Since the last edition of Mountain Views, the extent of the potential impact of the UK Government mandated Shared Rural Network (SRN) programme has become clearer. New planning applications for 25 or 30 metre masts in remote hill country, some of which have associated solar arrays or small wind turbines, are being submitted on a weekly basis. Ofcom has refused Freedom of Information requests to provide the locations of these proposed masts citing national security as one of the reasons for refusal, absurd as mast locations are made public when individual planning applications are lodged. However NatureScot, under Freedom of Information, has provided a list of 195 proposed sites in Wild Land Areas alone, although 47 are apparently no longer to be used. Masts of this size are 'industrial developments' and, if built, the area around each can hardly still be considered to be 'wild land'. It is unreasonable to object to masts which provide mobile phone coverage to occupied houses or to business premises but the great majority of applications for masts in Wild Land Areas do no such thing. The SRN has chosen sites by using desktop mapping to identify areas with limited or no mobile coverage, not by identifying inhabited areas where additional masts would serve populations. Some masts have been sited to link with others ('daisy chaining') in the cheapest and most convenient 'line' without any concern for the landscape implications.
The irony of all this won't be lost on readers of Mountain Views- in the not too distant future mobile phones will have a level of satellite connectivity, some already do, and ground based apparatus will rapidly become redundant!
The SRN exercise poses a threat to the whole concept of 'wild land' as great as that of large scale renewable projects but there is a difference. Many environmentalists are conflicted over renewable infrastructure in wild landscapes; they recognise the urgency of decarbonising the grid. The great majority of these masts serve no purpose.
There are twelve current, approved, withdrawn or potential sites in the Park. As well Luibeg Burn (see Mountain Views Autumn/Winter 2023-4), two are proposed for around White Bridge west of the Lynn of Dee, three for Glen Tilt and two for Glen Feshie plus other spots.
A broad opposition has emerged. In addition to the group of organisations (which NEMT is a member of), co-ordinated by the John Muir Trust and Mountaineering Scotland, individuals and landowners who don't want specific masts on their land have joined the fight.
A twin track approach has emerged which NEMT fully supports: objecting to applications where these serve no communities (especially those in Wild Land Areas) and political campaigning (contacting politicians; making the case to Ofcom and the Shared Rural Network for a rethink; media publicity etc). The former is essential, and has born some fruit in that a number of application have been withdrawn, albeit probably temporarily, but it is the latter which is most likely to bring a rethink of the programme.
Campaigning has led to questions to the Minister and discussions within Westminster. Interestingly the National Audit Committee has stated that the business case included limited evidence of the specific benefits of extending mobile coverage into remote or sparsely populated areas, including locations where building masts may be more difficult or expensive, or where there may be an impact on the environment.
In addition, Highland Council, the planning authority with the most potential applications, has called for a pause and review of the SRN rollout on the basis of widespread concerns.
Legally, no!
However, one NGO is taking a robust approach to masts proposed for its land which it considers to be in unacceptable places. It -
Glen Lyon, with mast: what the future holds? © Shared Rural Network
At the campaigning level, NEMT has supported the national campaign, raised concerns with MPs, lodged a Freedom of Information request with Ofcom, publicised the situation though various outlets and encouraged people to object to individual applications. NEMT is planning to engage further with the media.
With regard to objecting to individual planning applications, NEMT's policy is-
To date, NEMT has objected to thirty applications as follows. Applicants have withdrawn those marked as such, primarily following waves of objections; however many of these are likely to be resubmitted with alterations.
NEMT has commented on, as opposed to objecting to, two other applications.
A Facebook page has also been set up.
This sorry saga will run and run but here are two examples...
Glen Clova: proposed mast above Braedownie would be highly visible on the centre skyline
© Sandy Stevenson tour-scotland- photographs.blogspot.com
Firstly, the absurd: Angus Council approved a mast on the southern end of the ridge between glens Clova and Prosen, one and a half miles north of the Airlie Monument. Another mast had recently been approved one mile north of the site. Despite national guidance saying that mast sharing should take place if at all possible, Angus Council simply accepted the developer's word, without further investigation, that this wouldn't be possible. Two tall masts a mile apart - what could be more ridiculous?
Secondly, the outrageous: two masts in upper Glen Nevis, close together and remote from any habitation whatever, are under formal consideration by Highland Council. Readers of Mountain Views will be familiar with this wonderful area between the Grey Corries to the north and the Mamores to the south. People are attracted to this place, and others like it, for the very reason that here you can escape from the trappings of civilisation. Two masts would 'industrial' the landscape. Highland Council has signalled to the developer that this location is likely to be rejected - let's hope that this is the case.
