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Mono Pole and associated cabinets
FOR
Sure (IOM) Ltd
AT
Sure Site 52
Vacant plot
Woodbourne Lane
Douglas, IOM
Planning Application Supporting Statement DATE: 06 November 2020
PREPARED BY:
Redacted
Sure IOM Ltd
Sure IOM REF: Site 52 Woodbourne Lane
In 2006/7 Sure Isle of Man Limited (Sure) was awarded an Isle of Man (IOM) Mobile Operators Licence, issued by the island's Communications Commission, to provide a mobile phone network and services to the island's inhabitants and visitors. This service competes with the incumbent operator (Manx Telecom) and allows greater choice and competition for consumers and businesses.
The mobile phone network consists of a number of sites that house various pieces of equipment to provide coverage in the vicinity, such as panel antennae, and also transmission dishes that link sites together. Combined with other sites they are designed to provide an extensive, continuous network.
Sure, will endeavour, whenever possible, to install its equipment on existing infrastructure or radio transmitters. The aim is always to minimise the visual impact of providing mobile phone network infrastructure.
Where this is not possible, and it is necessary to introduce additional telecommunications infrastructure, this supporting statement will justify why the infrastructure is required and demonstrate that the best possible design available for the site has been identified, keeping visual impact and amenity a priority at all times.
It will also help to explain the decisions which led to the specific location being chosen and will outline which alternatives were considered and discounted.
A variety of supporting information may be included with each application but ultimately Sure aim is to minimise the number of new structures and reduce the visual impact of the network, whilst providing sufficient signal strength to provide coverage for customers to take advantage of a range of Sure's services.
For the avoidance of doubt: a cell site, as referred to in this document, is a combination of equipment including cabinets, antennae and structures, required to facilitate the operation of a mobile phone cell.
The proposed development will consist of a single 15-metre-tall Shrouded Monopole Including antenna and 5 cabinets housing all the electrical equipment required. The electrical cabinets will be screened from view by a 1.8 -metre-tall wooden fence. This type of Mast design has been specifically chosen as it has all structure mounted equipment within the shroud. The hight of 15 metres is to allow a radio propagation path above properties immediately surrounding the proposed location.
The proposed development site is located on a vacant plot of land on Woodbourne Lane, to the rear of 8 to 12 Woodbourne Villas, Alexander Drive, Douglas. The location of the site has been chosen as it is a vacant piece of ground, screen form the main road by properties on 4 sides. This site is also at the highest point in this part of Douglas giving the largest coverage area to a mast of this height. The proposed site is in a poor state of repair and could be described as "shabby". I believe, it could be argued, that new fencing and regular maintenance would improve the visual amenity of the proposed site.
The location and appearance have been carefully considered to best hide the existence of the mast for public view, other than from 4 small locations, discussed on page 5,6 and 7. Plus a 50 metre stretch of Woodbourne Lane its self, however the proposed 1.8 m fence would partially obscure the proposed Pole even from this area. It is also felt that the existence of modern LED lighting columns sets a precedence for modern technological development which is out of character for the Conservation area in which it sits.
Planning Application Support Statement Woodbourne Lane ver1.3 {{image:107590}}
Proposed Application site
Should this application be approved, Sure do not intend to submit any further Planning or Preapproval for permitted development applications in the area of Selborne Drive or Woodbourne Road for the foreseeable future. As this Site would fully meet the needs of residents in this area.
The below images are photographic mock-ups of the proposed development. The ground site is only visible from a 50-metre length of Woodbourne Lane, a back lane, from the rear upstairs windows of 8 to 12 Woodbourne Villas and the rear upstairs window of 5 Tennis Road. The pole would be visible from approximately 18 meters of Tennis Road, as shown in picture A. It would also be visible from 8 metres of Selborne Drive at the entrance to Woodbourne Lane, please see picture B. In both these instances you would have to look to your side, away from the likely direction of travel to see the Pole. In the case of Photos C and E only the very top of the structure would be visible, I have highlighted the pole top with a red circle as it is quite difficult to see. It can clearly be seen from the below, that although physically higher than the surrounding structures, it will not dominate the skyline. The map, below, shows the area each photograph was taken from and indicates the size of the area the Pole would be visible from.
Planning Application Support Statement Woodbourne Lane ver1.3
Picture A
Picture B
Picture C
Picture E
The method to produce these Mocked-up photographs of the proposed development was to Park a 15 meter access platform in the proposed location of the Pole. Then eddit the photographs take to show a pole.
