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Mr I Brooks Isle of Man Government Dept. of Local Government & the Environment Planning & Building Control Directorate Planning Section Murray House Mount Havelock Douglas IOM IM1 2SF
18 February 2008
Dear Mr Brooks
Application for Full Planning consent.
Re: Arqiva Richmond Hill Transmitter, Station Richmond Hill, Douglas, Isle of Man
We hereby apply for formal planning consent to install a 20m monopole for Cloud9 and Cable & Wireless and associated ancillary development. The proposal will involve the removal of the two existing temporary masts currently on site which are 21.7m and 16.4m in height respectively.
In accordance with the statutory requirements I enclose an application for full planning consent, a fee in the amount of £53 and copies the following supporting information and drawings: -
As you may be aware from our previous applications for this site, Arqiva is an international communications company with origins back to the Independent Broadcasting Authority (IBA). The IBA was responsible for the administration, development and transmission of all commercial television and radio programmes in
Received 20030 08000586 Town and Country Planning Act 1999 PLANNING and BUILDING CONTROL DIRECTORATE
RECEIVED ON 20 MAR 2008 DEPT OF LOCAL GOVERNMENT AND THE ENVIRONMENT
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the UK and it is as a result of these beginnings, and subsequent acquisitions, that Arqiva now has a large portfolio of masts and towers.
We are actively engaged in promoting the sharing of our sites for electronic communication network operators and other similar commercial applications. Arqiva fully endorses site sharing, which is consistent with local plan polices, in which existing masts and telecommunication sites should be utilised where possible to safeguard the amenities and character of an area, and prevent mast proliferation.
The proposal.
The proposal involves accommodating both Cloud9 and Cable & Wireless on one 20m monopole. The proposal will incorporate the following equipment:
The proposal will also include small equipment cabinets at the base of the mast and ancillary equipment.
Following the original pre-application letter dated 6 December 2008 and our previous discussion with Mr Brooks on the 14 January 2008, we have amended the design to include one 20 metre monopole, as opposed to two monopoles 24.7m and 22.7 metres respectively.
Both Cable and Wireless and Cloud9 have comparable heights to the existing temporary masts currently on site. In fact they have both reduced their base antenna heights by approximately 1.5 metres. This reduction in height combined with the use of a dual use monopole substantially improves the design and appearance.
The intended antennas are designed to be mounted in a compact, slim-line fashion which will minimise the impact of visual intrusion and have been kept to the minimum that will suit the clients' specification requirements.
Following our discussion with Mr Brooks on the 14 January 2008, we understand that Council have a preference for a monopole design over a lattice tower solution; however we have included an alternate design which illustrates a lattice tower design for your comparison.
We have sent pre-consultation letters dated 4 February 2008 to Braddan Parish Council and Manx Natural Heritage and included the attached plans. We are yet to receive a reply to these letters.
The application is supported by coverage plots from Cable \& Wireless and Cloud 9.
In order to find the optimum environmental solution and having regard to the technical requirements, the applicant has carefully applied a sequential assessment of alternative sites. It is evident that the small size of the target coverage area of Cloud 9 and Cable and Wireless limits the choice of appropriate locations and therefore must be considered in conjunction with the site selection process.
In the first instance, the applicant has explored the possibility of locating on existing masts, or telecommunications sites suitable for site sharing. At this stage the site was selected, and the original temporary consent was submitted.
There are no alternative existing sites available in the area to accommodate these structures; accordingly, we consider that this location represents the optimum site to deliver mobile communications services for Cable \& Wireless and Cloud9.
The proposal is subject to the Strategic Plan adopted 1 August 2007. Infrastructure Policy 3, is relevant to the proposal it specifically states: "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".
The strategic plan section 11.9.3 also states that "A Committee which includes representations from all interested parties has been established to co-ordinate the use and development of communication masts and infrastructure. Government Plan 2004/7 includes a proposal to increase mast sharing by operators".
The site is zoned as a transmitter site, it is an existing telecoms site, and our proposal involves locating both Cable and Wireless and Cloud9 on one single monopole. This is clearly consistent with the policy objectives above which encourage mast sharing. In addition the single monopole is a substantial improvement to the existing temporary mast designs.
It is considered that this proposal will not unacceptably harm the character and appearance of the area and will have only a minor visual impact on the locality.
The very nature of telecommunications facilities means there will usually be a degree of visual impact as they generally require a high location that can provide effective signal transmission. It would be incorrect to state that the development will cause no visual impact at all, it is a question of balance between the visual impact and all factors in its favour, including the technical need for mast in this location and lack of appropriate or viable, less harmful alternative options. We accept that there will be a minor degree of visual impact from the proposed mast.
The proposal incorporates a duel user design that reduces mast proliferation through site sharing of infrastructure. The proposal represents a reasonable balance between the need for this development, and amenity considerations.
The site is also subject to Area Plan, however we understand that the Area Plans have yet to be published and the existing adopted Local Plans and the 1982 Order, read in conjunction with the Strategic Plan and any relevant Planning Policy Statements and Planning Circulars will be the policy framework against which planning applications will be determined.
We understand, the extant policy document, is the Isle of Mann Planning Scheme, the Braddan Parish District Local Plan adopted 1991. The site itself is believed to be classified as a "Transmitting Station", as defined within Section 5 Industry of the plan. The surrounding area is zone as open space (agricultural) and designated.
On the subject of RF emissions, you may be aware in 1998 the International Commission on Non-Ionising Radiation Protection (ICNIRP) published guidelines covering exposure to RF radiation which set levels of exposure at about 5 times less than those established by the National Radiation Protection Board (NRPB). These guidelines have been incorporated into a European Council recommendation in 1999, and are also the guidelines referred to in the Stewart report published in May 2000. With regard to our current proposals, please find enclosed a declaration of conformity with the ICNIRP guidelines for public exposure.
It is Arqiva's policy to ensure that on all our sites the total RF emissions from all the antennas on site do not exceed the ICNIRP guidelines for exposure to the general public. We regularly make calculations to determine the worst case emissions from our sites. We also have an ongoing programme of site surveys to ensure that our calculations continue to be conservative. Our measurements continue to show that emissions from Arqiva sites are a small fraction of the ICNIRP guidelines. It is this fact that we consider to be important to our neighbours.
I trust this information is of assistance however, should your require any further details please do not hesitate to contact me on the direct number above.
Yours Faithfully,
Andrew Douglas Senior planning surveyor Arqiva - Site Solutions
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