DEC Officer Report

PLANNING OFFICER REPORT AND RECOMMENDATION

Application No.: 24/00129/B Applicant: Sure (Isle Of Man) Ltd Proposal: Redevelopment of an existing Sure Mobile site that will consist of replacing the current monopole with a new 15 meter slimline lattice with multiple mobile panel antennas/dishes/radio kit with associated ground equipment cabinets and boundary fence. Site Address: Sure Site IOM 04 Ballakissack School Lane Santon Isle Of Man IM4 1EG Senior Planning Officer: Mr Jason Singleton Site Visit: 28.02.2024 Expected Decision Level: Officer Delegation Recommended Decision: Permitted Date of Recommendation: 11.03.2024

Conditions and Notes for Approval

C : Conditions for approval N : Notes attached to conditions

• C 1. The development hereby approved shall be begun before the expiration of four years from the date of this decision notice.

Reason: To comply with Article 26 of the Town and Country Planning (Development Procedure) Order 2019 and to avoid the accumulation of unimplemented planning approvals.

• C 2. Unless otherwise approved in writing by the Department, any telecommunications cabinet, mounted equipment or telecommunications structure must be removed from the land on which it is situated, within 6 months of it no longer being required for telecommunications purposes, and such land must be restored to its condition before the development took place, so far as is practicable.

Reason: To ensure that any redundant infrastructure is removed and to comply with Strategic Plan Infrastructure Policy 3.

• C 3. The development hereby approved shall not commence until further details of the antennas, dishes and remote radio heads to be installed have been submitted to and approved in writing by the Department. The development shall not be carried out unless in accordance with the approved details and shall be retained as such thereafter unless a variation or

alteration is permitted under Schedule 2 of the Town and Country Planning (Telecommunications) Development Order 2019 (or any alteration/replacement of that order).

Reason: To ensure appropriate use of the mast for telecommunication equipment.

• C 4. Notwithstanding the provisions of the Town and Country Planning (Permitted Development) Order 2012 (or any amendment or replacement of that order) no fencing, walling or gates shall be erected at the site other than as shown on the approved plans shall be erected.

Reason: to ensure the development is carried out in accordance with the approved plans in the interests of the visual amenity of the area.

• C 5. The proposed 15m slim line lattice tower and the 1.25m high post and rail fence shall be painted dark green and maintained and retained in perpetuity. Reason; To be in keeping with a rural area.
• C 6. No development shall be commenced on site until a planting scheme has been first submitted to and approved in writing by the Department showing details of existing and proposed type of native trees and bushes to bolster the existing levels of planting to those areas of open parts of the site, and a programme of implementation. All planting shall be carried out in accordance with the approved details.

Reason: In the interests of the wooded appearance of the development and the surrounding area.

• C 7. The proposed telecoms mast and affixed communication equipment here by approved shall be no higher than the stated 15m when measured from the concrete base as shown on plan referenced; IoM_04/014-A REASON To ensure the mast height is installed in accordance with the approved plans
• C 8. The proposed antennas, dishes and RRU shall be coloured to match the slimline lattice mast to which they are affixed and retained in perpetuity. REASON: To mitigate any visual impact.
• C 9. The temporary work area / fencing as shown on the drawing entitled, "Temporary Work Area" shall be removed from the site within 2 weeks of the new mast being brought into use.

Reason: to prevent the retention on site of temporary works which would be detrimental to the visual amenity of the area.

This application has been recommended for approval for the following reason.

The proposed application is not considered to harm the use and enjoyment of neighbouring properties nor would it result in any adverse impact upon the countryside and would comply with Spatial Policy 5, General Policy 2, 3, Environmental Policy 1, 22; and Infrastructure Policy 3 of the Isle of Man Strategic Plan 2016.