NEMT has been in contact with the Environmental Rights Centre for Scotland on how best to draft an objection to the expected planning application for the telecoms mast at Luibeg. They have given advice on the points of law involved and have offered to review our objection when the Luibeg application is resubmitted. We will be taking them up on the offer.
We have participated in a variety of letters to politicians in both Westminster and Holyrood. The official stance is that, as telecoms is not a devolved matter, the SRN is Westminsterīs responsibility. The Scottish Government is involved as it is responsible for the planning system in Scotland. To date, there have been no planning applications that have been refused and then appealed. Thus, the Scottish Government has yet to get involved.
As noted above, the problem for the politicians is that many people want improved mobile phone coverage in rural areas. Understanding that we arenīt objecting to new masts in rural areas but just new masts in remote, uninhabited areas of wild land is difficult.
We have co-signed letters to the Director of Ofcom and also to the Minister for Data and Digital Infrastructure. Initially, this was Sir John Whittingdale who was standing in for Julia Lopez. A copy of this letter was circulated to all members in October last year. Similar letters were sent to MPS on the Environmental Audit Committee and the Scottish Affairs Committee. We have since chased local MPs to pressure for a reply. The most helpful of the local MPs has been Richard Thompson, MP for Gordon, who wrote to Ofcom on our behalf. Eventually, Julia Lopez replied. Her reply and the Director of Ofcomīs reply, in true politician style, make bland points about improved coverage is better, rather than addressing the basic point that putting masts in uninhabited areas seems to be a waste of public money.
Below, I attach a reply from Kirsty Blackman MP, which illustrates the above point.
All legislative and regulatory responsibility for telecommunications rests with the UK Government and Ofcom respectively, and as such, the current consultation relates to a reserved matter. The Scottish Government is supportive of the Electronic Communications Code which aims to reduce barriers to deployment of digital infrastructure and promote infrastructure sharing between operators.
The Scottish Government has no formal role in the Shared Rural Network (SRN) programme which is a joint venture between the UK Government and the UK's four main mobile network operators.
The Shared Rural Network, developed by the UKīs four mobile network operators and the UK Government, will deliver 4G coverage to 95% of the UK, enabling rural businesses and communities to gain greater connectivity. The Scottish Government fully recognises the need to ensure that SRN deployment in Scotland is maximised whilst being cognisant of the importance of Scotland's natural environment. In order to improve communications between SRN programme leads (both UK Government and industry) and key Scottish stakeholders including the National Parks and NatureScot, the Scottish Government has organised and participated in direct discussions with these parties. They encourage the SRN programme to explore these issues with all relevant stakeholders through improved engagement and to determine mutually acceptable outcomes.
The Scottish Government has also shared with the SRN programme their experience and learning gained from our Scottish 4G Infill programme, which has deployed 55 masts to serve rural and island communities. This learning includes the importance of thorough local stakeholder engagement at the mast site selection and acquisition stage.
To date the Scottish Government has invested over Ģ1 billion of public funding to transform Scotlandīs digital connectivity through the Digital Scotland Superfast Broadband (DSSB) and the Reaching 100% (R100) programmes and improving mobile connectivity through the Scottish 4G Infill (S4GI) programme.
It is important that UK legislation and regulations supports the Scottish Governmentīs ambition to be a truly digital nation. The Scottish Government has published their Full Fibre Charter which marks a significant milestone in the development of the relationship with key commercial communications provider as we all work together to extend full fibre broadband access across Scotland.
Future-proofed digital infrastructure is critical to inclusive growth and the development of a low carbon economy. Access to high-speed digital connectivity will build resilience and enable businesses to grow - extending into new markets, enabling innovation and enhancing exports. This helps create jobs - not least in the sector - and protects livelihoods all around Scotland.
My SNP colleague Richard Thompson MP wrote to Ofcom and the UK Government on this important issue to ensure our beautiful rural areas are not overly impacted by mobile masts constructed there. Ofcom responded that they expect "MNOs [Mobile Network Operators] would normally aim to target mast site locations that are likely to provide the most substantive benefits, and for these to be deliverable in the context of local community preferences and the planning system". My SNP colleague Ian Blackford MP met with community members in Knoydart recently to discuss this issue.
The most useful political response has been that of Highland Council, which has written to the Scottish Government, asking them to pause the ongoing roll-out to allow some of the above issues to be addressed.
Going forward, NEMT intends to
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