After listening to residents and objectively looking at the proposals, our Planning working group have lodged an objection to the City of Edinburgh Council over the proposals for a mobile phone mast next to Montgomery Street Park.

20/04148/PA: Objection from Leith Central Community Council

Prior notification for electronic communication code operators. | Telecommunications
Mast North East Of Montgomery Street Park Montgomery Street Edinburgh
Leith Central Community Council objects to the application and, in accordance with the
particulars listed below, the City of Edinburgh Council should refuse the application.

Reasons

The application is contrary to the Edinburgh Local Development Plan Policy RS 7 Telecommunications

● It would not have 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.
● Such evidence, including any reasons for rejection, would not have accompanied the application.
● The visual impact of the proposed 20m mast would not have been minimised through
careful siting, design and, where appropriate, landscaping.
● The application would not have demonstrated that all practicable options to minimise
impact have been explored, and the best solution identified.
● The proposal would be considerably taller than all nearby buildings and would
overwhelm the adjacent listed church at 121 Montgomery Street, Calton Centre,
Formerly Kirk Memorial Evangelical Union Church.
● The proposal would harm the natural heritage of Montgomery Street Park as it would be 5m taller than the park’s mature tree canopy..
● The application would not have provided a detailed assessment of the impact of
telecommunication waves on the health of the adjacent mature trees.
● The proposal would harm the built heritage of the city by being located on the New Town Conservation Area boundary.
● The proposal would comprise a large cluster of apparatus at its top which would add to the visual impact it would have on the New Town Conservation Area.
● The City of Edinburgh Council’s Mast Register would not have been used to check for a suitable site (“it was felt that the industry database was a more up-to-date source of
information – Planning justification statement – p1).
● A valid operational justification would not have been provided.
● An assessment of the cumulative impact of individual proposals where other
telecommunications developments are present nearby or are proposed to be located
nearby would not have been provided. Such an assessment would describe how the
cumulative effects have been considered and any negative visual impact minimised.
● The application would not have demonstrated that the site is wide enough to
accommodate the proposed equipment without impacting upon pedestrians traffic
provision.

The application is contrary to the Edinburgh Local Development Plan Policy Env 6 Conservation Areas

● The proposal would not have demonstrated that it does not adversely affect the setting
of the New Town Conservation Area.
● The application would not have provided a sufficiently detailed form for the effect of the
development proposal on the character and appearance of the area to be assessed.
● The application is not including visuals or photomontages to demonstrate the minimal
impact of the proposal.

The application is contrary to the Edinburgh Local Development Plan Policy Env 16 Species Protection

● The application, by its very nature may have a detrimental effect on European Protected
Species (EPS) covered by Habitats Regulations. Bats are often sighted in Edinburgh
parks and a full bat survey of the current status of the species and its use of the site has
not been provided.
The application is contrary to Section 59 of the Planning (Listed Buildings and
Conservation Areas) (Scotland) Act 1997
● The proposal would not have demonstrated that a special regard has been given to the
desirability of preserving listed buildings or their setting or any features of special
architectural interest which they possess.
● The proposal would not have been advertised as affecting the setting of a Listed Building
(121 Montgomery Street, Calton Centre, formerly Kirk Memorial Evangelical Union
Church)

The application is contrary to Planning Advice Note: PAN 62 Radio Telecommunications

● The application would ignore the opportunities that exist in urban areas to use small
scale equipment, to disguise and conceal equipment and sensitively install equipment on buildings and other structures.
● The application would be in a visually sensitive location within an urban area where it is particularly necessary to take positive steps to disguise or conceal equipment. Such
locations include conservation areas, scheduled ancient monuments and their settings,
listed buildings and their settings and recreational areas, eg public open spaces.

The application is contrary to National Planning Policy Guideline NPPG 19: RADIO TELECOMMUNICATIONS

● The proposal would not have demonstrated that the operators have explored alternative siting and design. Information about these enquiries should accompany every planning application. Operators should thoroughly explore alternative sites to find the solution with the least landscape impact, which may help allay public concern. Where difficulties in site acquisition arise code system operators have powers of compulsory acquisition. Although due to the time involved in compulsory acquisition operators will generally seek another site.

The pre-application consultation process has not been completed

● The application is not providing evidence or data from the public consultation.
● The pre-application consultation with the Council, with regards to the siting of masts
would not have been completed. The Planning justification statement notes that the
applicant has not received a reply from the Council before proceeding to a formal
application.

For all the reasons listed above, Leith Central Community Council objects to the application and, in accordance with the particulars listed below, the City of Edinburgh Council should refuse the application.