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Jurby, Isle of Man
WRITTEN STATEMENT IN SUPPORT OF APPLICATION INCORPORATING THE DESIGN AND ACCESS STATEMENTS June 2008
National Grid Wireless Ltd Unit 3 Edward Court Altrincham Business Park Broadheath Altrincham Cheshire WA14 5GL Our Ref: 74010
1 INTRODUCTION ..... 3 2 THE DIGITAL SWITCHOVER PROJECT ..... 5 3 TECHNICAL CONSIDERATIONS ..... 8 4 DESIGN AND ACCESS STATEMENT ..... 11 5 SUMMARY AND CONCLUSIONS ..... 14
1.1 This statement is submitted in support of an application for planning permission made in respect of the existing television broadcast installation at Jurby The key features of the existing installation is a 45 metre high mast that supports a number of antennas, including cross $\log$ antenna for television broadcasting, together with associated equipment housing set within a existing secure compound. 1.2 The site was originally developed by the BBC in the early 1970's but it is now owned and operated by National Grid Wireless Ltd, following the sale of the BBC transmission network in 1997. 1.3 The facility now needs to be altered to accommodate the additional apparatus required as part of the Digital Switchover Project, which is explained in more detail in the next section. The proposed works are shown on the application drawings, but to assist, comprise the following:
1.4 As necessary any uncontaminated earth and materials excavated will be reused for fill and levelling. 1.5 There is a requirement to maintain the existing broadcast services from the site for the duration of the works. The cabin being replaced will therefore have to remain in place until DSO has occurred. 1.6 In the next sections we highlight the benefits of the proposal and provide a reasoned justification for its approval in the context of relevant planning policy and other material considerations. We also explain the community involvement in drawing together the proposals. Although not a specific
requirement in the Isle of Man, we have as a matter of best practice also set out a Design and Access Statement.
2.1 The Digital Switchover (DSO) Project is a major transformation project that will see the UK switchover to fully digital TV region by region between 2008 and 2012. 2.2 Government and the industry regulator OFCOM are driving DSO. This is part of a wider and ongoing policy to improve and take maximum advantage of the many potential opportunities presented by electronic communications in all their diverse forms. A recent example of this is the report jointly published in March 2005, by the Prime Minister's Strategy Unit and the Department of Trade and Industry, entitled Connecting the UK: the Digital Strategy. The functions of the former DTI are now the responsibility of the Department for Business, Enterprise and Regulatory Reform. 2.3 Letters have been sent out to all UK planning authorities, the one in England having been sent on 31 July 2006 from the Communities and Local Government, Culture Media and Sport and Trade and Industry Departments (for England) . This letter will have advised you about DSO, its implementation by Arqiva and National Grid Wireless and the planned timetable. It also highlighted the significant public benefits associated with the project. The letter went on to provide specific planning policy guidance, which is referred to in more detail in the next section. 2.4 Government has identified three main public benefits and the letter gives a brief explanation about them. To help you better understand, we amplify upon these.
2.5 A clear digital divide exists between different parts of the UK. Some already benefit from terrestrial digital television services via the Freeview platform, but even then, customers in different areas may only receive some of the
channels potentially available. In addition, the current digital services are not robust in that most of the installations that provide service do not have sufficient reserve antennas to allow for continuous broadcasting in the event of a major failure to the primary system or to allow major maintenance works. 2.6 DSO will largely end this digital divide, which means with few exceptions the population at large will be able to enjoy:
2.7 The latter illustrations will be of particular benefit to rural populations and less affluent sectors of society who are unable to afford personal computers. Interactive programming means, for example, that when the Olympics are staged in London in 2012, viewers will have greater control over the events they are able to watch, rather than have to watch the events selected by programming editors.
2.8 The second reason is that analogue television broadcasting uses a large amount of the radio spectrum, which is a finite and scarce resource. This is because the signals convey the full range of sound and visual content. By contrast digital technology converts this range into numbers, which can be compressed and transmitted in bursts or packages- the receiving equipment then converts this back into the appropriate sound and picture. By these means several audio-visual services can be carried in the same spectrum which is used for a single analogue channel. The day to day comparisons where we have already seen the switch between technologies are, for example, old LP's to CD's, and videos to DVD's.
2.9 The switchover to digital will therefore free up a large amount of radio spectrum that the Government intends to make available to other users or services that might include mobile TV or high definition TV. Some of these services will add to the range of electronic communication services available and stimulate competition to the benefit of the public at large.
2.10 The UK has always been a world leader in broadcasting, but as other countries move towards a digital platform, so the UK risks being overtaken. High quality transmissions and a wide choice of services offer obvious benefits to the viewing public. In addition, a high quality platform is critical to thriving culture and media industries, whose success brings about considerable benefits to the UK economy.
