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Our Ref: GH/Manx/George Hotel
15 August 2012
Director of Planning Planning and Building Control Division Department of Infrastructure Murray House Mount Havelock Douglas ISLE OF MAN IM1 2SF
Dear Sir or Madam,
MONO CONSULTANTS LIMITED 48 ST VINCENT STREET GLASGOW G2 5TS t: 44 (0)141 566 6660 f: 44 (0)141 566 6661 www.monoconsultants.com
Please find attached an application for planning permission and registered building consent on behalf of Manx Telecom. The proposal involves the removal of the existing microcell antenna and the installation of 2No face mounted antennas onto the chimney of the George Hotel, The Parade, Castletown. The proposal also involves the installation of wall mounted equipment cabinets in the basement of the hotel and ancillary development. The proposed antennas and supporting steelwork would be painted to match the background on which it is mounted.
The application comprises:
We trust that the information contained is sufficient for you to determine the applications, however please do not hesitate to contact me if you require any additional information.
Yours faithfully,
Ginny Hall MRTPI
Direct Dial: 0141 270 2733 Mobile: 07796 995 843 E-mail: [email protected]
(For and on Behalf of Manx Telecom)
REGISTERED IN SCENE AND NO VILLAGE REGISTERED OFFICE AS OF VINCENT STREET GLASGOW G2 5TS
| Copy of Developer's Notice enclosed? | Yes | No |
| Date served: n/a |
RECEIVED 04 16 AUG 2023 PHILIP MORRIS U.S.A. PURCHASING DEPT.
Airport Director Consultation (only required for an application for prior approval) {{table:409115}} Developer's Notice {{table:409116}}
The proposed site:
The proposed site is George Hotel which is a 3 storey Registered Building located in the Castletown Conservation Area. The George Hotel is an established location for telecommunications equipment and accommodates an existing Manx Telecom microcell antenna on the front elevation of the chimney.
Type of Structure:
Description:
The proposal involves the removal of the existing microcell antenna and the installation of 2No face mounted antennas onto the chimney of the George Hotel, The Parade, Castletown. The proposal also involves the installation of wall mounted equipment cabinets in the basement of the hotel and ancillary development. The proposed antennas and supporting steelwork would be painted to match the background on which it is mounted.
Reasons for choice of design:
A thorough search of the central Castletown area was undertaken to find a suitable location for the installation of telecommunications equipment to meet the demand for improved 3G coverage in the central and southern areas of the town. The George Hotel was considered to be the best option available in terms of the level of coverage provided and minimising impact on the character and appearance of the area and it is an existing and established location for telecommunications equipment. Given that the George Hotel is a Registered Building within the Castletown Conservation Area it is accepted that telecommunications equipment will need to be designed in a way which is sensitive to the character and visual amenity of the building and surrounding area. The proposal, which is subject of this application, involves the installation of antennas onto the front and rear elevations of the chimney of the George Hotel in addition to some internal equipment cabinets within the basement of the building. The proposed antennas and supporting steelwork would be painted to match the building fabric on which they are mounted in order to minimise visual contrast when viewed from the surrounding area. The use of face mounted antennas onto the chimney of the building ensures that the equipment would not protrude above the roof of the building, thereby minimising impact on the shape and appearance of the building when viewed from the surrounding Conservation Area.
