DEC Office Report

PLANNING OFFICER REPORT AND RECOMMENDATION

Application No.: 24/00442/B Applicant: Sure (Isle Of Man) Ltd Proposal: Redevelopment of site with the installation of a 10m lattice tower with associated antenna and dishes Site Address: Scarlett Point Tower Scarlett Castletown Isle Of Man IM9 1TB Senior Planning Officer: Jason Singleton Site Visit: 07.05.2024 Recommended Decision: Permitted Date of Recommendation: 13.05.2024

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 telecoms mast and affixed communication equipment here by approved shall be no higher than the stated 10m when measured from the concrete base as shown on plan referenced; IoM_41/014 Rev.A REASON To ensure the mast height is installed in accordance with the approved plans
• C 6. The proposed antennas, dishes and RRU shall be coloured to match the monopole tower mast to which they are affixed and retained in perpetuity. REASON: To mitigate any visual impact.
• C 7. The temporary work area / fencing as shown on the drawing entitled, "Temporary Mast and Temporary Work Area" Ref; IOM_41/015_A 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 rural countryside or its setting and would comply with Spatial Policy 5, General Policy 3, General Policy 2 (b,c,g,m) Environmental Policy 1, 2, 22, and Infrastructure Policy 3 of the IoM Strategic Plan.

Plans/Drawings/Information; This decision relates to drawings and supporting information received on 12th April 2024 referenced; IOM_41/010_A

• IOM_41/012_A
• IOM_41/013_A
• IOM_41/014_A
• IOM_41/015_A _______________________________________________________________

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 encompasses the former coastguard station tower on Scarlett, Castletown. The building is approximately two stories high (approx. 8.5m) with a flat roof and glazing and wrap around balcony to three sides. The immediate surrounding lands are agricultural fields and is immediately adjacent to the sea and adjacent to the Raad ny Foillan (Coastal Footpath).

1.2 This site is partially used by Sure Mobile who is also the applicant and contains an antenna and dish affixed to the northern (rear) elevation. Part of the site is also used for amateur radio station. THE PROPOSAL

2.1 Planning permission is being sought for the removal of the current communications equipment on the building and the installation of a new 10m high slim line lattice tower on a concrete slab foundation, adjacent to the building. The tower would be a triangular shape consisting of three columns with supporting bracing forming the overall structure with a grey galvanised colour. - 2.2 Mounted to the lattice tower would be: 1 x panel antennas towards the top of the mast one dish @ 600mm dia and one dish @ 300mm dia. Also proposed is a new electrical meter cabinet to the east elevation of the building. None of the equipment would be higher than the top of the 10m lattice tower. - 2.3 The applicant notes; " The proposed structure will be a 15-meter slimline lattice, 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 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 1 microwave link, the size/location of the dish on the included drawings for this application are indicative until a final vendor decision has been made, final sizes will be confirmed with planning ahead of installation." - 2.4 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"). Signed 09/02/24. - 2.5 At present the specification of the 'antennas' 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". - 2.6 It is to be noted during the decommissioning of the existing and the erection and commissioning of the new mast and equipment, a temporary 10m mast mounted to a wheeled trailer with panel antennas affixed will be installed to the side of the site and fenced off with Heras fencing, all of which will be removed on completion of the new tower. PLANNING HISTORY

3.1 11/01099/B - Installation of mobile phone communications antenna to rear of building. Approved.

PLANNING POLICY LOCAL PLAN

4.1 The application site is identified on the Area Plan for the South as 'white land' and within an area of countryside that is not designated for development. The building is shown outlined on the plan.

4.2 The land is also linked to Map 2 Landscape Assessment Areas; that identifies site is within an area that is broadly classified undulating lowland Plain and rugged coast - Ref E10 on the landscape constraints plan on the Area plan for the South.

4.3 Within the written statement for the area plan for the south Ref E10; Castletown Bay "The overall strategy is to conserve the character, quality and distinctiveness of the coastal area with its rich ecological habitats, open and expansive panoramic views, and to conserve the coastal setting of Castletown". - 4.4 The site/ area is further noted in F8 "Poyll Vaaish and Scarlett Peninsula; "The overall strategy is to conserve the strong sense of openness throughout the area, with strong field pattern as well as the setting of the numerous archaeological sites and wartime structures within the area". - 4.5 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 - 4.6 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 2,3,4 Settlement hierarchy 5 New development will be located within defined settlement.

General Policy

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

• 1 Protection of the countryside
• 2 Protection of the character of AHLV 22 (iii) Safeguarding the environment and/or the amenities of surrounding properties Infrastructure Policy
• 3 Need for communications infrastructure versus environmental impacts

4.7 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;

4.8 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. - 4.9 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.
• 4.10 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 Malew Parish Commissioners do not object (01/05/24)

5.2 Highways Services do not object (19/04/24)

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

• - Principle of development (SP2,3,4,5; STP1; GP3e)
• - Necessity (IP3)
• - Design (Gp2b)
• - Visual impact (GP2c, EP1, Ep2, IP3)
• - Impact upon residential amenity (GP2g and EP22)
• - Other matters

PRINCIPLE

6.1 The general principle would comply with Stp1 as the applicants are utilising an area of land where telecommunications infrastructure is already in existence and is set to replace the existing adjacent to an existing structure.

6.2 It is noted that this site sits outside of any defined residential settlement boundary, the nearest being Castletown. However the proposal would seek to bolster mobile coverage to the neighbouring parishes of Malew and Arbory. The proposals would also benefit those adjoining town and rural areas where there are many sporadic rural dwellings and agricultural farms that sit within the identified settlement villages in the south (Castletown, Coly/Ballabeg) as identified in SP2,3,4.

