**Document:** APL Statement
**Application:** 24/00140/B — Redevelopment of an existing Sure Mobile site that will consist of replacing the current lattice tower with a new 15 meter slimline lattice tower with multiple mobile panel antennas & radio kit with associated ground equipment cabinets.
**Decision:** Permitted
**Decision Date:** 2024-04-03
**Parish:** Braddan
**Document Type:** report / planning_statement
**Source:** https://planningportal.im/a/32160-braddan-restart-unit-replacement/documents/1057920

---

# APL Statement

15-meter Lattice Tower FOR Sure (IOM) Ltd AT Sure Site 37 Restart Isle of Man Business Park Douglas Isle of Man IM2 2QZ Planning Application Supporting Statement DATE: 31st January 2024 PREPARED BY: Alex Taylor Sure IOM Ltd

### Sure IOM REF: IOM_37 Restart

## Introduction

In 2006/7 Sure Isle of Man Limited (Sure) was awarded an Isle of Man (IOM) Mobile Operators Licence, issued by the Islands Communications Commission (CURA), to provide a mobile phone network and services to the Islands inhabitants and visitors. This service competes with the incumbent operator (Manx Telecom) and allows greater choice and competition for consumers and businesses.

The Sure Mobile Network is made up of multiple sites around the Island, these mobile sites use radio equipment to provide mobile coverage around the Island, this equipment includes mobile panel antennas, radio equipment and also transmission dishes that we use to link our remote sites back to our core network. All our sites then combined provide all Island coverage for our customers.

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, always keeping visual impact and amenity a priority.

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 Sures 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 Sures services.

For the avoidance of doubt: a mobile site, as referred to in this document, is a combination of equipment including cabinets, antennas, and structures, required to facilitate the operation of a mobile phone network.

## The Proposal

![map or plan from page 3](https://images.planningportal.im/2024/02/7063219.jpg)

The proposed development will consist of replacing the current 12 meter lattice with a 15 meter slimline lattice tower on the existing Sure mobile site located at Restart Court, IOM Business Park.

The proposed 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.

The new structure will also support smaller dishes known as microwave links for the mobile site’s transmission/backhaul back to the Sure core network.

*MIMO, Multiple In Multiple Out, this is a protocol required for higher speeds and high capacity

- 4G/LTE

The current structure is incapable of supporting the newer equipment that is required to support the next generation of mobile technologies, this is due to several factors such as size/weight of new equipment, wind loading on the current structure and also available space on the structure, we would like to increase this to potentially support additional mobile panels and microwave links and also to allow us to mount RRHs on the structure to improve the mobile service in the area.

## The Application Site

The new proposed structure will be built on the existing Sure mobile site. The mobile site is currently situated to the rear of Restart (Argon Building), within the IOM Business Park.

| |
|---|

## Site Selection Process

![photograph from page 4](https://images.planningportal.im/2024/02/7063221.png)

![photograph from page 4](https://images.planningportal.im/2024/02/7063222.png)

![photograph from page 4](https://images.planningportal.im/2024/02/7063223.png)

The proposed development is an upgrade of our existing site, as the existing structure can no longer support newer mobile equipment it will start to impact the network in the local area. The physical structure of the lattice tower is not capable of supporting next generation antenna. The failure to develop this mast will severely impact the ability of Sure to support next generation technologies development in the area.

## Visual Impact

We believe that the visual impact of the proposed new structure will be minimal, we have opted to keep the structure as a lattice tower, this means that it will be difficult to notice a difference between the old and new proposed structure, other than the additional height and the structure itself will be heavier duty to take the additional load we require.

### Current structure

Current Sure lattice tower, we expect very little change to the visual impact from the current structure to new lattice tower.

Examples below of slimline lattices that are currently deployed on a few Sure mobile sites around the Island.

![Street-level photograph showing a two-story commercial building with 'Argon' signage, a parking area with vehicles, and a telecommunications mast visible in the background.](https://images.planningportal.im/2024/02/7063225.jpg)

## Trees (Within 15-meters of proposed development)

![photograph from page 6](https://images.planningportal.im/2024/02/7063230.png)

![photograph from page 6](https://images.planningportal.im/2024/02/7063231.jpg)

There is a total of 5 trees within 15-meters of the proposed development, they appear to be a mixture of Silver Birch and Common Hornbeam, as the tree canopy and root area does not go into the proposed site area, we do not see this development causing a negative impact to these trees.

Pictures below of the trees.