Plans/Drawings/Information; This decision relates to drawings and supporting information received on 7th February 2024, referenced;

• IoM_04/010 A - Location Plan
• IoM_04/011 A- Site Plan
• IoM_04/012 A Existing Elevations

• IoM_04/013 A Proposed Elevations IoM_15/015 A Temp work area _______________________________________________________________

Interested Person Status

Additional Persons None _____________________________________________________________________________ Officer’s Report THE SITE

1.1 The application site is a small parcel of land identified in red that sits within the wider agricultural field of 514508 (17.08 Acres). The site sits predominately to the northwest corner of the field and adjacent to the northern boundary / hedgerow and is accessed from a farm track from Ballakisack School Lane to the south and through Ballakissack Farm. The site is also adjacent to a PROW 233 which links School Lane to the Moaney Road. - 1.2 The site currently contains a concrete hardstanding that is fenced off with a timber post and rail fence with a 13m monopole and two associated communications and electrical cabinets. This site is used by Sure Mobile who is also the applicant. - 1.3 Across the width of field 514508 from East to west are a series of wooden telegraph poles with three runs of suspended electrical cables. - 1.4 To the north of the site (approximately 11m) is a Manx telecom monopole mast at a height of 12.5m. THE PROPOSAL

2.1 Planning permission is being sought for the replacement of the current 13m high monopole and the installation of a new 15 meter high slim line lattice tower on the existing concrete slab foundation. The tower would be a triangular shape consisting of three columns with supporting bracing forming the overall structure with a plain grey colour of the manufacturer's galvanised finish. - 2.2 Mounted to the lattice tower would be: 3x panel antennas; 6xRRU (Remote Radio Units) and 3x MicroWave links with associated ground equipment cabinets and two equipment cabinets (0.6mx0.6mx1.8m) on the existing concrete base. None of the equipment would be higher than the top of the 15m lattice tower. - 2.3 At present the specification of the 'antennas' and 'RRU's' specification are not known but the agents confirm; "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". - 2.4 The proposed works would be enclosed within a new fenced off area with 1.25m high wooden post and rail fencing that would measures a footprint of 5.6m x 3.6m and would make use of the existing foundation. - 2.5 The applicant notes; " 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. The proposed structure will also support smaller dishes known as microwave links used as transmission links for the site back to the Sure core network, the proposed design includes 3 microwave links…The current structure is incapable of supporting the next generation of mobile technologies, this is due to the current structure

• failing the wind loading assessment that we have had carried out based on the new equipment specifications, as equipment is getting heavier in some cases and it is also moving to tower mounted kit, rather than being in radio cabinets at the base of the structure".
• 2.6 The application has been submitted by one of the Island's licensed operators (Sure Mobile) and is accompanied by a certificate of compliance with the World Health Organisation's ICNIRP guidelines for public exposure. (ICNIRP - "International Commission on Non-Ionising Radiation").
• 2.7 As part of the proposal, the applicants intend to erect a temporary 8m high mast with 3 panel antennas and dishes on a trailer while the existing site is decommissioned, removed and the new installation undertaken. This mobile telecoms trailer will feature all the equipment cabinets to operate and will not require any hardstanding or excavation works to install. Equally it will be fenced off with Harras fencing. The proposed location of this is to the immediate south of the existing site. PLANNING HISTORY

3.1 06/02107/B - Installation of a 12.85m high monopole mast with associated equipment cabinets. Approved. - 3.2 Adjacent to the site is another telecom monopole from a different mobile provider ref; 00/00992/B - Creation of mobile telecommunications site including 11m monopole. Approved.

PLANNING POLICY LOCAL PLAN

4.1 The application site is identified on the Area Plan for the East on;

• Map 2 (Landscape Assessment) as D13 Incised Slopes.
• Map 3 (Proposals) as rural or agricultural land / land not zoned for development.

4.2 Within the written statement accompanying the Area Plan, telecoms are noted at;

• o Para 7.4 iv. To provide and support the best quality telecommunications networks and to support the economy by doing so.
• o Utilities Proposals 3 (in part) - The telecommunications system must be designed in accordance with the requirements of the relevant telecommunications servicing agency and should be consistent with any approved strategy, policy or plan for the provision of advanced telecommunications infrastructure, including fibre optic technology. It is expected and required that all new development be connected at the best standard possible.
• o Telecommunications Proposal 1 New developments should:

• a) Make provision for fibre optic cables directly to each dwelling or commercial premises.
• b) Within Comprehensive Treatment Areas (see Chapter 13), be phased so as to ensure that telecommunications structures are installed efficiently and will avoid ongoing disruption to site foundations.
• c) Design facilities so as to be able to host equipment from more than one operator, and that such sharing be encouraged.
• d) Demonstrate that the proposal has taken into account radio networks in particular those used by the emergency services (TETRA).