6.3 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. - 6.4 As an exception can be found under GP3e and cross referencing with IP3 to ensure there is no visually intrusive masts in sensitive landscapes, all while EP1 seek to protect the countryside and its ecology for its own sake. As such the principle would conform to Sp5 and GP3e with the main focus of this application being on the visual impact of the proposed replacement mast on the rural landscape by installing a 10m slim line lattice tower while considering the general development control principles as discussed below. NECESSITY - 6.5 The application is submitted by Sure Mobile, essentially to improve the available mobile signal coverage to both indoor and outdoor demands within the villages and rural parishes, but also to the wider catchment of the South of the Island, as demonstrated as part of the submission. - 6.6 In favour of the proposals is Infrastructure Policy 3 and its supporting text which broadly advises that the maintenance and improvement of the Island's telecommunications

• systems will likely require the provision of new infrastructure and a balance has 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.
• 6.7 A further material consideration is the general support from the Climate Change Plan 2022-2027 through improved network infrastructure to allow for increased levels of home/remote working within the wider residential areas. The residential catchments as identified above are important considerations, particularly given the Government's strategy for remote workings.
• 6.8 The proposed structure would be slightly higher than existing and would have an advantages over the current situation due to the antenna being higher which will offer a significant improvement to the user experience in this area. The proposed mast will also have the capacity to support next generation network development. In terms of mast sharing, this is a direct replacement and there are no other telecoms masts in the immediate vicinity that would be viable in this location.
• 6.9 The overall "need" for the proposal can be substantiated in this instance and works towards the overall Government objectives to enhance the level of connectivity through the investment and modernisation of communications equipment. This will result in the provision of newer and faster technology as part of the Islands communication goals, which is also part of the overall Island Economic Strategy and is welcomed as technology and demands on mobile services increases. As such this aspect would be read in accordance with IP3 of the IOM Strategic Plan. DESIGN
• 6.10 The design of the mast would see a slim line tubular, triangular shaped 'structure' with diagonal bracing through which the sky behind would be partially visible, whereas the existing monopole is a solid tapered structure, which helps the new mast to blend in with its surroundings. However, to the upper proportions of the mast would be affixed with various transmitting equipment which could emphasise its visual appearance.
• 6.11 The current structure affixed to the building is understood to be incapable of supporting the next generation of mobile technology RRU's and the building would not be able to support the increased loading from the additional steel work needed to brace the building to carry the additional weight.
• 6.12 The level of finish of the antennas and mast 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 noted that the antennas attached to the mast would be no higher than the top of the pole and can be conditioned as such, but it is important that any communications equipment and antennas are colour coded to match the mast to mitigate any visual impact and they are all read as one unified colour.
• 6.13 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 in this instance given the lack of any natural vegetation and the views will mainly be looking upward, the galvanised grey colour as proposed would be acceptable here. VISUAL IMPACT
• 6.14 General policy 2 ensures any visual impact do not adversely affect the character of the surrounding landscape and equally Environmental Policy 1 ensures there is no adverse visual harm to the wider countryside and its ecology. The opening sentence of Infrastructure Policy 3 is also helpful when balancing the need and any visual impact. The policy narrative helps to

• ascertain whether the increase in height above the coastguard building and new design of mast, particularly the upper proportions would be detrimentally to the countryside setting, noting the topography and the land use designations surrounding the site.
• 6.15 The magnitude of the development's intrusion upon the wider landscape setting here would be visible from the coastal footpath as the site is within a very exposed location with very little to natural vegetation or cover to obscure the development. Here the mast will be seen in the same context of the former Coastguard tower, which is already an unusual structure on the coastal / rural landscape.
• 6.16 The agents have noted in their supporting statement; "due to the structure type and the location selected to build the new proposed structure. Having opted for a slim line lattice built up against the Coastguard Tower we think that we can increase the network capacity in the area using a more versatile structure without a negative impact on the landscape, the proposed structure will be slightly taller than the Coastguard Tower, however due to its design we believe the visual impact of this height increase will be minimal". As such this is an agreeable approach as a replacement mast to mitigate visual impact and could be supported.
• 6.17 The proposals would not be seen to be introducing excess levels of development nor be seen as an incongruous feature on the landscape. As such this aspect would comply with Ep1, Ep2 & Gp2b where the proposals would not adversely affect the character of the countryside. RESIDENTIAL AMENITY
• 6.18 The application site is in a remote rural setting and there are no residential dwelling within the vicinity that would be impacted by the replacement of the mast and its communication infrastructure. As such the proposal would comply with GP2g and EP22. OTHER MATTERS
• 6.19 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.
• 6.20 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. In this respect, the proposal is compliant also with GP2(m).
• 6.21 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/ assessed on the plans.

- 7.0 CONCLUSION

7.1 Whilst it is acknowledged that the height of the lattice tower will have a limited visual impact in the existing rural setting, it is considered that the proposal would not create any additional visual harm or intrusion into the site and surrounding rural area.

7.2 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 and would conform to those parts of Strategic Policy 1, General Policy 2(b,c,g,m), Environment Policy 1 and Infrastructure Policy 3 of the Isle of Man Strategic Plan 2016, and is recommended for approval with conditions. - 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 Acting 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 : 16.05.2024 Determining officer

Signed : A MORGAN Abigail Morgan Acting Head of Development Management

Customer note This copy of the officer report reflects the content of the file copy and has been produced in this form for the benefit of our online services/customers and archive records.