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25/90519/B
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PLANNING OFFICER REPORT AND RECOMMENDATIONS
Application No. : 25/90519/B Applicant : Sure (Isle Of Man) Ltd Proposal : Replacement of existing radio mast, relocation of third party radio equipment and installation of new mobile telephony equipment Site Address : Esjcr Tower Esjcr Headquarters Dukes Avenue Douglas Isle Of Man IM2 4RG
Senior Planning Officer: Jason Singleton Photo Taken : 22.07.2025 Site Visit : 22.07.2025 Expected Decision Level : Officer Delegation
Recommendation
Recommended Decision:
Permitted Date of Recommendation: 22.07.2025 __
Conditions and Notes for Approval C : Conditions for approval N : Notes attached to conditions
C 1. The development hereby approved shall be begun before the expiration of four years from the date of this decision notice.
Reason: To comply with Article 26 of the Town and Country Planning (Development Procedure) Order 2019 and to avoid the accumulation of unimplemented planning approvals.
C 2. Unless otherwise approved in writing by the Department, any telecommunications cabinet, mounted equipment or telecommunications structure must be removed from the land on which it is situated, within 6 months of it no longer being required for telecommunications purposes, and such land must be restored to its condition before the development took place, so far as is practicable.
Reason: To ensure that any redundant infrastructure is removed and to comply with Strategic Plan Infrastructure Policy 3.
C 3. Notwithstanding the provisions of the Town and Country Planning (Permitted Development) Order 2012 (or any amendment or replacement of that order) no fencing, walling or gates shall be erected at the site other than as shown on the approved plans shall be erected.
Reason: to ensure the development is carried out in accordance with the approved plans in the interests of the visual amenity of the area.
C 4. The proposed antennas, dishes and RRU shall be coloured to match the tower / mast to which they are affixed and retained in perpetuity.
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Reason: To mitigate any visual impact.
C 5. The proposed telecoms mast here by approved shall be no higher than the stated 40.7 m when measured from the concrete base as shown on plan referenced; 105 REV-C
Reason: To ensure the mast height is installed in accordance with the approved plans
This application has been recommended for approval for the following reason. The proposed application is not considered to harm the use and enjoyment of neighbouring properties nor would it result in any adverse impact upon the street scene or its setting and would comply with Spatial Policy 5, General Policy 2 (b,c,g,m) Environmental Policy 22, and Infrastructure Policy 3 of the IoM Strategic Plan.
Plans/Drawings/Information;
This decision relates to drawings and supporting information submitted on 28 May 2025, referenced; 100 - Rev C 101 - Rev C 102 - Rev C 103 - Rev C 104 - Rev C 105 - Rev C 106 - Rev C __
Right to Appeal
It is recommended that the following organisations should NOT be given the Right to Appeal:
Douglas City Council - No objection __
Officer’s Report
THE SITE 1.1 The application site forms the curtilage of the IoM Police Headquarters, Dukes Avenue, Douglas which is a large two storey detached building located to the north-eastern side of Dukes Avenue and south of the Glenclutchery Road.
1.2 To the North East corner of the secured car park (police vehicles only) is an existing steel framed lattice tower stands at 50m high square lattice tower and contains various telecommunication and telemetry systems at various heights. The base of the tower sits on a concrete base with 2.0m high palisade fencing surrounding the mast and ancillary equipment cabinets.
THE PROPOSAL 2.1 Planning permission is being sought for the replacement of the current 50m high tower and the installation of a new 40m high lattice tower on the existing concrete slab foundation. The tower would be a square tubular shape consisting of four columns with supporting bracing forming the overall structure with a grey galvanised colour. The replacement mast would be affixed to the existing concrete base within the fenced areas. The existing telecommunication cabinets and gantry cabling tray at the base level would be swapped out with replacement / modern equipment cabinets on the existing concrete base.
