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CAIRNGORMS NATIONAL PARK AUTHORITY 
Interim Planning Policy No.2: Radio Telecommunications 30/01/04 
CAIRNGORMS NATIONAL PARK AUTHORITY 
Title: SUPPLEMENTARY GUIDANCE FOR THE 
CAIRNGORMS NATIONAL PARK: 
INTERIM PLANNING POLICY No.2: RADIO 
TELECOMMUNICATIONS (Preliminary Draft). 
Prepared by: NORMAN BROCKIE, PLANNING OFFICER 
(Local Plan/Policy) 
Purpose 
This aim of this report is to introduce the preliminary draft of Planning Policy No.2: 
Radio Telecommunications. In its present form it is intended as a discussion 
document which will be modified, probably through several drafts, in response to 
the Committee’s comments and responses from external consultees. 
Recommendations 
1. The Committee supports the intention to proceed to the ‘Interim Planning 
Policy No.2: Radio Telecommunications’ (Consultation Draft) which will be 
issued to the four constituent Local Authorities, Perth & Kinross Council, other 
statutory bodies/interest groups and the constituent Community Councils for 
consultation and comment. 
2. A report will be submitted to a future meeting of the Committee on the 
responses to the draft document from consultees. 
Executive Summary 
This Policy Paper has been developed in direct response to issues that have arisen 
and proven contentious/problematic to the CNPA development control process. The 
issue of Radio Telecommunications, particularly mast installations on hilltops, will 
obviously have a significant impact on the landscape of the National Park. 

