.A hum! Three Ireland (Hutchison) Limited. Registered Office: 28/29 Sir John Rogerson's Quay. Dublin 2. Ireland. Dublin City Council Planning Department, Civic Offices, Wood Quay, Dublin 8 7"1 February 2020 Our ref: DU1228 Re: Application for planning permission for development at this site: To the rear of Floods Bar, 140 Sundrive Roadl Crumlin, Dublin 12. The development will consist of: The construction of a telecommunications structure (overall height of 19m), ancillary ground-based equipment, cabinets and fencing. AChal?a. DU: PLEN N0 2337220 RECEIVED 20 FEB 20 1.0 SUBJECT SITE AND DEVELOPMENT The subject site is located to the rear of Floods Bar on Sundrive Road. There is existing telecommunications infrastructure at this location in the form of antenna face-mounted to the chimneys of the building. This site is required to provide 36 voice and 46 data service provision in the area. The current uptake of devices has put additional pressures on the network meaning existing base stations are undergoing signi?cant upgrades in technology to meet this demand and so are critical in maintaining current and future service provision. Failure to develop this installation will have an immediate and negative impact on Three's network and its customers in this part of the city. The site is zoned Z3 to ?Provide for and Improve Neighbourhood Facilities? as per Dublin City Council Development Plan. Public service installations are permissible uses under this zoning objective. Compliance with development plan policy is assessed further in section 3.3. USE ZONING OBJECTIVES Zor?eZ?I To Zora Z2 To protectamor hiprove the noti?es otreslds'dal cmservatlai areas Zorsza Zero 23 To preserve. provide and Improve :ecrostlmal W. . 2000215 To protean comaityirsea__ - Above: Extract from Dublin City Council Map Directors. Canning Fok: British. Frank Sixt: Canadian. Edith Shih: British. Christian Salbalng: French. Registered number: 316932 Elaine Carey: Irish. Simon Henry: British. David Hennessy: Irish. Robert Finnegan: Irish Place of registration: Republic of Ireland 2.0 TECHNICAL JUSTIFICATION 2.1 Introduction This section provides a technical justi?cation for the proposed installation (radio base station) at Floods Bar, the Installation is required to provide 2G voice, 3G and 4G data service provision in the area. The installation forms part of an integrated telecommunications network system which has been meticulously planned out to provide best possible network performance within the limitations encountered in this environment. The current uptake of devices has put additional pressures on the network meaning existing base stations are undergoing signi?cant upgrades in technology to meet this demand and so are critical in maintaining current and future service provision. Failure to maintain this installation will have an immediate and negative impact on Three?s network and its customers. This site is proposed to provide mobile voice and data coverage to the Kimmage and Drimnagh area and to improve voice and broadband access to residents and business users in the area. 2.2 Network Planning and Performance The site selection process at the network planning stages is central to creating an overall network that is ef?cient and meets customer expectation but also meets the regulatory systems within which the network is operating. Aside from the land-use planning and property procurement considerations, addressed in other sections of this report, there are many external factors that affect network performance. Performance can be affected by various issues such as the technology of the devices used, the local environment the signals need to travel through, the fundamental physics behind wireless transmission and more. Some of these cannot be avoided and measures must be taken to try to minimise these negative effects. The following will brie?y elaborate on some of these issues in order to understand the limitations for site selection that the radio planners have to consider: Factor Impact Physical Obstructions Wireless signals can have trouble penetrating solid objects such as hills, buildings, single walls or even people. The more obstructions between the transmitter and receiver, the more chance there is that the signal strength will be affected so sites are chosen with as clear a line of site to the next base station as possible. Network Range and Distance The further apart the networked devices that are communicating with each between Devices other are, the more the signal strength dr0ps. This is due to way that wireless signals propagate, covering a wider area as they travel further and because of this, as the signal spreads more, the weaker it becomes. In general, if the distance is doubled the signal becomes 8 times weaker