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2.2 The application has been submitted by one of the Island's licensed operators (Sure Mobile) and is accompanied by a certificate of compliance with the World Health Organisation's ICNIRP guidelines for public exposure. (ICNIRP - "International Commission on Non-Ionising Radiation"). Signed 19/03/25.
2.3 The applicant notes; " Sure are proposing to replace the current 50-meter square lattice tower located at ESJCR, Dukes Road, with a new 40-meter square lattice tower on amended steel support grillage, the new structure will be capable of supporting multiple panel antennas, providing 2G, 3G and 4G/4G+ coverage in the area along with capability to support next generation mobile antenna technology, tower mounted remote radio heads (RRHs) will also be mounted near the new antennas, these are required to support MIMO* on the network. Along with the Sure telecoms equipment, there will also be Tetra Tx/Rx antennas for DHA and other 3rd party equipment that will be reinstalled from the old structure to the new proposed structure. *MIMO, Multiple In Multiple Out, this is a protocol required for higher speeds and high capacity 4G/LTE".
2.4 In this instance much of the existing equipment from other operators will be relocated lower down the tower and Sure seek to replace their equipment with more modern equipment as noted below;
2.5 Mounted to the tower would be: 7 x panel antennas (two different sizes) and below this are; 8 x RRU's and one dish @ 300mm dia. None of the equipment would be higher than the top of the 40m structure.
PLANNING HISTORY 3.1 06/02192/TEL - Installation of 3 antennas and 3 dishes onto existing mast and the installation of a radio cabinet within existing equipment room. Approved.
PLANNING POLICY LOCAL PLAN 4.1 The application site is identified as 'Buildings or Land for Civic, Cultural, or Other use" on Map 4 (Douglas) of the Area Plan for the East and within the settlement boundary of Douglas.
4.2 Within the written statement accompanying the Area Plan, telecoms are noted at; o Para 7.4 iv. To provide and support the best quality telecommunications networks and to support the economy by doing so.
o Utilities Proposals 3 (in part) - The telecommunications system must be designed in accordance with the requirements of the relevant telecommunications servicing agency and should be consistent with any approved strategy, policy or plan for the provision of advanced telecommunications infrastructure, including fibre optic technology. It is expected and required that all new development be connected at the best standard possible.
o Telecommunications Proposal 1 New developments should: a) Make provision for fibre optic cables directly to each dwelling or commercial premises. b) Within Comprehensive Treatment Areas (see Chapter 13), be phased so as to ensure that telecommunications structures are installed efficiently and will avoid ongoing disruption to site foundations. c) Design facilities so as to be able to host equipment from more than one operator, and that such sharing be encouraged. d) Demonstrate that the proposal has taken into account radio networks in particular those used by the emergency services (TETRA).
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4.3 The site is not within a Conservation Area nor is it identified as being in an area at risk of flooding from surface water, river or tidal. There are no registered trees or registered tree groups boarding the site.
STRATEGIC PLAN 4.4 The following policies from the 2016 Strategic Plan are considered pertinent in the assessment of this application;
Strategic Policy 1 Development should make the best use of resources 2 Priority for new development to identified towns and villages
Spatial Policy 1 Named service centre (Douglas) 5 New development will be located within defined settlement.
General Policy 2 General Development Considerations (b,c,g)
Environment Policy 22 (iii) Safeguarding the environment and/or the amenities of surrounding properties
Infrastructure Policy 3 Need for communications infrastructure versus environmental impacts
4.5 The text preceding Infrastructure Policy 3 is an important consideration where it states in paragraph 11.9.2; o "The maintenance and improvement of these systems is likely to require the provision of new infrastructure; infrastructure required by private telecommunications operators is likely to be more extensive. It is important that a balance be struck between the need for new, evolving communications systems to satisfy residential and business demand and the impact that the necessary infrastructure will have upon the environment. New communications development should be in accordance with the provisions of this plan".
OTHER MATERIAL CONSIDERATIONS; 4.6 The Climate Change Plan 2022-2027 has an overarching series of strategies and policies which promotes a more sustainable approach to living and working, one of which is remote / home working and learning.