INTERIM PLANNING POLICY No.2:
RADIO TELECOMMUNICATIONS (Preliminary Draft).
Contents: 
page 
1. Introduction 1 
2. National Policy Guidance 1 
3. Local Authority development plan policy 3 
4. English & Welsh National Park Policy 3 
5. Siting and Design 3 
6. Suggested Policy 6 
7. Appendix 1: Local Authority Policies 8 
8. Appendix 2: English & Welsh National Park Policies 10 
1. INTRODUCTION. 
1.1 Since the Cairngorms National Park was set-up on the 1st September 2003, 
and started to implement the development control call-in procedure, a number 
of issues have emerged as problematic/contentious to the planning process. 
The issue of telecommunication developments is one such issue, particularly 
with regard to landscape impact. The growth in demand for telecoms, and 
advances in technology, are likely to have serious implications for the planning 
system, and for designated landscapes such as National Parks. 
1.2 While we must carefully assess telecom proposals for their impact on the 
National Park, we must also accept that remote and ‘peripheral’ areas (in 
UK/EU terms) will require good telecommunication networks for economic and 
social development. 
The AIMS of the CAIRNGORMS NATIONAL PARK: 
1.3 While the CNP must have regard to national planning policy, existing 
development plan policies and specialist advice (e.g. from SNH) for guidance 
towards the formulation of its own policies, central to all Park policy must be its 
four aims; these are: 
a) to conserve and enhance the natural and cultural heritage of the area; 
b) to promote sustainable use of the natural resources of the area; 
c) to promote understanding and enjoyment (including enjoyment in the form 
of recreation) of the special qualities of the area by the public; and 
d) to promote sustainable economic and social development of the area’s 
communities. 
1.4 Where there is conflict between these four aims, greater weight must be given 
to the first. While the development of telecom networks can certainly be relevant 
to the fourth aim, the very nature and proliferation of such developments can 
also have a significantly adverse impact on the first. 
2 NATIONAL POLICY GUIDANCE 
2.1 There are three principal pieces of planning guidance issued by the Scottish 
Executive: 
Circular 5/2001 (changes to the General Permitted Development Order 
regarding telecommunications development). 
NPPG 19: Radio Telecommunications. 
PAN 62: Radio Telecommunications.
2.2 Circular 5/2001 : The Town and Country Planning (General Permitted Development) 
(Scotland) Amendment (No.2) Order 2001: Development by Telecommunications Code 
System Operators. This Circular outlines the revisions made to the permitted 
development rights (PDR) previously applicable to certain classes and sizes of 
telecommunications development. Of particular interest is section 12, which 
removes the PDR from development within National Parks (with 3 exceptions: 
emergency development, up to 2 small antennas on a house [neither of which 
faces onto a road] and a new line between existing telegraph poles). All cases 
with permitted development rights must still, however: 
notify the Planning Authority (who may comment); 
remove un-required equipment and restore the site; 
declare compliance with radiation protection (where relevant). 
2.3 NPPG 19: Radio Telecommunications (July 2001). The purpose of this policy 
is to ensure that Scotland has world class telecommunications services, while 
minimising the environmental impact of new or replacement equipment. The 
document deals with all the general issues which are related to telecom 
installations. Sections 19-22 and 53-55 cover health issues, although they give 
no practical advice, only saying that health issues are the concern of bodies 
other than the Planning system; regardless of this, any installation close to a 
settlement or houses must be fully licensed to cover health and safety issues. 
Sections 28&29 cover the economic benefits of having good telecom networks, 
particularly in remote and peripheral areas, and playing a key role in improving 
Scotland’s efficiency and productivity. 
2.4 PAN 62: Radio Telecommunications (Sept.2001). This paper provides the 
detailed background for NPPG 19, with advice on siting and design, and 
general information on the variety of telecom systems in operation. The 
systems are summarised below, siting & design issues are covered in section 
5. 
2.5 Some of the most common systems in operation are summarised as: 
Mobile radio telecom systems (mobile telephones): these work by 
using radio frequencies which are served by geographical cells; each 
operator divides the country into hundreds of cells, at the centre of 
each is a base station. The area covered by each cell is governed by 
its anticipated call-capacity, height of the antenna above ground, 
terrain and radio frequency. There are 3 sizes of base station: 
macrocell (providing the main radio coverage, generally mast-mounted 
or fixed to existing structures), microcell (filling the gaps between 
macrocell, antennas are usually small boxes, mounted on 
buildings/structures in urban areas) and picocells (small antenna inside 
large buildings). 
TETRA (Terrestrial & Trunked Radio) and pager systems: this system 
is used by the emergency & public safety services; they utilise a wide 
variety of mast types, but are generally thinner & taller than those used 
by mobile operators. 
Private Business Radio (PBR): these utilise small antennas for specific 
groups of users. 
Fixed Radio Access (FRA): these utilise groups of small antennas 
which require direct sightlines between base stations. 
Other radio telecom systems: such as for broadcasting operators; 
antenna are usually microwave dishes fixed to large lattice masts. New 
networks will be required to facilitate the change from analogue to 
digital systems. Dish antenna are also used to communicate with 
satellite systems. 
3 EXISTING DEVELOPMENT PLAN POLICY BACKGROUND 
3.1 The four constituent Local Authorities within the CNP all have existing 
Development Plan policies or guidance for telecommunication developments. 
Proposals will be granted and encouraged, subject to: locational, visual impact, 
mast-sharing, health, and operational need issues being satisfied. Highland 
has particular policies relative to the health issues concerned with microwave 
systems. 
3.2 See Appendix 1 for a summary of relevant policies. 
4 ENGLISH & WELSH NATIONAL PARK POLICIES. 
4.1 The English and Welsh National Parks all have policies for telecom 
developments which impose strict criteria for assessing their environmental and 
visual impact; as a rule, the character and natural beauty of the Park must not 
be adversely affected. A selection of policies are summarised in Appendix 2. 
5 SITING AND DESIGN ISSUES 
5.1 The siting and design of telecommunications development are the key issues 
to be addressed by the planning system; the visual & landscape impacts are 
likely to be the most important aspects for the National Park, as well as other 
environmental considerations. 
5.2 There are various options available in site selection and base station design, 
some of which are summarised below: 
Small scale equipment: the smallest suitable equipment and structures 
should always be installed. 
Concealing and disguising: there are various options available to 
