93845 - Planning Statement
Argyll and Bute Council · 14 September 2026
Back to Argyll and Bute Local Review Body — 14 September 2026 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
Page 1
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.
Page 2
1 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
Page 3
2 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;
Page 4
3 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.
Page 5
4 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
Page 6
5 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
Page 7
6 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.
Page 8
7 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.
Page 9
8 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.
Page 10
9 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.
Page 11
10
Page 12
11 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.
Page 13
12 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.
Page 14
13 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
Page 15
14 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”.
Page 16
15 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
Page 17
16 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.
Page 18
17 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
Page 19
18 • 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.
Page 20
19 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.
Page 21
20 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
Page 22
21 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.
Page 23
22 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.
Page 24
23 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.
Page 25
24 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.
Page 26
25 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.