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Dear Sirs,
Our Ref : Arqiva/Richmond Hill Temps
Re : Proposed 2No. temporary pump up masts for Cable & Wireless and Cloud 9 Mobile Communications at the Arqiva Richmond Hill Transmitting Station, The Speke, Braddan, Douglas, IOM. PLANNING APPLICATION SUBMISSION.
We are instructed by Arqiva to prepare and lodge on behalf of Cable & Wireless and Cloud 9 Mobile Communications a full planning application for the proposed works at the above site.
Following the telecommunication industry's "10 Commitments" initiative; PPG8; and the Code of Best Practice, a prior consultation letter was dispatched to the Planning & Building Control Directorate dated 16th November 2006 but to date, we have not received any response. We are pleased however to enclose our full planning application for these proposals and to enable you to register and determine the application, we have enclosed the following : -
1.1 Arqiva is an international communications company with a 50 year broadcasting heritage and with origins back to the former Independent Broadcasting Authority [ IBA ]. The IBA was responsible for the administration, development and transmission of all commercial television and radio programmes in the UK and it is as a result of these beginnings that Arqiva now has a large portfolio of masts and towers.
1.2 Arqiva has been a leading provider of wireless infrastructure for business users for more than 20 years. Their customer base includes all major UK broadcasters and wireless telecommunications operators as well as localised network suppliers. Arqiva seek to
| Chartered Town Planning Consultants Telecommunications Specialists | |
| Isle of Man Government Dept. of Local Government & the Environment Planning & Building Control Directorate Planning Section Murray House Mount Havelock Douglas IOM IM1 2SF RECEIVED ON -4 JAN 2007 DEPT. OF LOCAL GOVERNMENT AND THE ENVIRONMENT | 7 Beech Tree Drive Clowne Chesterfield Derbyshire S43 4UJ Mobile : 07779 331991 Tel & Fax : 01246 813923 [email protected] 23rd December 2006 |
provide additional facilities and mast sharing with other users within the telecommunications industry, in accordance with governmental obligations.
1.3
Arqiva are actively engaged in promoting the sharing of their sites throughout the UK for Cellular Telephone, Code Operators and other similar commercial telecommunications applications. They fully endorse the Planning Policy Guidance Note 8 and the Code of Best Practice, particularly the encouragement of the sharing of telecommunication sites and telecommunication structures, thus safeguarding the character and amenities of the locality and negating tower proliferation.
2.1
Telecommunications is a public utility that used to be provided by the Post Office. The decision was taken in the early 1980's to privatise this service and this was enacted through the Telecommunications Act 1984 (the 1984 Act). The operators have been granted licences issued by the Department of Trade and Industry under Section 7 of the 1984 Act. Following the Communications Act 2003, that ended the previous licensing regime, the operators are Electronic Communications Code Network Operators (previously Telecommunications Code Systems Operator).
2.2
The operators have a specific obligation to develop and maintain both second and third generation mobile telecommunications networks across the UK. Under the spectrum licence issued under the Wireless Telegraphy Act, the operator's 3G network must cover 80% of the UK population by 2007 and also be able to meet the reasonable customer demands that may be placed upon. The 3G system is of course broadband and carries voice, text and have high data capabilities that will also enable the transmission and receipt of visual media, including real time video calls.
2.3
The benefits of modern communications, including mobile communications are acknowledged within PPG8 and hence the general policy to facilitate the growth of new and existing systems. Modern mobile telecommunications are also recognised by Government as the fundamental bedrock to the core objective to make sure that the UK is the best place in the world to carry out electronic business. The target date for attainment was 2002, although the Government has not announced whether this core objective has been met. However, it has announced a further core objective, that the UK has the most extensive and competitive broadband market in the G7 by 2007. The 3G networks operate at speeds that fall within the OFCOM definition of broadband and so their development is fundamental to the attainment of this latest objective.
2.4
The range of benefits are not obvious to all and to assist the following public benefits are highlighted by way of examples: -
> Mobile phones can help facilitate modern forms of working, including greater homeworking. This can bring about an improved balance between home and working life. At the same time, it can help minimise private car movements and so help reduce peak period congestion and pollution. This is a particularly important benefit when transport policy to reduce travel and CO² emissions seems to be failing.