camouflage and disguise installations. Painting equipment to match its 
background/setting is the most obvious method; if the antenna is fixed to a 
building, it can be enclosed in GRP (glass-reinforced plastic) moulded to 
match an architectural feature. Screening by trees can be an effective 
method of helping to conceal a telecom development, but a planning 
condition may be required to maintain the tree cover. There are some mast 
designs that try to look like trees, but these should be used carefully. 
Mast sharing: mast sharing should be the first option considered where 
there are existing installations in the area, unless the sharing will cause the 
structure to be enlarged to an unacceptable level. The conditions in code 
system operator’s licences require them to explore the possibility of 
sharing, and it will also lead to a quicker and cheaper installation. If sharing 
has not been considered, the planning authority may ask for more 
information. Any new mast must be structurally capable of being shared by 
additional telecom developments. 
Site sharing: where an existing mast cannot be shared, then a new one may 
be erected close-by to share infrastructure, this may of course lead to a 
negative impact via their cumulative effect; a careful balance must be 
struck therefore between a concentration of masts, or their dispersion 
across the landscape, and analysis of which solution has the least visual 
and environmental impact on the landscape. 
Installations on buildings or other structures: siting equipment on buildings, 
chimneys, spires, silos or electric pylons can utilise already dominant 
features in the landscape ~ and minimise new developments. 
Ground based masts: the final option is to erect a new mast 
5.3 Landscape Impact. The most obvious issue relative to telecom developments is 
the visual impact on the landscape, closely followed by the physical impact. 
Within designated landscapes, extra care must be taken to reduce these 
impacts. A prominent hill-top location may be the best solution for radio 
coverage, but it will also create the greatest adverse impact. If a new mast 
must be provided, we will expect careful consideration of site options and a 
search for the least intrusive solution/location. 
5.4 The Cumulative Impact of the development, in conjunction with existing 
telecom installations, must not detrimentally affect the character of the National 
Park. 
5.5 Natural Heritage Issues. Important issues will be: loss of habitat (from the mast, 
ancillary development, access track, power supply etc.); disturbance to wildlife 
(this will be a particular concern during breeding periods, but also during 
shooting seasons); and changes to drainage & hydrological patterns. All of the 
above must be carefully considered and mitigation measures included in any 
planning application. Where a proposal is within the breeding territory of 
endangered bird species, e.g. raptors, consultation with the RSPB & SNH may 
rule against the proposal. 
5.6 Health Issues. Health and safety issues, and exclusion zones, are covered by 
other legislation; we would expect, however, that any planning application lists 
the health issues involved and what precautionary procedures will be 
implemented. We would note that Highland council restricts the installation of 
microwave equipment from occupied Council property. 
5.7 Ancillary Equipment. Equipment housing, and compound fencing, can often 
make as much landscape impact as the mast/antenna and must be carefully 
designed using the principles throughout this section; as well as painting or 
screening, undergrounding or landscaping should be considered. 
5.8 Power Supply. Radio telecomm equipment requires a power supply, which can 
be problematic in remote and exposed areas. New power supplies to exposed 
sites should be by underground cable, not overhead lines. Where a generator 
is to be used, or a renewable energy source such as solar panels or a wind 
turbine installed [although a back-up supply is usually also required], the siting 
and design must ensure a minimal landscape impact. 
5.9 Access Tracks. Vehicle hill-tracks as a general issue are covered in more detail 
by Interim Planning Policy No.3. Existing tracks should be utilised whenever 
possible, as new tracks can sometimes be more intrusive on the landscape 
than the telecom installation itself. Tracks should be carefully designed to make 
the minimum visual and environmental impact. 
5.10Replacement and Redundant Equipment. Replacement equipment should aim 
to be less visually intrusive than what is being replaced. Equipment which 
becomes redundant must be completely removed from site, and the site itself 
restored to natural condition. Code system operators are required to do this by 
the Telecom Act 1984, but planning conditions may still be applied. This also 
applies to access tracks, which should be returned to an appropriate natural 
state. 
5.11 Historic Environment. Within Conservation Areas, or on Listed Buildings, all 
new equipment will be subject to full planning control and Listed Building 
Consent as appropriate. An installation on a Listed Building should be on the 
least visible aspect and have no detrimental impact on the building’s character. 
Within Conservation Areas no installation should be on the main façade(s) of a 
building. For all situations, the roof-lines must also be kept clear. 
SUGGESTED POLICIES 
6 A wide range of policy options would be permissible as a basis for Interim Policy 
Guidance, depending on the ‘degree of restriction’ the CNPA wishes to exercise 
over telecommunication projects. This, in turn, will be influenced by its view 
(informed by consultation with the four constituent Local Authorities, Perth & 
Kinross Council, statutory bodies, interest groups and the local communities) 
about the balance between man-made and natural features which is appropriate 
to this National Park. The following policies are therefore offered as a starting 
point for discussion. They are based on the following prepositions: 
a) In relation to considerations of landscape, environment and cultural 
heritage, the Cairngorms National Park is of the highest importance in 
national terms. 
b) Outwith established settlements and other clearly defined development 
centres, there should be a strong presumption against further incursions of 
man-made developments within the Park, except for those necessary to 
serve the needs of local communities or to promote the understanding and 
enjoyment of the special qualities of the area by the public. 
c) The support of constituent and adjacent Local Authorities should be sought 
to protect the Park from unsightly telecom developments outwith its 
boundary, which adversely affect its setting or detract from important 
views. 
7 POLICY FOR TELECOMMUNICATIONS DEVELOPMENT. 
7.1 Telecom proposals are likely to make a significant impact on the Park, partly 
due to the hilly landscape, but also from their proliferation and cumulative 
effects. To achieve adequate coverage in such a mountainous area will 
obviously not be easy, but we must still avoid a mast being erected on every 
hilltop. Where existing installations cannot be utilised, any new development 
must be sited and designed to make the minimal landscape and environmental 
impact. 