| Reason(s) why site required e.g. coverage, upgrade, capacity (map attached if required): |
| In order to improve the level of service that Manx Telecom provides for their customers, they are constantly developing their network, as well as refining and modernising their equipment. The dynamic nature of technological advances in the telecommunications industry, coupled with the demands from subscribers to provide new and better quality services, dictates a continual reinvestment programme in the infrastructure behind the use of mobile devices. Manx Telecom are currently involved in developing new sites to provide coverage to areas which have not benefited from access to the full services they offer and to areas of their existing network where increased capacity or improved service quality is required to meet demand. |
| Many more people now use mobile devices for personal and business purposes and to a large proportion of the population, the use of a mobile phone is now considered an essential part of everyday life, both at work and in their leisure time. These customers legitimately demand and expect to have adequate signal coverage and capacity for their mobile devices throughout the island. |
| However it remains the case in some areas and at particular times of the day, capacity on the Manx Telecom network may not keep up with demand, creating network congestion, poor download speeds and service disconnections. Combating these technical deficiencies is at the forefront of the origins of a new cell instruction. |
| Although the main functionality of mobile phones to support voice calls and messaging remains at its core, in recent years the emergence of smart phones and high-spec wireless devices has put added pressures on Manx Telecom's network as customers demand reliable data streaming and coverage capacity. The increasing ownership of smart phones is driving significant increases in the number of people accessing the internet on mobile phone networks, creating the emergence and growth of the 'pocket internet'. |
| In this respect many consumers have commented that typical mobile speeds are insufficient for the use of data-hungry mobile devices seeking to download music, video content and applications. Internet-based communications services such as social networking sites and instant messaging has put added pressure on mobile phone networks as the growth in the average time spent online can be attributed to the use of the internet becoming more mainstream and accessible via mobile devices. Improved in-building coverage and capacity is a |
| ICNIRP Declaration attached | Yes | No |
| ICNIRP public compliance is determined by mathematical calculation and implemented by careful location of antennas, access restrictions and/or barriers and signage as necessary. Members of the public cannot unknowingly enter areas close to the antennas where exposure may exceed the relevant guidelines. When determining compliance the emissions from all mobile phone network operators on the site are taken into account. |
| Frequency: | 3G (TX) - 2110.3-2120.3Mhz 2G (TX) - 946-959.8Mhz GMSK |
| Modulation characteristics² | 3G: QPSK + 16 QAM 2G: GMSK |
| Power output (expressed in EIRP in dBW per carrier) | Antenna A1 - 3G: 58.5, 2G: 56 Antenna A2 - 3G: 55 |
| Height to underside of antennas (m above ground level) | 11 metres |
² The modulation method employed in GSM is GMSK (Gaussian Minimum Shift Keying) which is a form of Phase modulation The modulation method employed in UMTS is QPSK (Quad Phase Shift Keying) which is another form of Phase Modulation
key objective of Manx Telecom's 3G network rollout. It is emphasised that the only reason Manx Telecom seeks to place a base station anywhere is to improve the service to its customers and planning authorities should not question the need for a proposed telecommunications development. Indeed it would not be financially viable for Manx Telecom to develop their existing networks further and invest time and monies into any particular case, if there was no demand for the mobile phone service it seeks to provide. Any new telecommunications base station should be seen as an important economic driver which is a material planning consideration.
The proposed site at the George Hotel is required in order to provide high quality 3G coverage to the streets and buildings in the central and southern Castletown area. The enclosed coverage plot entitled 'Composite UMTS Coverage without George Hotel' shows that central and southern areas of Castletown have a lack of high quality 3G coverage. The plot illustrates that some areas in central Castletown (unshaded areas on the coverage plots) do not benefit from any 3G coverage while much of the town centre is shared in red and yellow colours which illustrate a low level of 3G coverage which would not be accessible inside buildings. This coverage deficiency means that customers may have difficulties gaining access to the full services available through the Manx Telecom 3G network when they are indoors. The coverage plot entitled 'Composite UMTS Coverage with George Hotel' illustrates the level of 3G coverage which would result from the existing Manx Telecom sites in the Castletown area, in addition to the proposed site at the George Hotel. This clearly illustrates that the proposed installation at the George Hotel will ensure that the central and southern areas of Castletown will benefit from an 'in-building' level of 3G Manx Telecom coverage.
The specific coverage requirement in this area of central Castletown means that the search area where a site would be operationally viable is very limited. There are two existing Manx Telecom base stations in the vicinity of Castletown (one at the nearby airport and one at the football ground to the north of the town). The coverage from these two sites is not sufficient to provide high quality in-building 3G coverage in central Castletown. On that basis, a new site is required in the central area of Castletown to provide a continuous level of in-building 3G coverage to Manx Telecom customers in the area.