4.3 Furthermore, the site is noted in TAPE written statement for;

• o Landscape Character Area Santon (D13) generally refers to the overall protection of the countryside, its rural character, quality of such and distinctiveness.
• o Landscape Proposal 7 (Santon)

In cases where new development is proposed, applications must demonstrate that it can be suitably integrated into the surrounding landscape setting through reasonable mitigation measures and considering siting, colours, materials, finishes and the general scale.

4.4 The site is not within a Conservation Area nor is it identified as being in an area at risk of flooding from surface water, river or tidal. There are no registered trees or registered tree groups boarding the site. STRATEGIC PLAN - 4.5 The following policies from the 2016 Strategic Plan are considered pertinent in the assessment of this application; Strategic Policy

• 1 Development should make the best use of resources (c)

Spatial Policy 4 Hierarchy of defined settlements for development (Newtown) 5 New development will be located within defined settlement.

General Policy

• 2 General Development Considerations (b,c,g)
• 3 Exceptions to development in the countryside (e)

Environment Policy 1 Protection of the countryside 22 (iii) Safeguarding the environment and/or the amenities of surrounding properties Infrastructure Policy 3 Need for communications infrastructure versus environmental impacts The text preceding Infrastructure Policy 3 is an important consideration where it states in paragraph 11.9.2;

• o "The maintenance and improvement of these systems is likely to require the provision
• of new infrastructure; infrastructure required by private telecommunications operators is likely to be more extensive. It is important that a balance 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. New communications development should be in accordance with the provisions of this plan".

OTHER MATERIAL CONSIDERATIONS;

4.6 The Isle of Man government has an overarching series of strategies and policies that are considered materially relevant to the assessment of this application. This includes the Isle of Man Government Climate Change Plan 2022-2027; which promotes a more sustainable approach to living and working, one of which is remote working. - 4.7 National Telecommunications Strategy 2018 "The National Telecoms strategy, laid out in six themes, looks to set a direction of travel by which the Island's telecom infrastructure can be recognised as being world class. The Government has made it clear that enhanced telecoms infrastructure is a top priority… The benefits will be available to all our residents and businesses on the Island and will underpin and support economic growth". This document talks broadly about telecoms on Island but geared more towards fibre broadband. - 4.8 IoM Economic Strategy November 2022; Our big Picture Evidence base report phase 1 - December 2021; Para 4.9 (page 147) "Analysis suggest that the overall quality of internet connectivity of the Island is not keeping

pace with competitor jurisdictions, such as Jersey and there has been a decline in satisfaction regarding the quality of telecommunication services".

REPRESENTATIONS (this report only contain summaries - full reps can be read online)

5.1 Santon Parish Commissioners had not commented at the time of writing despite being consulted on 08/02/24. - 5.2 Highways Services do not object (23/02/24) ASSESSMENT

6.1 The main issues to consider in the assessment of this planning application are as follows:

• - Principle of development (STP1,SP4, SP5, IP3)
• - Location of the proposal (GP3),
• - Design and visual impact (GP2 b, c, EP1)
• - Impact upon residential amenity (GP2 g and EP22)
• - Other matters PRINCIPLE

6.1 The application is submitted by Sure Mobile, essentially to improve the available mobile coverage in the rural parish of Santon and the immediate residential area of Newtown and Mount Murray (both identified as Predominately Residential on Map 11). The principle would loosely be seen to assist with compliance to Sp4 as Newtown is a named village and could assist with remote employment workings. Stp1 is adhered to as the applicants are utilising a previous telecoms site and the existing infrastructure and facilities in this area. - 6.2 The proposed installation will have the capabilities to address both indoor and outdoor coverage demands within the surrounding area, whilst significantly increasing the level of coverage within the Santon Parish area as demonstrated as part of the submission. The proposals also reflects the investment and modernisation of communications equipment on site which is sought as part of the overall Island Economic Strategy and those supporting policies within the TAPE written assessment. - 6.3 In favour of the proposals is Infrastructure Policy 3 and its supporting text which advises that the maintenance and improvement of the Island's telecommunications systems will necessitate a balance to be struck between the need for new and evolving communications systems, particularly to satisfy the needs of residential and business demand, and the impact of such required development upon the environment. - 6.4 The principle of development also further receives support from the Climate Change Plan 2022-2027 through improved network infrastructure that would allow for increased levels of home/remote working within the wider residential area. The residential catchment here is an important consideration, particularly given the Government's strategy for remote workings and the agent notes; "Good connectivity is vital to support this strategy and ensuring that areas of the island, such as a Santon, have high-capacity reliable mobile services to access the latest in technology is therefore key". - 6.5 The "need" for the improvement of telecommunication equipment can be substantiated in this instance given the existing telecoms infrastructure located in the immediate vicinity and this proposal seeks to enhance this through the investment with new technology and consolidate the equipment to one new mast that would work towards compliance with IP3. LOCATION - 6.6 The site sits outside (south east) of the defined residential settlement boundary of Newtown, so technically could be contrary to SP4. However the proposals are to serve those identified villages and adjoining rural areas. There is allowance in Sp5 for development outside of those identified settlements that are within the countryside that cross references to GP3e for: "location dependant development in connection with working of minerals or the provision