> Mobile phones can help minimise unnecessary journeys, so increasing productivity and reducing travel demands.
> Mobile phones can help extend business opportunities into peripheral areas. This important benefit will be considerably enhanced by 3G wireless broadband provision in areas where fixed links will be uneconomic to provide.
> Mobile phones can bring about far greater personal convenience and security, for example, teenagers can keep in parental contact when out in the evening.
2.5 Mobile communications are clearly therefore a public service. A further major benefit is the contribution that such systems make to the attainment of often elusive objectives relating to sustainable development. In view of the statutory duty now placed upon local planning authorities under Section 39 of the Planning and Compulsory Purchase Act 2004, this contribution merits highlighting.
2.6 Having regard to the Government’s four key aims for sustainable development in its strategy: A Better Quality Life, a Strategy for Sustainable Development in the UK, mobile communications will in particular assist in the following ways:
> Modern communications in all their different and emerging forms, including mobile communications, help maintain high and stable levels of economic growth and employment.
> Modern communications, including mobile communications, aid social progress, which recognises the needs of everyone. This manifests itself in a number of ways as illustrated by the following examples:
> Modern communications, including mobile communications, provide effective protection of the environment by helping reduce the need to travel by enabling modern working practices such as greater home working. Such practices reduce the need for travel and can alleviate the pressure for new commercial development such as offices, through more efficient and flexible use of existing accommodation.
> For the same reasons, modern communications, including mobile communications, help ensure the prudent use of natural resources.
2.7 However to make this important contribution to sustainable development objectives and to provide the range of services demanded by the public, mobile networks need to be supported by an infrastructure of base stations. There are now in excess of 50 million
mobile phone customers in the UK and line numbers and usage exceeds that for fixed lines. From a total population of around 56 million, this means almost every young person and adult now has a mobile phone. This assumes the very young and the very old do not and allows for some users who will have more than one line (typically for business and private use or for voice and a dedicated line for data). The majority of the UK population therefore wants to have the benefits of mobile communications. For any mobile customer the most frustrating aspects of the service they receive are dropped calls or no service.
As stated in our pre-application consultations, Arqiva are proposing to replace the existing 10m high monopole at the site with a new 50m high slimline, tapering lattice tower to support new equipment for BBC DAB; Cable & Wireless and Cloud 9 Mobile Communications, as well as the existing Manx Telecom equipment to be transferred from the existing monopole. A formal planning application for this proposal is to be lodged imminently. We are aware that the site previously hosted a 61m high lattice tower and indeed, the foundations for this remain today.
However, Cable & Wireless and Cloud 9 have a more pressing need for equipment at the site and in view of the likely timescales for the receipt of planning approval and then construction of said new tower, a temporary solution for both operators is required. From March 2007 for a 12 month period or until the completion of the new tower, whichever is the sooner, the operators require to provide their services to cover the 200th TT Race meeting and also the usual peak traffic over the tourist season.
The application is supported by technical justification and a coverage plot from Cable & Wireless and also by a coverage plot for Cloud 9.
Accordingly, it is proposed to carry out the following development at the site : -
As mentioned, the temporary masts will be required for a period of 12 months from erection or until such time as the permanent tower replacement is operational, whichever is the sooner. A conditional approval along these lines is of course acceptable.
The existing 10m high monopole supporting equipment for Manx Telecoms would also remain in situ until the replacement was built.
As a community orientated company with an established track record in the broadcast and telecommunications industry, Arqiva is aware of the sensitivity around additional network deployment. Their policy is designed to deliver successful site deployment while addressing local concerns and fulfilling the requirements of the Planning Authorities. The policy has evolved through their wide experience in pursuing the full spectrum of
planning applications and embracing the spirit of the telecommunication industry's '10 Commitments' initiative on community consultation.