Policy RT1: RADIO TELECOMMUNICATIONS DEVELOPMENT. 
Radio Telecommunicaton proposals will be permitted where all of the 
following critera are met, in line with the siting and design critera in section
5 of ths paper: 

a) The proposal has no adverse impact on the landscape or cultural 
heritage of the Park, from any of its works, or through cumulative impact the 
siting and design must minimise the visual and envronmental impacts. 
b)There are no adverse envronmental impacts on fora, fauna or habitats. 
c)The applcant is licensed, and there is an established operational need 
for the location proposed.  
d)Existing masts, sites and other structures cannot be shared; a justification is required. 
A new mast must be structurally capable of being shared by additonal telecom systems.  
e) alternatve sites have been investgated. 
f)There is no discernible risk to publc health; a certcate in accordance 
with the Publc Exposure Guidelines is provided. 
g) There will be no adverse impact on residential prpoerties or communities
h)Exsting telecom servces will not be interfered with. 
i)all related powerlines will be routed underground. 
j)Any assocated buidings/infrastructure,including access tracks and 
fencing, should be designed and sited to minimise visual and environmental impacts. 
k)No advertising signage or logos, or non-safety lightng, may be incuded 
with the development.
l)  all redundant equipment and infrastructure is to be removed at the end 
of their lifespan, and the site reinstated to an approved natural condition