The appearance of the proposed pole in the above may seem smaller that expected, this due the releative hights and disances between the objects (buildings, pole) and viewing angles (elevations). If you were to stand 10 m from an 8 m high wall, attempting to view a tower 40 m behind that, it would not be visible. The tower would have to be over 50 m tall to be visible. 20 m from the wall it would still have to be over 35 m in hight to see it. To view a 15 m tower 40 m to the rear of an 8 m high building, you need to be 145 m from the building. In a built-up area, it's very difficult to find a clear line of sight from 145 m away, picture E on page 6 was the only example of this we were able to find.
The Conservation Area Character appraisal goes into some detail about the history of the area and the buildings and street scenes that comprise the key elements to be preserved. The Woodbourne is the main Key structure noted in the Character appraisal, that could be impacted by the proposed development. Given the site chosen for the proposed development it will not be visible from any vantage point including the Woodbourne, and therefore, we feel have no impact on the element of the conservation area. In addition, it would not be possible to view the proposed Pole in conjunction with any element named in the Conservation Character appraisal. We therefore feel that although the proposed development is within a Conservation Area, it will not have detrimental impact on the Conservation Area. The proposed site has been carefully chosen as to have as little impact on the Conservation area as is possible.
The Proposed development will be clearly visible from the rear windows of 5 Tennis Road and 6,7 and 8 Woodbourne Villas, with some indirect views of the development from other properties backing on the proposed site. However, given the general state of disrepair of this area at present, a proposal to fence and maintain the area will greatly improve the overall visual amenity to the residents of surrounding properties enjoy. We feel that this proposal will improve the area, by clearing weeds fencing and maintaining the site. Improving the area in some small way by halting the general decline it is currently subject to.
The proposed installation will not have any impact on the area other than the improvement of Mobile phone coverage. The ground cabinets do have colling fans, these are of such low volume that they can not be heard from 3 meters way. The proposed site will conform with ICNIRP regulations and therefore poses no other known risk to public health.
There has been a level of discussion between Sure and the IOM Planning department, in relation to a mast development in this area.
16/01298/C For temporary car parking which was refused. 20/00257/TEL A pre-approval application for permitted development for Sure IOM. Refused
Sure mobile phone network coverage, in the area round Woodbourne Road is very poor due to the lack of a Sure mast in the area. Without the development of a site in this area there is no prospect of a 5G deployment or even reliable 2G, 3G or 4G services for the residents of this area. In addition, this hole in coverage puts a disproportionate load on the surrounding sites, reducing the performance, available to users of these sites in other areas. A site in this area will improve data services to users served in a wider area from mobile sites at Pulrose, Circular road and Dukes road as it will significantly reduce load on the sites spreading the benefit across Douglas and Onchan. This piece of network infrastructure is critical to the continued good operation of the Sure mobile phone network in Douglas. It should be considered as Critical National infrastructure as it is critical for the continuation of the Sure network in Douglas.
People are becoming more and more reliant on Mobile technology as part of their everyday life. That access to modern telecommunications is now considered a need, in the same way access to water and electricity in considered a need, is now accepted. Sure, customers who live in the conservation areas in this part of Douglas, do not have access to these services because there is no suitable mast for them to connect to. We have been looking for a potential mast site in this area for 12 years, this proposal represents the best technical solution we have yet to find.
As an operator of Critical National Infrastructure we are obliged by our Licence to provide a level of service to the islands residents. Something which we have failed to do in the area around Woodbourne Road, due to the absence of suitable location for a Street works development, with in the Douglas conservations areas. Due to increase in demand we have had to deploy additional Critical National Infrastructure, in the form of a temporary mobile trailer mast on Woodbourne Road, to prevent the collapse of the network in the area. Had this temporary site not be deployed, network congestion through the pandemic would have rendered the Mobile phone network in Douglas, largely unusable. Removing the ability of a significant portion of the population to work from home at this time of national emergency. A site in the area will also significantly improve the ability of residents to access 999 service from within their properties. Something Sure customers in this area where unable to do prior to the deployment of the Temporary Mobile mast at The Masonic hall.
This Proposed site will also reduce the load (congestion) on the adjacent, heavily congested, Sure Mobile sites at Capital House, Circular Road, Pulrose Power station and The Police Headquarters. Dukes Road, significantly improving the service provided to Sure customers though a large part of Douglas. Such has been the impact of the Temporary mast at the Masonic Hall, that if it were now to be removed, without an alternative site being deployed, it would impact the Sure mobile network across the whole of Douglas and Onchan. Severely reducing the network performance for a significant number of customers, to the point of it being practically unusable. Our proposed site in this application will address this critical need.