3.1 The terrestrial television network was largely developed by the BBC and the Independent Broadcasting Authority (IBA) during the 1950's and 1960's. The BBC sites are now owned and operated by National Grid Wireless and the IBA sites by Arqiva. 3.2 Under the current arrangements, the BBC and the commercial broadcasters are responsible for the programming content, with NGW and Arqiva being responsible for the actual broadcasting into customer homes. 3.3 So that viewers only need to orientate their television aerials and tune into one broadcast transmitter, the original BBC and IBA networks were shared, i.e. all ITV services could be obtained through a BBC owned and operated site and vice versa. The only exception to this is with the more recent Channel 5, which is not available through al BBC sites and hence many viewers are still unable to obtain this channel through terrestrial television.
3.4 The analogue television network extends to a total number of 1,154 sites, which provide television coverage to about $99 \%$ of the UK population. There are three types of sites as follows: a. 50 Main Transmitter Stations (MTS) providing direct coverage to more than $80 \%$ of the UK Population b. 120 High Powered Relay Stations (HPRS) providing coverage to almost $15 \%$ of the UK Population c. 984 Low Powered Relay Stations (LPRS) providing coverage to just under $5 \%$ of the UK Population 3.5 The MTS's typically range from 150 to 250 metres in height, the most well known probably being our site at Crystal Palace. They are usually guyed masts located in rural areas. 3.6 The HPRS sites are generally 45 metres high lattice towers, but can extend to around 100 metre high guyed masts. 3.7 The LPRS sites are as low as 12 metres in height and many are like telegraph poles. 3.8 Programming is sent from the television studios by broadcast or cable link to the MTS sites where they are then broadcast across the country. The MTS sites can serve millions of viewers over a sub regional geographical area. 3.9 Owing to topography the MTS sites cannot provide high quality transmissions to all parts of their areas and so HPRS sites are used to pick up the signal from the MTS and then effectively boost coverage into where it is required. An HPRS based on the edge of an urban area could therefore provide coverage over tens of thousands of viewers. 3.10 Even with an HPRS pockets of poor coverage can remain and hence LPRS sites are deployed to provide localised infilling. LPRS sites therefore tend to serve only a few hundred viewers or households, but can serve several thousand.
3.11 The programme feed to an HPRS or a LPRS is (with limited exceptions) derived by off-air reception either direct from their parent MTS or from another relay station, which is itself dependant on the MTS. In this way the programme feed may involve a series of links using the HPRS sites. 3.12 Because the programme links are fed into the MTS sites and they provide direct coverage over the bulk of the UK population and indirect coverage over the rest, they are absolutely critical to the television broadcast network. 3.13 The HPRS sites are also very important being they still serve large populations and are often used as a link in the chains of rebroadcast signals. 3.14 In addition to the analogue network, all the MTS and some of the HPRS sites are also used to provide a digital television broadcast network that is transmitted under the Freeview package. Freeview is consortium formed by the BBC, BSkyB and NGW following the demise of OnDigital. This network only covers about $73 \%$ of the UK population and as indicated above, because it has been squeezed into spectrum already occupied by an established analogue television platform, does not have the same resilience as the analogue network. 3.15 DSO will not change the category or hierarchy of any of the installations nor the basic technology of broadcasting signals over wide geographical areas to be picked up by individual receiving aerials. To that extent the main characteristics of the network will remain unchanged, but the particular technical and operational characteristics of the post - DSO network involve replacing the transmit antennas at many sites. Additionally, greater use of satellite technology is expected for active site monitoring and some programme feeds.
3.16 The installation is an LPRS and so has a local function within the broadcast network. The installation is fed by the MTS at Douglas and serves an estimated local population of 3,000 people.
3.17 The proposed work is to locate a new cabin in an existing compound to house the new digital equipment necessary for the switch over from analogue. Once DSO has occurred the existing NGW cabin can be removed together with a stub from an old tower.
4.1 The Design and Access considerations are examined in the context of the site and surrounding area, the national and local planning policy framework and the particular issues especially relevant to the determination of this application.
4.2 The site is an existing television broadcast facility and we have already identified its main characteristics and its role within the national network. 4.3 The site is situated within the old air-force Base at Jurby and has been part of the landscape for a number of years. There will be no significant change to the view, but in any event, the proposed works should not result in any material change to the appearance of the installation.
4.4 The Isle of Man Strategic Plan does not make any specific reference to the DSO project and we therefore encourage the Commission to have regard to the advice set out in the Government letter dated 31 July 2006.