and so on. Wireless Network Wireless networking is becoming more common and therefore more wireless Interference transmissions are being sent through the air. Signals operating at similar frequencies can cause interference with each other and have a signi?cantly negative effect on the performance of the network. This means that more widely used frequency bands can be severely affected by the overcrowding of wireless signals to a point where a device will not operate at an acceptable level. Other wireless technologies can cause identical interference such as mobile phones and microwave ovens that operate within the same ranges. Signal Sharing Wireless networks allow more than 1 device (Smart phone, Tablet etc.) to communicate with a base station at any one time. This sharing of connection means that the more customers accessing the network, the more devices the base station must communicate with instantaneously. The point of access must delegate its resources to each subscriber individually per the amount of transmitting radios it operates on. Network Usage- Bandwidth I With the widespread take-up of Smart Phones and other 46 internet-ready Data Speeds mobile devices a more common problem is network usage. The more people utilising the network bandwidth, the less bandwidth there is to share between them. As bandwidth requirements increase with for example video streaming and other bandwidth intensive applications, existing base station technologies need to be upgraded in or to maintain performance. The proposed 3G services provided on 900Mhz band and 4G services delivered on the band give a larger cell coverage area compared to older 3G on 2100Mhz band and provide better building penetration indoor coverage. The 4G services provide data speeds far in excess of 3G services (up to 10 times faster) and can outperform ?xed line broadband services in a lot of cases and especially in rural areas. Wall construction can be one of the biggest inhibiters of wireless signals, speci?cally affecting indoor networks or coverage. Construction materials used in buildings and of?ces have different levels of impact; concrete is a contributor to poor indoor coverage. Basically, the thicker the walls, the less success the signal will have penetrating through them whilst maintaining a high strength. 2.3 Coverage Requirements for Floods Bar and environs Local Environment Characteristics The main driver for the new site at Floods Bar is to improve service to the large area of residential and commercial premises in the wider area. This site will provide voice and high-speed data services to the surrounding residential areas and amenities in the Kimmage/Drimnagh area. By not deploying a site with suitable height, coverage will suffer for all users in the surrounding areas. The speci?c location chosen for the new site will provide Three with enough overtap of the coverage footprint to adequately serve the area. The overtap will counteract the reduced cell shrinkage affect that occurs during high customer data usage at peak times as the bandwidth reduces and contention rate increases. Keeping a good dominant cell serving the area means continuous service to the residential and business customers. 2.4 Restrictions on Locating on Existing Telecoms Structures Three lreland has a policy to co-locate into existing telecommunications structure where possible, that are located with the target area. Following a comprehensive search of the target search area. no existing base station options were identi?ed that could be shared or upgraded to provide the necessary coverage required. Only as a last resort have Three lreland considered that building a new site is the only option available. The only way to cover this area with suitable radio coverage into this location is by building a new site in the site proposed. Table 2.4.1 Alternatives Investigated DEC PLAN N0 230?/20 20 FEB 20 Site ID and Name Distance from coverage objective Reason for not collocating H3G Site DU0896 Sundn've 0.7 km away from coverage objective unable to cover speci?c area HSG site DU1164 National Stadium 1.2km away from coverage objective unable to cover speci?c area objective H3G site DU1074 Harolds Cross 1.5 km away from coverage unable to cover speci?c area Bridge objective H3G site DU1171 Peggy Kellys 1.1 km away from coverage unable to cover speci?c area objective H3G site DU0140 Madigans 0.7 km away from coverage Thissiteislowinheightalsothus Kimmage Rd objective coverage is limited H3G site DU0141A Cashel 0.9 km away from coverage unable to cover speci?c area Business Centre objective H3G site DU0911Crumlin Garda 1.3 km away from coverage unable to cover speci?c area objective H3G site Bingo 1.4 km away from coverage unable to cover speci?c area Please note that the coverage maps provided illustrate optimal coverage with all other sites in the vicinity operating at maximum ef?ciency. Should one or more of these sites experience a technical fault, require maintenance or upgrading works which would result in equipment power down, the adjacent sites act as a back-up system to maintain a consistent level of service in the area. This explains the importance of each base station in the overall network and ensures network resilience in network operations. 