## Equipment Cabinets

The proposed equipment cabinet will be used to house mobile equipment that is required to support the radio equipment that is located on the structure with processing cards and site transmission equipment, there will also be power equipment within the cabinet, this will include battery back up in the event of power outages in the area to ensure the mobile coverage is maintained.

|Number of Cabs|2|
|---|---|
|Cabinet Height|1800mm|
|Cabinet Width|600mm|
|Cabinet Depth|600mm|
|Cabinet Colour|Neutral (options to paint to fit surroundings if deemed appropriate)|

## Antennas

The following antennas have been selected for the new proposed structure, the visual impact of the antennas should be minimal, due to the structure type and the neutral colour of the panel antennas, the antennas can also be painted to suit the surroundings if required.

Antenna Type

2.0m Panel Antenna

Antenna Height

1998mm

Antenna Width

469mm

Antenna Depth

205mm

Antenna Frequency Ranges

690 – 960 MHz 1695 – 2690 Mhz

### * Equipment Cabinets & Antenna sizes/locations and quantities are indicative as the final vendor decision has not yet been made, sizing will be confirmed with planning ahead of installation *

## Need for Site Development

The current Sure mobile site at Restart, IOM Business Park is limited on network enhancements due to the current structure type as the current lightweight lattice cannot be modified to take any additional equipment/load.

Antennas and RRHs (radios) sizes/weights are changing, some are getting wider and also heavier, this will be an issue for us on this site as we will be unable to install this equipment on the current structure as it will exceed the windload limits for the structure, this would massively impact mobile service in the area in the future.

Mobile equipment in the past has been a combination of tower mounted kit (antennas) and ground kit (radio cabinets to house radio cards), as we progress into next generation equipment, the equipment is moving towards being tower mounted (RRHs – Remote Radio Heads), this is to enable improved network performance as the kit being located near the antennas will maximise our MIMO potential from the radio kit, if we do not upgrade the existing structure we would not be able to mount these RRHs near the antennas, thus impacting the level of service we can provide from the site.

The proposed new structure will have significant advantages over the current structure, we will be able to mount the antennas slightly higher on the structure and we will also gain space for potentially installing additional antennas to enable us to optimise network capacity for the surrounding areas, ensuring maximum performance potential is being achieved from the mobile site.

Another advantage will be the structural strength of the new tower, it will be built to support next generation mobile equipment to improve the network capacity and capability in the area, it will also be a climbable structure, this is a major advantage as it allows easy access for Sure RAN Engineers to the equipment mounted on the structure in case of any maintenance or faults on site.

These improvements directly support the Isle of Man Governments ‘Island Plan’ which has a vision of a digitally connected Island, that supports a tech enabled and future ready jurisdiction, the IOM Business Park and surrounding residents will benefit from greater network capacity and service due to these improvements to the Sure mobile site.

Coverage Maps

Health & Safety (ICNIRP)

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.

![map or plan from page 9](https://images.planningportal.im/2024/02/7063235.jpg)

## Telecoms Policies

- 1. Isle of Man Government Statutory Boards, Offices & Agencies Plans 2006-2009. Volume 3.

- a. Page 25 under Communications Commission Aims & Objectives Section: Objective: Social inclusion – to enhance access to services for the whole population:
- b. “We will enforce universal service obligations by telecoms operators with significant market power. They must provide telephone services throughout the Island,”

- 2. Isle of Man Government Statutory Boards< Offices & Agencies Plans 2005-2008. Volume 3

- a. 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.
- b. “We will encourage increased mast sharing by broadcasters, under the Radio Masts Regulation Act Limitations”.

- 3. The Town and Country Planning Act 1999. a. 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.”

- 4. 4) Isle of Man Government Digital Strategy and Digital Inclusion Strategy

### https://issuu.com/isleofmangovernment/docs/digital_strategy_v0.1?e=17903168 /13316277 https://www.gov.im/media/1352205/digital-inclusion-strategy-july-2016.pdf

- 5. 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.”
- 6. 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.

## Summary

To summarise, we consider that this application will offer the best available solution to the enhancement of mobile service on the Sure network in the area.

The current mobile site is in the optimal position to provide coverage to IOM Business Park and surrounding areas, alternative sites would not provide sufficient benefit to justify its development.

Therefore, the design proposed represents both the optimum planning, environmental and technical solutions in this instance. As such, we believe the development as proposed is in accordance with planning guidance as defined above.

## Historic Planning Applications

• Original planning for Sure mobile site at Restart o 13/00329/B Erection of mast and telecommunication equipment/antenna

---

*Data sourced from the Isle of Man public planning register under the [Isle of Man Open Government Licence](https://www.gov.im/about-this-site/open-government-licence/).*
*Canonical page: https://planningportal.im/a/32160-braddan-restart-unit-replacement/documents/1057920*