4.5 This letter encourages us to follow a two stage consultative approach. To that end, Arqiva wrote on 26 September 2006 to forewarn you about the DSO project and to identify the particular sites on the Isle of Man that will need to converted, including the NGW sites.
4.6 Due prior consultation has also been carried out on the specific proposals for this site. The assessment for this and the consultation strategy was based upon the best practice approach adopted by the mobile phone operators. 4.7 No comments were received during this process, but now that you have the application formally before you, we would be pleased to assist with clarifying further any aspects about it.
4.8 Similar to England, Infrastructure Policy 4 of the Isle of Man Strategic Plan clearly encourages the reuse or sharing of existing sites and this is notwithstanding any designated area within which they may lie. The broadcast network is long established and even where visible the masts have become accepted features in the landscape. Furthermore, the visual impact of the larger structures is acknowledged to be outweighed by the clear public benefit from television broadcast services through previous consents. These would have been granted following due consideration of any possible alternative sites, having regard to the associated technical constraints. In addition, by relying on comparatively few very large sites, the potential impact associated with many more sites is avoided. For this reason alone the reuse or sharing of existing sites is encouraged. 4.9 Two further technical reasons exist that are relevant to terrestrial television broadcasting. The first is the way in which the use of the radio spectrum and the various channels are regulated and used to avoid domestic and international interference. This severely limits scope for relocating sites and even one small change can have large consequential implications. 4.10 The second technical reason is that viewers' aerials will be orientated towards particular broadcast installations. If moved, those aerials would have to be reoriented towards the new mast, which would add greatly to the cost and inconvenience of DSO to ordinary members of the public. In addition, there would be a real possibility that some people would chose to climb onto there rooftops to carry out this work and put their lives at real and unnecessary risk.
4.11 The alterations proposed at an existing broadcast installation therefore accords with this advice.
4.12 The Government clearly advises that material considerations include the significance of the development as part of a national network. The particular role of the site has been explained together with the population dependent upon it for terrestrial television services. Network considerations also guide the shape and form of the development proposed. 4.13 The amount and scale of the new apparatus has been confined to what is operationally required for DSO. This is important to NGW to maintain the overall costs of the project, which would be unnecessarily high if the works were over specified. 4.14 As the proposals involve no alteration of an existing mast, the layout of the equipment housing is to change with a new cabin set in the existing compound the new antennas must be compatible with both the digital technology and the antennas adopted for the whole new network. That said, the consultative approach adopted did allow for detailed observations to be made and to be taken into account where practicable. 4.15 With regard to access, once installed and operational the permanent works should not result in any material change to the existing level of activity and traffic already generated through the lawful use of the site as part of a national television broadcast network.
4.16 The Government advises that applications should be accompanied by an ICNIRP certificate. The installation will remain compliant with the relevant ICNIRP guidelines on public exposure and a certificate to this effect has accordingly been submitted with this application. 4.17 In conclusion, having regard to Infrastructure Policy 4 the development proposed strikes an appropriate balance between operational and
environmental considerations. Insofar as any exception to this policy might be construed, the need to maintain television coverage and to implement DSO constitutes a strategic national need to justify an exception.
5.1 The application relates to works necessary to convert an existing television broadcast installation from analogue to digital. This is required by Government as part of a national transformation project known as the Digital Switchover. 5.2 Digital switchover will bring about a number of significant benefits. Of especial importance at local level, existing terrestrial services will be improved through greater universal choice and quality. The spectrum released through the project will also spur the next generation of electronic services available to the public, such as mobile TV and high definition TV. 5.3 The existing installation is a Low Powered Relay Station, but it is of great importance within the local area as it provides television coverage to around 3,000 people. 5.4 In bringing forward the application, due prior consultation has taken place. 5.5 The reuse of the existing site is required by the plan approved by OFCOM, the regulator and as reflected in UK policy. The use of an existing facility also accords with Infrastructure Policy 4 of the Isle of Man Strategic Plan, insofar as applicable. These policies apply regardless of any designation. 5.6 The additional apparatus has been confined to the minimum that is required to facilitate DSO. The design and appearance of the apparatus is necessarily guided by the technical requirements of DSO and the existing apparatus being added to. 5.7 The site will continue to comply with the relevant ICNIRP guidelines on public exposure and a certificate has been supplied to this effect.
5.8 In spite of the additional apparatus proposed, the net increase in visual prominence of the existing installation will be within acceptable parameters. In any event any increase in visual prominence will be outweighed by the need to convert this site as part of DSO required by Government. 5.9 To conclude, the development is in accordance with the local development framework and National Policy and we respectfully request the planning permission sought.
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