the nearby vegetation and screening of trees. The proposal complies fully
with national planning guidance and as such it is considered to provide the best location from
both a technical and town planning view. 
The equipment cabinets are required to support the monopoles functionality and can be added
as permitted development rights under a Regulation 5 notification once the monopole has
been approved however for transparency they have been included and form part of the
application. Given their height under 2.5m2 they will not be of detrimental impact to the area,
given they will be finished in light grey RAL7035.   
Ultimately, this location is considered to be the optimum location for the installation in terms
of both technical and operational needs and minimising environmental impact, in particular
landscape and visual impact upon the Inveraray designated landscape and the setting of the
Inveraray conservation area. The design of the development proposed is the most
environmentally sensitive available to meet the operational needs of the development and, as
outlined above, will be in keeping with the character of the wider setting of the local area. As
previously stated the existing site is no longer operational as such is to be decommissioned.   
In consideration of the NPF4 and local development plan, it is our belief that the development
proposal meets the requirements of national and local level policies whilst having regard to
technical and operational factors and maintaining the necessary level of coverage to
Inveraray. 
Therefore, it is our belief that the wider public benefit in this instance vastly outstrips any
perceived visual intrusion and it is our belief that as such locals and associated stakeholders
within the council should support this application because of the distinct lack of impact on the
wider area whilst according to the policies mentioned within this document that present greater
and wider opportunities for locals in this area. 
Any information required regarding location, height of antennas, frequency etc. can be found
in the supporting documents, which are submitted as part of this full planning application.  As
noted above, an ICNIRP certificate has also been enclosed. We are of the opinion that this
proposal is compliant with all relevant planning policy, as noted above, and could therefore be

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supported by your department. 
In regard to NPF4 and local policies 10, 17, 20 and 44 of the Argyll and Bute LDP it has been
demonstrated that the design, the monopole structure proposed has been chosen as this is
the most sympathetic within such locations as this, due to its slimline nature allowing onlookers
to continue to view surrounding trees through the structure that is required to host essential
communications infrastructure. Furthermore, by opting for a galvanised finish to the mast, this
will ensure that any potential views of the top of the structure will be the least visually intrusive
on the skyline due to the ability of galvanised materials to blend into the sky as far as is
practicable. The chosen height of 25m is the lowest possible height that the antenna can be
set at to ensure that coverage is maintained to the surrounding area, the mast has been
designed to be future proofed as this allows for the possibility of other operators to site-share,
along with providing the structural stability for any future upgrading works that may be required
as technology continues to advance. 
Furthermore, in accordance with NPF4 and local policies 10, 17, 20 and 44 of the Argyll and
Bute LDP, the siting has made use of the adjacent mature tree belts to provide a natural
vertical context and screening/backdrop (depending on the direction of view) for the mast and
cabinets, further reducing any potential visual prominence at this location.

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3.0 Access 
Access requirements both to and around the site should be considered. It must be considered
that this site is for telecommunications purposes only. In principal, no access to the cabinets
or the mast is allowed and as such access requirements are not considered an issue. 
3.1 Construction and Maintenance
Access to the site will be taken via the dedicated access route to the site location off the A819.
Maintenance visits are required approximately every 3-6 months by an operative with a light
vehicle. Consequently, it is not envisaged that access to the site would cause traffic
management or other issues. During the construction process all build, and maintenance
regulations will be complied with. Proof of compliance can be confirmed closer to the time of
construction if necessary. 
It should be noted that the install of the equipment will be as per the latest NJUG guidelines
which will of course consider the proximity of trees in the site area. 
3.2 Public Access
Radio base stations are not designed to be accessible by the public. The equipment cabinets
would always be locked and only accessible by authorised persons. Therefore, no specific
public access provisions are required to be incorporated into the design of the proposal.

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4.0 Regulatory Statement 
EE is authorised to operate a public electronic communications network and supply public
electronic communications services under the provisions of the Telecommunications Act
1984, the Communications Act 2003 and the Electronic Communications Code (Conditions
and Restrictions) Regulations 2003 and aims to meet all reasonable customer demand for that
service. 
OFCOM statistics show that in 2013 mobile phones are owned / used by 92% of UK adults.
This demonstrates the vital role mobile communications play in the social and economic
wealth of the country.  Whilst most of the UK now benefits from mobile coverage there are still
spots without coverage. EE under their communications code licence to run a public
communications network are duty bound to provide equal coverage to all areas of the UK. 
Therefore, the need for communications systems should not be tested by Local Planning
Authorities, as it is for the communications code operators to determine locations where
coverage is required and demonstrate in evidence. 
The development proposed is to replace an existing EE installation which is to be
decommissioned and removed. Should this proposal not proceed, the area will be left with
significantly reduced coverage or no coverage whatsoever in the future.

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5.0 Health and Safety 
Telecommunications planning guidance states that it is not for the local planning authority to
seek to replicate through the planning system controls under the health and safety regime as
it is a matter for the Health and Safety Executive. The Government guidelines state that
provided a proposed base station meets the ICNIRP guidelines for public exposure, then it
should not be necessary for the local planning authority to consider the impacts of health
concerns. 
It is confirmed that the proposed equipment and installation complies with ICNIRP guidelines
and a Declaration of Conformity has been submitted in support of the application.

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6.0  Conclusions 
As part of their UK upgrading programme, EE now propose to upgrade coverage in this area
to include 4G services which will maintain and provide improved data services to customers
in addition to the existing voice and text services they enjoy. In addition, EE provide the new
UK wide Emergency Services Communications Network (ESN) and their 3G/4G/5G network
will support this service. As such, the proposed replacement installation will form part of the
ESN for all of the emergency services operating within this area. 
The telecommunications installation proposed as set out in this application has been designed
and sited having regard to technical, engineering and land use planning considerations in
order to minimise its impact on the local environment. The mast height has been kept to the
minimum required to ensure operational efficiency - a structure with an overall height of 25
metres is needed in this locality because of the surrounding clutter. Consideration has been
given to the design of the mast and this is reflected in the lattice structure, which is frequently
used within rural/village areas. 
In relation to planning policy, in accordance with the guidance set out in both national and
local policy, a thorough search of the area has been undertaken and revealed that there are
no existing masts or other structures suitable. Therefore, the development of a new mast site
is justified, and it has been demonstrated that it has been sited and designed to minimise its
visual impact and all other environmental impacts as far as practicable in accordance with the
development plan. 
The Council are therefore respectfully asked to approve this application for full planning
permission.