The CNPA may seek independent technical advice in relation to the proposal, and 
in particular clauses c), d) & e) of the Policy. 
16 LANDSCAPE AND ENVIRONMENTAL ISSUE CHECKLIST. 
16.1 Further information may be required for the consideration of an application, 
along the following lines: 
Sustainable Development: materials, location, energy 
production/consumption, local jobs created/sustained 
Landscape: impact assessment, visual impact analysis, ZVI (zone of visual 
influence), viewpoint analysis, photo-montages. 
Natural Environment: designations, NVC survey of vegetation, habitat & 
species survey & impacts, landscape impact assessment. 
Built Environment: impact on local properties and heritage. 
Infrastructure: road access & tracks, construction traffic, driver distraction, 
power connections. 
Pollution: noise, shadow flicker, interference. 
Tourism/Recreation: effect on footpaths/cycleways, visual assessments 
from tourist routes/viewpoints. 
Proximity to settlements: 
Effects on Aircraft: 
Cumulative impact: 
Community Consultation: 
Decommissioning and Site Restoration:
Conclusions 
While the CNPA would wish to support the development of telecommunication 
networks, to benefit the local economy and social infrastructure, these 
developments must be carefully sited and designed to minimise their visual and 
environmental impacts within the above policy framework. Within a landscape 
designated for its national importance, all ‘man-made’ development will have some 
effect on its character, and every effort must be made to mitigate these. 
Norman Brockie 
30th January 2004
APPENDIX 1: CONSTITUENT LOCAL AUTHORITY’S 
EXISTING DEVELOPMENT PLAN POLICIES AND GUIDANCE. 

Local Authority/Plan 
Policy Contents (summarised)

Highland 
Council 
Structure P2001 
U4: Telecommunicatons.
Contents (summarised)
Proposal for masts and other telecom. 
structures will be favourably considered 
providing they comply wth Strategic polcy 
G2 (sustainable design) and the following 
criteria: 
exsting masts and other structures cannot be shared. 
existing servces are not interfered with. 
There is no discernible risk to public health. 
the operator is licensed (excl domestic) 
the proposal forms part of a network (excl. domestc). 
redundant masts and equpment are removed (without preudice to re-use elsewhere). 
U5: Telecoms. And Council Property.
Contents (summarised)
New installation of microwave telecom. 
equipment will not be permitted on or near 
Counc‘sensitive’(occupied) property. 
RECOMMENDATION 
U6: Telecoms. And 
magnetic Fields. 
The Council recommends (to Government)that precautionary guidance be issued for 
micrcrowave telecom. equipment near public occupancy. 
RECOMMENDATION 
U7: Telecoms. And 
Planning Requirements. 
The Council recommends (to Government) that permitted development rights for free standing 
telecom. masts & assocated 
infrastructure be wthdrawn. 
Badenoch & 
Strathspey 
Local Pan 1997 
2.4.18 
Contents (summarised)
The Council will favourably consider 
proposals provided that: 
visual amenity and nature 
conservation interests are not 
signifcantly affected. 
and criteria similar to those in the 
Structure Plan

Moray Council 
Development 
Plan 2000 
L/ED9: 
Telecommunicatons 
Contents (summarised)
Proposals will be permitted where they 
meet environmental criteria, health 
regulatons and locational requirements; sites may need to be justified and mast 
sharng will be encouraged. Camoufaging 
and impact mitigation wil be sought

Aberdeenshire 
Council 
NEST Structure Plan 2001-2016 
Policy 4: Telecommunications 
Contents (summarised)
..developments are encouraged but should 
 be sited and designed to minimise adverse 
impact. Local Plans should prepare policy 
guidance. 

Finalised Local 
Plan August 2002 
Inf\9: Telecommunications Masts
Contents (summarised) 
Telecommunications masts and associated 
apparatus will be approved, in principle, 
where they comply with the Four Tier 
approach (for environmental designation) 
and 
a) they are sited and designed to minimise 
visual impact or they reduce the 
intrusiveness of existing masts or 
antennae; 
b) the developer provides a certificate in 
accordance with the Public Exposure 
Guidelines; 
c) any rejection of options for mast sharing 
and installation on existing structures has 
been fully justified; AND 
d) removal, land restoration and after use 
details are satisfactory. 
In National Scenic Areas and Areas of 
Landscape Significance additional care 
must be taken in the siting and design of 
masts and antennae. 