• of necessary services", an emphasis on necessary services here would be the policy route to follow.
• 6.7 As an exception can be found under GP3e and cross referencing with IP3 to ensure there is no visually intrusive masts in sensitive landscapes, and while EP1 seek to protect the countryside and its ecology for its own sake. As such the proposals would conform to Sp5 and GP3e with the main focus of this application being on the visual impact of the proposals on the rural landscape over and above the existing 15m high lattice tower. DESIGN AND VISUAL IMPACT
• 6.8 General policy 2 ensures any visual impact is considered and equally Environmental Policy 1 ensure there is no adverse visual harm to the wider countryside, especially given a mast at 15m could be visible from afar and in particularly from the A5 (Douglas to Castletown) highway. The specific siting of the proposed mast and its antennas, essentially the upper proportions could be visible on the landscape from afar but needs careful consideration to ascertain whether this would be more detrimental than the current situation, noting the existing adjacent (Manx) telecom mast to the west of the site and the High Voltage electric cabling to the south.
• 6.9 The opening sentence of Infrastructure Policy 3 is helpful when balancing the need and any visual impact, where it notes: "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." IP3 also encourages mast sharing, as there is no other network mast in this vicinity, it would not be possible, and a balance needs to be struck to ensure there is no visually intrusive masts in sensitive landscapes.
• 6.10 The agents have noted in their supporting statement; "the replacement structure will be less visually intrusive than the current structure due to the fact that it will no longer be a solid structure, but rather one that you can essentially look through, helping it blend in with the surroundings"… The proposed structure would have a slight increase in the height, going from 13-meters up to 15-meters, this will be an advantage on the site as it will improve the coverage footprint in the surround areas due to the ability to mount the antennas higher, the proposed structure will also provide the required space needed to mount the RRHs (radios) adjacent to the antennas, something that we would struggle with on the current monopole".
• 6.11 When viewing the site from the Main road A5, (nearest highway) it was noted there are only fleeting views of the general area (from the highway to the east) where the existing masts are placed and given the topography in the area with the site being higher than the road and the built forms along the length of the highway, those views are limited and more akin to sporadic views. It was also noted the size and scale of the existing masts onsite and the dominant presence of the wooden telegraph poles with their cabling that are present in the same field and throughout the wider landscape setting (serving those rural residential properties) and also cross over the highway (A5) adjacent to Rose Cottage. The same can be said when viewed from Moaney Road (second nearest highway) to the north of the site.
• 6.12 When viewed from the PROW, the proposed mast, of galvanised steel, would have a slim line and simplistic appearance, with the lattice style offering a degree of transparency when viewed in the context of the skyline. The communications equipment attached, would be no higher than the top of the pole (15m) and can be conditioned as such. The proposal would be visible, and not forgetting most of the mast would be affixed with various equipment (multiple mobile panel antennas/dishes/radio kit) towards the upper proportions, which would certainly be seen from nearby and also further afield. However in the overall context this would not be seen as an incongruous feature on the landscape and would seek to comply with Ep1 where the proposals would not adversely affect the countryside.