Statistical analysis of traffic through put, to users of the surrounding sites, shows significant improvement since the activation of the temporary mobile trailer mast on Woodbourne Road. Data speed across Douglas and Onchan have improved from an average of 21 Mbps, the current average of 39 Mbps. This represents a significant improvement in user experience. One that will not continue if planning permission of a permanent site in this area is not granted. It is now our view that should the temporary trailer mast, on Woodbourne Road be removed with no alternative in place, that the Sure Mobile network in Douglas would become severely congested. This would have a major impact on Sure customers though out Douglas and Onchan.
The Isle of Man Government recently launched its Digital Inclusion Strategy 2016-2021. It recognizes the importance of online access and brings together partners in the public, private, and voluntary sectors to help people get online. It is part of the Government's Digital Strategy, which aims to bring more services online and help more people to access them.
The strategy notes the benefits of helping more people to get online including access to training and jobs, social and leisure activities and how it can help to address wider social issues and support economic growth.
Good connectivity is vital to support this strategy and ensuring areas of the island, such as Woodbourne Road, are able to access the latest in mobile technology is therefore key.
The accompanying coverage plots show the significantly improved coverage this proposed site is expected to provide. We anticipate that up to 800 homes will benefit from the improvement in coverage this site would provide.
Planning Application Support Statement Woodbourne Lane ver1.3 Expected coverage should the proposed site be approved (primary within the Red circle) Current coverage in Woodbourne road area As the above shows outdoor coverage is outdoor generally acceptable however indoor is very poor in the target area.
The proposed site is within the Selborne Drive conservation area Douglas; it does not fall within an area of restricted building height due to Air Safety.
This site has been designed in accordance with the current mainland UK Cellular operator's guidance for both Occupational and Public ICNIRP compliance. Our design team is satisfied that this site design complies with the above guidelines and therefore a signed ICNIRP certificate is enclosed with this application.
Page 25 under Communications Commission Aims & Objectives Section: Objective: Social inclusion – to enhance access to services for the whole population:
> "We will enforce universal service obligations by telecoms operators with significant market power. They must provide telephone services throughout the Island."
Page 20, under Communications Commission Aims & Objectives Section: Objective: The built environment – to reduce the visual impact of telecommunications and radio infrastructure on the island's landscape.
> "We will encourage increased mast sharing by broadcasters, under the Radio Masts Regulation Act Limitations."
Page 101: "A balance must 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. Measures which may help to achieve a satisfactory balance will include a presumption against visually intrusive masts in sensitive landscapes, the encouragement of mast sharing by different operators, and the removal of redundant infrastructure. Exceptions to this policy would need to demonstrate a strategic national need, which cannot be otherwise secured by mast sharing or alternative locations."
https://issuu.com/isleofmangovernment/docs/digital_strategy_v0.1?e=17903168/13316277
https://www.gov.im/media/1352205/digital-inclusion-strategy-july-2016.pdf
1.3 "Most people take digital technology and the internet for granted. It is something that has become so deeply embedded in daily life that it is hard to function when access to it is lost." 2.3 "In line with providing more digital services, Government needs to ensure that residents of the Island are equipped with the access, skills, motivation and trust to go online, to help those who want to be digitally capable to make the most of the internet."
Sure IOM Ltd believes the proposed installation complies with the island's policies and strategies above.
To summarise, we consider that this application suggests the optimum location and design for the proposed site.
The current mobile network coverage plots, combined with the number of customer complaints received, demonstrate that there is a definite need for a site in this area to alleviate the extremely poor mobile network coverage in the area. The coverage plots provided in this application show the significant improvement to the customer experience that a site in this location would achieve. This proposed Mobile phone site will perform a critical role within the Islands telecommunications infrastructure and is vital for the continued operation of the Sure Mobile phone network.
The location and appearance have been carefully considered to best hide the existence of the mast for public view, other than from a 50-metre stretch of Lane to the rear of Woodbourne villas and 4 small view areas in the vicinity.
Due to increase in demand there is now a critical need for a Mobile Phone site in this area, with out one the Sure Mobile phone network across the whole of Douglas and Onchan will be servery, negatively impacted. This proposal will not give any improvement to the visual amenity of the conservation area, it will however significantly enhance the lives of not only residents of the conservation area, but those of Douglas residents in general.
Therefore, the design proposed represents both the optimum planning, environmental and technical solutions in this instance. This proposed solution would address the very real need the residents of the Woodbourne Road area, have for access to 21st century telecommunications. As such, we believe the development as proposed is in accordance with Isle of Man Government policy.
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