Thank you for inviting the Mountaineering Council of Scotland (MCofS) to participate in the Evaluation of New Planning Controls over Telecommunications Development in Scotland consultation. The following thoughts represent our response to this consultation exercise.

Six out of the eight questions that you asked in your letter are specifically aimed at local authorities and the telecommunications industry. Questions 5 and 7 are, however, relevant to our particular interest in this issue, so our comments are really generated by those two questions.

Whilst the MCofS was one of the bodies that campaigned for PDO rights to be taken away from telecommunications masts, we feel that government was far too slow in making the changes that it did, and so a great deal of damage to the ground and to scenic landscapes was inflicted before the legislation was tightened.

Throughout the debate on the impact of telecommunications masts and the need to bring them fully within the planning system, we have maintained our argument that access tracks, which are often bulldozed in upland areas, are as much a landscape issue as the masts themselves. For that reason we are calling for such tracks, whether associated with telecommunications masts or not, to have PDO status removed and to be brought within the full planning system.

Your question 5 asks whether a better balance has been reached between the needs of the industry and management of the environment. Our response to that is that the management of our environment, especially scenic landscapes, is far more important than the needs of the telecommunications industry. This is the industry that has erected a mast on the summit of Mount Blair, so its record of concern for scenic landscapes is particularly poor. The PDO rights that protected masts from the normal inspections of the planning system allowed a great deal of landscape damage to slip through the net, and gave a strong impression of the industry being more important than the landscape. This also placed a worrying emphasis on the need to protect the planning system from overload, despite the fact that these masts and their associated tracks were destroying the landscape that should be protected by that system.

Despite all this, we are pleased that the system has been tightened, but we have not been sufficiently close to a particular planning case in the last year or two to actually see the difference that the changes have made.

Other areas where we feel that stronger legislation and guidance is required is in the control of altitude and visibility of masts, and the requirements for removal of masts and the restoration of the ground under the masts and along the access tracks. We believe that the erection of masts on hilltops and other prominent places should be outlawed and this should be reflected in planning law and the relevant NPPG. We are also aware that as technology develops and better network coverage is achieved by use of some form of satellite system rather than via masts, there will be a time when masts are removed and ground restored. Our fear is that agreements to restore ground will be interpreted very lightly and will probably amount to sprinkling some seeds on the few square metres below where the mast once stood. Agreements need to be much stronger than this, and should ensure that all materials are removed from site, and vegetation under the mast, adjacent buildings, and along access tracks be fully restored. It would be better to face up to this issue now, rather than at a time when 90% of the masts have been removed. Government waited until most of the masts were on the ground before making a necessary law to protect the landscpae, so we would not like to see it make the same kind of lazy mistake when it comes to addressing the removal of masts.

9 May 2003

MCofS Consultation Responses