4.2 In this respect, the issues surrounding development of the replacement mast and the two temporary pump up masts, in this sensitive landscape is fully appreciated and Arqiva were anxious to ensure that meaningful consultation takes place prior to the submission of this application and indeed, the application for the main redevelopment. Accordingly, a letter dated 16th November 2006 was issued to the Planning & Building Control Directorate. Additionally, a concurrent letter was dispatched to the Braddan Parish Council.
4.3 No responses have been received to these consultations and thus the application has been lodged as originally proposed. Copies of the consultation letters are enclosed.
4.4 If however concerns remain about any aspect of this development, we would welcome an early dialogue with a view to resolving outstanding issues and so not unduly hindering the progress of the application.
5.1 The Braddan Local Plan is we understand, the extant policy document within which applications will be considered. The current plan has been in force since July 1991 but the Draft Braddan Local Plan of April 2001 is perhaps more appropriate, albeit we remain uncertain as to whether this has yet been adopted?
5.2 From this plan, we understand that the site does not lie within any Article 1[5] land but the site is classified as a "Transmitting Station", as defined within Section 5 Industry of the plan.
5.3 This statement does not provide specific policy wording but states at Paragraph 5.3 that, "There are also industries operating within the parish which have been approved or accepted in the past on the grounds of special or particular need to be located in particular locations within the countryside." We understand that the Arqiva Transmitting site is one such 'industry' and that the site is designated as a "Transmitting Station" for the purposes of the local plan.
5.4 Accordingly, we believe that the continuation of use of the site for the said approved purposes is consistent with this plan objective and moreover, that the haring of the site and expansion of the number of operators accommodated, accords with the wider aims and objectives of telecommunications equipment deployment in that it negates tower proliferation and the establishment of new Greenfield sites in the area.
6.1 Access to the site off the A5 and via the existing access track remains unaltered. Traffic generation, once the installations are completed, ought to be negligible and, being new equipment, it is not envisaged to require significant maintenance visits, especially over the temporary period required.
6.2 There will be no new equipment buildings. The design of the temporary pump up masts is wholly functional and choices of alternative designs are not available. The site is of course
allocated as a telecommunications facility and these structures are consistent with the type and form and design of equipment which is expected to be found on such sites.
6.3 We therefore consider that there is little more we can say in this instance regarding design & access of this development but, if the Council do feel that further explanation / detail is need, we would be happy to provide this upon request.
7.1 Arqiva Richmond Hill Transmitting Station has been in existence for many years and at one time, hosted a 61m high tower for which foundations remain in-situ. Notwithstanding the rural and prominent setting, we believe that most local spectators accept the site for what it is and indeed, the local plan has designated the site as a transmitting station. Telecommunications structures in the countryside are now always considered obtrusive even if they are prominent and ironically, the largest of these structures are now attracting heritage interest to the extent that the Arqiva Emley Moor Transmitting Station near Huddersfield in West Yorkshire, a 330m high concrete structure, has now been granted Grade II Listed Building status!
7.2 As stated above, the structure designs are an honest representation of their function and no alternative designs are available. As such, we contend that, as far as possible, the scheme will minimize the impact upon the environment and that no significant or material harm to the immediate locality or the wider landscape will result.
7.3 Need for the systems are clear and of course, the permanent solution will not be in place by the time the next TT race meeting and tourist season is upon us. Arqiva’s Richmond Hill site forms an important part of the islands mobile network for Manx Telecom and the desire is to provide the same services for Cable & Wireless and Cloud 9, for the Douglas region and the principle highway network to and from the port areas.
7.4 There are no alternative sites available in the area to accommodate these structures, especially considering the imminent requirement of the permanent mast and the site is recognised as a preferred telecommunications site. Accordingly, we consider that this scheme represents the optimum, perhaps the only solution available, to deliver the mobile communications services for Cable & Wireless and Cloud 9 both in the short and long term.
We hope that the above supporting information is sufficient for the determination of the application but we are happy to provide additional information and / or meet with officers as appropriate. We would welcome a decision at the earliest possible opportunity, by delegation if at all possible and will do all we can to assist in achieving this.
We look forward to receiving your acknowledgement of safe receipt and the registration details of the application but in the meantime, please do not hesitate to contact the undersigned further as required.
Yours sincerely Ian Hewitt DipURP MRTPI
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