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6 Nov 2020

Protecting our heritage from insensitive development

Written by Rebecca Millar, Policy Officer
A view across Glen Lui in the summer sunshine
The Cairngorms National Park is the largest in the UK – it contains many different landscapes, including forests, rivers, moorland and mountains
Our most valued sites, like National Parks, Sites of Special Scientific Interest, World Heritage Sites and Conservation Areas are protected by the planning system, which guides development and acts as a barrier to insensitive development.

The Scottish Government is consulting on changes to Permitted Development Rights to make it simpler for developers to extend the height of phone masts and install and extend other digital infrastructure. Some of these proposed changes will affect Scotland’s protected areas. The Trust is concerned that these changes may have unintended but significant impacts on our natural, built and cultural heritage.

The proposals would mean that instead of having to go through the planning system, developers could extend the height of phone masts and extend or install new digital infrastructure in protected areas without planning permission.

Removing the scrutiny of the planning system will jeopardise the integrity of our most valued heritage, as local authorities will no longer be able to stop thoughtless and insensitive development at protected sites. It could also leave our most sensitive areas open to ‘development creep’.

Under the proposals, developers would have the right to extend existing phone masts up to 30m, 50m or 60m tall in protected areas (depending on their current height). This could cause substantial changes to our most sensitive and special areas and have a marked impact on the visual amenity of Scotland’s landscapes.


Case study 1

Strathmashie lies within the Cairngorms National Park, and in early 2020 Highland Council approved a planning application to erect a 20m-high phone mast there. The Cairngorms National Park Authority also had oversight of the application. Under the new proposals, this mast could potentially be extended up to 60m high – three times the size it is now with limited or no oversight from either authority. This would make it the height of the Scott Monument in Edinburgh!

A tall monument with a large spire dominates the skyline in Edinburgh.
Under the new proposals, masts in protected areas could be extended to the height of the Scott Monument without planning permission

As well as introducing new rights to extend masts, the proposals would allow digital infrastructure (such as antennae, housing cabinets for infrastructure and small cell systems) to be extended or installed in protected urban areas.

The Trust cares for many listed buildings in Conservation Areas and World Heritage Sites. Through these we celebrate Scotland’s architectural history, which attracts visitors from all over the world. Conserving our built urban heritage is culturally and economically important, but these proposals would allow development to occur with minimal oversight. This will likely result in an increase of visual clutter, which would negatively impact the historical and cultural character of areas and permanently damage the fabric of historic buildings.


Case study 2

Much of the heritage the Trust cares for lies in urban areas. The Georgian House in Edinburgh is part of a World Heritage Site and Conservation Area. Under the proposals, up to five antennae could be built on the Georgian House with no planning oversight or opportunity for the Trust to voice concerns.

A row of terraced townhouses with a unified exterior on a sunny day. A road runs before them.
The Georgian House, Edinburgh, which was designed by renowned architect Robert Adam

The proposals would also allow underground development in protected areas to take place without planning permission. In scenic areas, such as National Scenic Areas and National Parks, digging up land could scar the landscape and cause physical damage to archaeological sites. Development may also negatively impact the soil, water distribution and habitats in designated areas, harming ecosystems and biodiversity.

Although removing planning oversight may make the development process quicker, the Trust fears it could have the unintended consequence of allowing damaging development to occur at our most valued sites. We also believe that these proposals discourage a landscape-sensitive approach to development. Our landscapes, both urban and rural, are a precious social, economic and cultural resource. Landscape-sensitive development ensures that development only proceeds that doesn’t degrade these attributes.

The Trust is responding to the Scottish Government’s consultation on the Permitted Development Rights proposals. To make sure we continue to safeguard the places most precious to us, the Trust is calling for development to be subject to appropriate scrutiny and for Scotland to take a landscape-sensitive approach, guided by considered development plans produced by local authorities.

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