6.13 In terms of visual impact the finish of the equipment and mast here is an important consideration as it was proposed to be untreated colour of galvanised steel / grey that would be read against the skyline. It is important that any communications equipment and antenna is colour coded to match the mast to mitigate any visual impact and they are all read as one unified colour. This can be secured through an appropriate worded condition to help reduce the visual impact of the mast and equipment, whilst providing sufficient signal strength for customers to take advantage of a range of Sures' services. In terms of colour it was discussed with the applicants that a green or brown colour would be preferable as the backdrop here when viewed from public vantage points, would be read against the countryside when viewed from afar. - 6.14 With regard to the associated cabinets their visual impact would be negligible and would not be seen as in conflict with policy leading to an adverse visual impact, over and above given the levels of existing development on the wider site and would be read in the same context as the mast. - 6.15 On balance, the benefits of providing the required equipment to increase network coverage are considered to outweigh the limited visual harm resulting from the development, particularly in the context of the Government's ambition to improve public infrastructure and promote remote/home working as part of the Government's plan to achieve net zero status for the Island by 2050. - 6.16 On this basis, it is considered that the proposal would not create any additional visual harm or intrusion into the site and surrounding rural area and would conform to those parts of Strategic Policy 1, General Policy 2(b,c) and Infrastructure Policy 3. RESIDENTIAL AMENITY - 6.17 In terms of the nearest residential properties, the site is located approx. 370m to Rose Cottage (East of the site); 400m to Lower Ballagick (North West); 320m to Ballakissack Farm which ensures that their residential amenities would not be materially affected through any loss of light, overbearing impact or loss of privacy and as a result of the proposals. Whilst noted above there will be views of the proposals from dwelling houses, this would be a view and the loss of a view or interruption of a view is not a material planning consideration, despite their being no objection to the proposals. The development is therefore compliant with General Policy 2(g) and Environmental Policy 22. OTHER MATTERS - 6.18 In terms of health issues associated with a telecommunication mast and the proximity to residential dwellings, the Isle of Man has no specific guidelines in how to deal with such concerns. However, guidance in the United Kingdom (since replaced with less specific guidance) expressly advised that where a proposed telecommunications installation conforms to the recommendation of The Independent Expert Group on Mobile Phones ("The Stewart Report") and the guidelines for the public exposure set by The International Commission On Non-Ionising Radiation Protection (ICNIRP), then the Local Planning Authority should have no concerns with regard to health and safety issues. - 6.19 The application is accompanied by a certificate of compliance with the World Health Organisation ICNIRP guidelines for public exposure, and the 'Health and Safety at Work Inspectorate' is responsible for the monitoring of telecommunications installations to ensure compliance with the ICNIRP Guidelines. No concerns relating to the safety of the general public are therefore raised. - 6.20 The proposed equipment to be affixed to the mast are shown on the plans with indicative sizes. As such, whilst the principle of the telecom functioning equipment affixed to the mast has been shown and the quantity of units, those specific details can be conditioned to

ensure specifics and dimensions are submitted prior to commencement on site to ensure the mast is appropriately utilised for telecommunication equipment as shown on the plans.

- 7.0 CONCLUSION

7.1 Whilst it is acknowledged that the height of the tower will have some visual impact in the existing streetscape, it is not considered that this will be significantly detrimental to the established amenity of the area. It is concluded that the planning application would not harm the use and enjoyment of neighbouring properties or the highway network and would comply with aforementioned planning policies of the Isle of Man Strategic Plan 2016, and is recommended for approval. - 8.0 INTERESTED PERSON STATUS

8.1 By virtue of the Town and Country Planning (Development Procedure) Order 2019, the following persons are automatically interested persons:

• (a) the applicant (including an agent acting on their behalf);
• (b) any Government Department that has made written representations that the Department considers material;
• (c) the Highways Division of the Department of Infrastructure;
• (d) Manx National Heritage where it has made written representations that the Department considers material;
• (e) Manx Utilities where it has made written representations that the Department considers material;
• (f) the local authority in whose district the land the subject of the application is situated; and
• (g) a local authority adjoining the authority referred to in paragraph (f) where that adjoining authority has made written representations that the Department considers material. 8.2 The decision maker must determine:

• o whether any other comments from Government Departments (other than the Department of Infrastructure Highway Services Division) are material; and
• o whether there are other persons to those listed above who should be given Interested Person Status

I can confirm that this decision has been made by the Head of Development Management in accordance with the authority afforded to that Officer by the appropriate DEFA Delegation and that in making this decision the Officer has agreed the recommendation in relation to who should be afforded Interested Person Status

Decision Made : Permitted Date : 13.03.2024 Determining officer

Signed : S BUTLER Stephen Butler Head of Development Management

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