Angus 
Council 
Dundee&Angus 
Structure Plan 
2001-2016
No specific policy.  

Angus Local 
Plan 2000 
Policy TRA19: Telecommunications.
Contents (summarised)
Planning permission will be granted where 
the following criteria are met: 
There is an established operational 
need for the location proposed. 
There are no satisfactory alternative 
sites. 
Existing facilities cannot be shared. 
(for radio masts) antennae cannot be 
erected on existing 
buildings/structures. 
Any development should be sited and 
designed so as to minimise its visual 
impact, subject to technical and operational 
considerations. 

Angus Council 
Advice Note 26: 
Telecom Developments 
General advice on the health issues, visual 
impact, design and planning requirements 
related to telecom. developments.

APPENDIX 2: SELECTION OF LOCAL PLAN TELECOM. 
POLICIES IN THE ENGLISH & WELSH NATIONAL PARKS. 
National 
Park/ Plan 
Policy Contents 
Dartmoor 
DNP Local Plan Revised Deposit April 2003 
Policy UT6: Telecommunications. 
Contents (summarised)
Developments will be permitted where: 
They do not adversely affect the 
wildlife, natural beauty or cultural 
heritage of the Park; 
It can be demonstrated that there are 
no suitable alternative sites or 
structures that could be used to reduce 
visual impact.
 
Lake District 
LDNP Local Plan 1998
Policy UT7: Telecommunications Development. 
Contents (summarised)
Proposals will only be approved where their 
need outweighs the landscape and 
environmental impacts. Approval may be 
time limited, followed by a review and 
removal of the development at the end of its 
life. 

North York 
Moors NYMNP Local Plan May 2003 
Policy U1: Telecommunications 
Contents (summarised)
Masts will be permitted where the proposal 
does not have an unacceptable impact on 
the character of the locality and wider 
landscape. Where such impact cannot be 
mitigated by alternative sitings or design, 
consent will not be granted. 

Snowdonia 
Eryri UDP 200116, Deposit Version October 2003 
Policy A 37 
Telecommunications 
Development 
Contents (summarised) 
Proposals for telecommunications development 
will be permitted so long as it can be 
demonstrated to the satisfaction of the Authority 
that the proposal does not detrimentally harm the 
visual character or special qualities of the locality 
or wider National Park area, or the amenity of 
those individuals living within close proximity of 
the site, having due regard to the social and 
economic benefits the proposed development will 
provide and its significance as part of a national 
network. 
In addition the Authority would expect all 
proposals to satisfy all the following criteria: 
i) It can be demonstrated that an 
acceptable level of service cannot be 
provided: a) by siting antennas on 
existing buildings or structures, 
b) by sharing an existing mast or tower 
c) sharing an existing site, 
d) through the use of a more environmentally acceptable site either 
within or outsde the Park, 
i) The cumulatve effects of the 
developmentn conjunction with other 
existing similar instalations, does not 
detrimentally affect the character or 
amenity of the National Park, 

ii)The development is desgned and 
sited so as to minimise its impact on the 
Park and on the external appearance of 
any building on which antennas or other 
apparatus are sted, 
iv) additional buildings, equipment housings and means of encosure 
required for the essental operaton of the servce are sympathetc to their 
setting and the surrounding area in terms of their desgn, scale and the 
materials used for their construction 

v)Radio-frequency radiation from the antenna is demonstrated to be below 
Internatonal Commsson on Non-Ionisng Radiaton Protecton guidline levels, 
vii)Where there is a rsk of sgnifcant radio interference, it can be 
demonstrated that this can be overcome by appropriate measures. 

The Authorty wil attach a conditon to any consent for telecommunicatons facilities 
requiring all equipment and buidings which have become redundant or obsoete to be removed wthin 
six months of the facilty ceasing to operate.