4.7 National Telecommunications Strategy 2018 "The National Telecoms strategy, laid out in six themes, looks to set a direction of travel by which the Island's telecom infrastructure can be recognised as being world class. The Government has made it clear that enhanced telecoms infrastructure is a top priority... The benefits will be available to all our residents and businesses on the Island and will underpin and support economic growth". This document talks broadly about telecoms on Island but geared more towards fibre broadband but does reference Mobile integration and improvement on page 19 and notes; "Access to mobile connectivity complements fixed broadband services, providing telephony and internet services where people live, work and travel".
4.8 IoM Economic Strategy November 2022 Our big Picture Evidence base report phase 1 - December 2021; Para 4.9 (page 147) - "Analysis suggest that the overall quality of internet connectivity of the Island is not keeping pace with competitor jurisdictions, such as Jersey and there has been a decline in satisfaction regarding the quality of telecommunication services".
REPRESENTATIONS (this report only contain summaries - full reps can be read online)
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5.1 Douglas City Council do not object (10/06/25)
ASSESSMENT 6.1 The main issues to consider in the assessment of this planning application are as follows:
PRINCIPLE 6.1 The site sits within the defined settlement boundary of Douglas and is within an area that is designated for development which would ensure compliance with Strategic Policy 2 and Spatial Policy 1 as Douglas is the main employment and service centre on the Island. Spatial Policy 5 ensures that any new development is within the defined settlements, to which, Douglas is.
6.2 Stp1c is adhered to as the applicants are utilising a previous telecoms site and the existing infrastructure and facilities in this area (albeit replacing the supporting mast and newer equipment).
6.3 The proposals also reflects the investment and modernisation of communications equipment on site which is sought as part of the overall Island Economic Strategy and those supporting policies within the TAPE written assessment. As such the general principle would comply with the land use designation, STP1,2 and SP1,5.
JUSTIFICATION 6.4 The application is submitted by Sure Mobile, essentially to improve the available mobile signal coverage to both indoor and outdoor demands within this part of the Island, but also to the wider catchment of the East of the Island and the DHA emergency services TETRA communication network, as demonstrated as part of the submission.
6.5 In favour of the proposals is Infrastructure Policy 3 and its supporting text which broadly advises that the maintenance and improvement of the Island's telecommunications systems will likely require the provision of new infrastructure and a balance has to be struck between the need for new, and evolving communications systems, particularly to satisfy the needs of residential and business demand, and the impact of such required development upon the environment.
6.6 The replacement of the existing mast with a reduced height and relocation of existing equipment and new antennas will also have the capacity to support next generation network development and would continue with mast sharing which this (IP3) policy seeks.
6.7 The overall "need" for the replacement mast and modernisation of telecommunication equipment can be substantiated in this instance and works towards the overall Government objectives to enhance the level of connectivity through the investment and modernisation of communications equipment. This will result in the provision of newer and faster technology as part of the Islands communication goals, which is also part of the overall Island Economic Strategy and is welcomed as technology and demands on mobile services increases. As such this aspect would be read in accordance with IP3 of the IOM Strategic Plan.
VISUAL IMPACT 6.8 General policy 2 ensures any visual impact does not adversely affect the character of the surrounding landscape. The opening sentence of Infrastructure Policy 3 is also helpful when balancing the need and any visual impact. The policy narrative helps to ascertain the visual impact and the reduction in overall height and the replacement of antennas, RRU's and a
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dish, particularly to the upper proportions would not be visually detrimental to the setting when up close or further afield, noting the topography and the land use designations surrounding the site and the build forms in the immediate vicinity.
6.9 The replacement tower will essentially echo the current mast in appearance and is not a solid structure, but rather one that you can essentially look through and it blends in with the surroundings. The structure itself is a galvanised tower which helps with mitigating visual impact further due to the structure blending better with the sky behind as you look up at it from surrounding areas. Whilst the level of equipment to be replaced by 'Sure' is increasing, this should not be any visually different to the existing and would be coloured to match the tower (grey) helping the two to 'blend in'. The trade-off here is a lower mast and improved appearance of an existing communications tower. The ground level equipment would be replaced and is not seen from outside of the site and will remain behind the existing palisade fencing.