The following table provides details of alternative sites that were considered and discounted prior to progressing with the site which is subject of this application (the locations are plotted on the aerial photo below):
| Map <br> Ref: | Site Location | Reasons for discounting in terms of planning, acquisition and <br> coverage |
|---|
1 2
3
3
4
Shoprite Arbory Street Castletown
Existing Communications mast at Fire Station Farrants Way Castletown Existing lighting column Farrants Way Castletown Old Canada Life Office Castletown Square Castletown
The Fire Service is unwilling to accommodate telecommunications equipment for Manx Telecom at this location. This option has therefore been discounted as Manx Telecom does not have the owner's permission to use the property.
The possibility of installing telecommunications equipment onto an existing lighting column on Farrants Way was considered but subsequently discounted because the antennas would not have sufficient height to gain coverage over surrounding building clutter. This option was therefore discounted as it would not meet the coverage requirement in Castletown Square.
This building was surveyed with the intention of installing telecommunications antennas onto the tallest section of the building. This survey demonstrated that the tower section of the building was not structurally suitable to accommodate telecommunications equipment and it was therefore discounted.
The following aerial photo shows the location of the alternative sites that have been discounted in relation to the search area which is shown as a red circle.
Additional relevant information:
Isle of Man Strategic Plan (Adopted 2007) It is recognised by many that telecommunication networks are a core infrastructure asset for any modern economy and the Isle of Man Government need to plan positively for their installation and long term use.
Infrastructure Policy 3 of the Isle of Man Strategic Plan (Adopted 2007) deals specifically with communications systems and 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 shaning 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.
In accordance with Infrastructure Policy 3, an additional base station is required in central Castletown in order to satisfy the residential and business demand for high quality in-building 3G coverage. A thorough search of the area has shown that there are no existing telecommunications sites within the search area which would meet the coverage demand in the central Castletown area. While the existing communications mast at the Fire Station was identified, the Fire Service is unwilling to allow Manx Telecom to install equipment at this location.
The proposal which is subject of this application involves the installation of small scale, face mounted telecommunications equipment onto the chimney of the George Hotel, thereby negating the need for a ground based mast. The George Hotel is an existing and established location for telecommunications equipment in Castletown however, the existing microcell antenna is not sufficient to meet the demand for 3G coverage in the surrounding area. While the proposal which is subject of this application is only for Manx Telecom, the possibility of installing additional telecommunications equipment for another operator could be considered on a case by case basis. Given the Registered status of the building and the location within a Conservation Area, any equipment by additional operators would need to be sensitively designed in order to ensure that impact on the character and appearance of the building is minimised. It is considered that the sensitive design which is proposed at the George Hotel, along with the importance of providing improved mobile communications coverage to the surrounding area, ensures that a good balance is struck between the need for evolving communications systems and minimising impact on the environment. In accordance with Infrastructure Policy 3, we can confirm that Manx Telecom would remove any equipment that becomes redundant in the future.
Environment Policy 32 from the Isle of Man Strategic Plan relates to development affecting Registered Buildings and states that:
"Extensions or alterations to a Registered Building which would affect detrimentally its character as a building or special architectural or historic interest will not be permitted."
Environment Policy 35 of the Isle of Man Strategic Plan deals with development within Conservation Areas and states:
"Within Conservation Areas, the Department will permit only development which would preserve or enhance the character or appearance of the Area, and will ensure that the special features contributing to the character and quality are protected against inappropriate development."
The proposed installation of telecommunications equipment at the George Hotel complies with Environment Policies 32 and 35 of the Strategic Plan as it will not result in any detrimental impact on the character of the building, or on the architectural or historic interest of the building. While the proposal will result in some minor additions to the front and rear elevations of the chimney of the hotel, the sensitive siting and colouring of the equipment will ensure that the impact on the character and appearance of the building and surrounding Conservation Area will be minimal. While it would be difficult to argue that the installation would 'enhance' the Conservation Area, it is considered that the installation will 'preserve' the character and appearance of the area.