6.10 On this the applicant notes; "The tower at ESJCR has been in place for over 25 years so it has been part of the Douglas skyline for a considerable amount of time, the proposed plans would be to replace this with the same type of structure, just with 10-meter height reduction, this with the amount of time the structure has been in place will mitigate the visual impact of replacing the current structure".
6.11 On this basis, it is considered that the proposal would not create any additional visual harm into the site and surrounding buildings, street scene and would conform to those parts of General Policy 2(b,c) and Infrastructure Policy 3.
RESIDENTIAL AMENITY 6.12 The proposed reduction in height of the tower would not give rise to materially affect any of the surrounding properties through any loss of light, overbearing impact or loss of privacy as a result of the installation. As such the proposal would comply with GP2g.
PUBLIC HEALTH 6.13 In terms of health issues associated with a telecommunication mast and the proximity to residential dwellings, the Isle of Man has no specific guidelines in how to deal with such concerns. However, guidance in the United Kingdom (since replaced with less specific guidance) expressly advised that where a proposed telecommunications installation conforms to the recommendation of The Independent Expert Group on Mobile Phones ("The Stewart Report") and the guidelines for the public exposure set by The International Commission On Non-Ionising Radiation Protection (ICNIRP), then the Local Planning Authority should have no concerns with regard to health and safety issues.
6.14 The application is accompanied by a certificate of compliance with the World Health Organisation ICNIRP guidelines for public exposure, and the 'Health and Safety at Work Inspectorate' is responsible for the monitoring of telecommunications installations to ensure compliance with the ICNIRP Guidelines. No concerns relating to the safety of the general public are therefore raised. In this respect, the proposal is compliant also with GP2(m).
6.15 Equally the proposals would comply with EP22 as it would not be seen to create any statutory nuisance through vibration, odour, noise or light pollution during its operation.
CONCLUSION 7.1 The proposed installation is considered to have a neutral visual impact, it is not considered that this will be significantly detrimental to the established amenity of the street scene here or that on the surrounding buildings. It is concluded that the planning application would not harm the use and enjoyment of neighbouring properties thought its visual impact or its continued use as a telecoms tower and would comply with aforementioned planning policies of the Isle of Man Strategic Plan 2016, and is recommended for approval.
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RIGHT TO APPEAL AND RIGHT TO GIVE EVIDENCE 8.1 The Town and Country Planning (Development Procedure) Order 2019 sets out the process for determining planning applications (including appeals). It sets out a Right to Appeal (i.e. to submit an appeal against a planning decision) and a Right to Give Evidence at Appeals (i.e. to participate in an appeal if one is submitted).
8.2 Article A10 sets out that the right to appeal is available to: o applicant (in all cases); o a Local Authority; Government Department; Manx Utilities; and Manx National Heritage that submit a relevant objection; and o any other person who has made an objection that meets specified criteria.
8.3 Article 8(2)(a) requires that in determining an application, the Department must decide who has a right to appeal, in accordance with the criteria set out in article A10.
8.4 The Order automatically affords the Right to Give Evidence to the following (no determination is required): o any appellant or potential appellant (which includes the applicant); o the Department of Environment, Food and Agriculture, the Department of Infrastructure and the local authority for the area; o any other person who has submitted written representations (this can include other Government Departments and Local Authorities); and o in the case of a petition, a single representative.
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I can confirm that this decision has been made by the Head of Development Management in accordance with the authority afforded to that Officer by the appropriate DEFA Delegation and that in making this decision the Officer has agreed the recommendation in relation to who should be afforded interested person status, and/or rights to appeal.
Decision Made : Permitted Date : 22.07.2025
Determining Officer
Signed : S BUTLER
Stephen Butler
Head of Development Management
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