Overall, it is considered that the proposal complies with relevant policies in the Isle of Man Strategic Plan.
Policy and Guidance Notes for the Conservation of the Historic Environment of the Isle of Man
Special attention has been paid to the desirability of preserving the Registered Building, its setting and any features of special architectural or historic interest which it possesses. Particular regard has been had to the historic and special architectural importance of the building and particular physical features of the building that justify its designation as a listed building.
The Introduction of the Policy and Guidance Notes states:
"Above all Conservation means ensuring that, to the fullest possible extent, our built heritage remains in active use as an integral part of the living and working community, as a material asset that makes a positive contribution to economic prosperity and the overall quality of life which we enjoy on the Island."
In accordance with the above aim, the proposed installation on the George Hotel will meet the demands of modern day communications requirements in the area which in turn makes a positive contribution to economic prosperity and quality of life.
Policy RB/5 relates to Alterations to Registered Buildings and states:
"In considering whether to grant planning approval for development which affects a registered building or its setting and in considering whether to grant registered building consent for any works, the Department shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which is possesses."
It is considered that the proposal which is subject of this application would have a neutral impact on the setting and appearance of the Registered Building due to the sensitive siting and design of the proposed equipment on the chimney. The proposal involves the installation of equipment onto the building and does not involve the permanent removal or alteration of any features of special architectural or historic interest. The proposal ensures that the heritage asset of the Registered Building is preserved while also providing the wider benefit of meeting the demand for high quality 3G coverage in the surrounding area.
As detailed in the Code of Best Practice, the options available to operators can be affected by site conditions, technical constraints, landscape features and capacity requirements. The main options available are mast/site sharing, installations on existing buildings and structures, camouflaging equipment, using small scale equipment and erecting new ground based masts.
The search identified two existing telecommunications sites in the area. The Fire Station site was discounted because the owners were unwilling to accommodate Manx Telecom equipment. The George Hotel was also identified as an existing telecommunications site as it currently accommodates a microcell antenna and ancillary equipment for Manx Telecom. While the existing telecommunications equipment at the George Hotel is not sufficient to meet the surrounding coverage demand, it was identified as a location where an upgrade of equipment could be undertaken in order to meet the coverage demand in the target area. Given the sensitive nature of the site, Manx Telecom is proposing to use small scale antennas which would be coloured to match the building in order to minimise visual contrast.
Paragraph 135 of the Code of Best Practice highlights that the visual impact of installing telecommunications equipment onto buildings can be reduced by painting the equipment to match the background on which it is attached, keep in proportion to the building, respect architectural style, have minimal impact above the roofline and avoid creating clutter on the building. In accordance with that advice, the proposed antennas on the George Hotel have been selected in order to fit onto the existing chimney without dominating the building and its architectural features and avoiding any impact on the roofline. In addition, the equipment would be painted to match the background on which it is mounted.
The issue of health and safety concerns regarding telecommunications apparatus has been the subject of recent media coverage within the UK. As you may be aware, an Independent Expert Group on Mobile Phones (IEGMP) undertook thorough and in-going research with regard to the health effects of phones and base stations. The research found that:
Court cases and appeals in the UK have established that health concerns are not a sufficient basis alone for withholding planning permission, notwithstanding any view the Authority may have adopted about current research in this field, providing it has been demonstrated that the proposed installation will comply with the ICNIRP guidelines.
The proposal, which is the subject of this application, is designed to be ICNIRP compliant as demonstrated by the ICNIRP certificate included with this application.
| Name: (Agent) | Mono Consultants Limited | Telephone: | 0141 270 2733 |
| Operator: | Manx Telecom Limited | Fax no: | 0141 566 6661 |
| Address: | Mono Consultants Limited 48 St Vincent St Glasgow G2 5TS | Email: | [email protected] |
| Signed: | Mono Consultants Limited | Date: | 15 August 2012 |
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