2.5 Service Coverage Plots! Predictions I 5. DEE else as alas/s 1- i. .EBE attailta 5% The coverage maps illustrate the service coverage from the proposed installation at Floods Bar. EXISTING INDOOR COVERAGE UMTS . . .Excenent Level (dam) #49 . Fair/compromised H3G service Iv Good Signal Level (dBm) exists in stated areas Good Signal Level (dBm) I 0k Signal Level (dam) .Fair Signal Level (clam) >=-1os I Excellent Level (cBm) I it Good Signal Level (dam) . Good Simal Level (dBm) air/ compromised H3 59nd service exists in stated areas 3" 5?ng eve h. . . . I Excellent Level (dBm) I Good Signal Level (dBm) Good Signal Level (dBm) :e=-35 I 0k ?gnal Level (cBm) I Fair Signal Level (dBm) >=?1us J.. *3 - Improved H3G service after the addition of new ?oods Bar site Zoomed in of Predicated 36 Coverage with New Site I Excellent Level (dBm) i . I Good 5ng Level (dBrn) Good ?gnal Level . a? I 0k Signal Level (dBm) I Fair Sigrid Level (dBm) >=-105 Improved H3G service after the addition new Floods Bar site 2.6 Technical Conclusion 0le PLAN N0 2307/20 RECEIVED 20 FEB 20 The evidence provided within this Technical Justi?cation demonstrates the technical need for an installation at Floods Bar to maintain a high-quality network coverage for and deliver good customer experience to the large number of residential dwellings in the area, commercial and retail included. The proposed installation will form part of an established telecommunications network system that Three operates in the area and has been carefully chosen to ensure performance levels are maintained. The site is considered the best possible solution to meet both the existing and future demands of its customers in this area. Failure to progress this installation in its current location as can be seen in the plots provided will have a negative impact on Three's network by leaving customers in the area without enough coverage. 3.0 COMPLIANCE WITH NATIONAL GUIDELINES AND COUNTY DEVELOPMENT PLAN POLICIES 3.1 The Report of the Mobile Phone and Broadband Taskforce1 The purpose of the taskforce report is to deliver the National Broadband Plan in the shortest time possible and to reduce Ireland?s urban-mral divide. This taskforce report details exponential growth in data usage and demand in recent years: a over the last 10 years there has been an 800% increase in broadband subscriptions from 212,000 to 1.7 million a 4 million of us are now using the 36 and 4G mobile network a Mobile data usage has increased by a massive 500% over the last ?ve years. As the digital economy grows, it is vital that the infrastructure is in place in every city, town, and village so that populations can reap the rewards of the digital environment. The 40 actions contained within the taskforce report seek to reduce the barriers to developing new telecommunications infrastructure. The reports states that 'the constant rapid evolution in telecommunications technology requires planning and licensing processes to keep pace with consumer demand and the growth in new and emerging technologies The proposed development represents industry investment in response to increased demand for improved, and additional communications services in Ireland. 3.2 Telecommunications Antenna and Support Structures - Guidelines for Planning Authorities (1996) and Circular While these Guidelines are somewhat out of date in terms of technological advances and requirements, they form the basis for assessment of applications for antenna support structures. The Guidelines state that consideration must be given to the technical requirements of telecommunications networks and that will be substantially in?uenced by radio engineering factors?. The Guidelines advise that councils should have an understanding that the location and design of is in?uenced by technical requirements and the operator will have limited scope in terms of changing same. The technical justi?cation outlined in Section 2 clearly and comprehensively outlines the technical requirements of the site and the factors that have in?uenced the location of the proposed development. The subject development is required to maintain high quality network coverage and to deliver good customer experience to this densely populated part of the city. The Guidelines recommend the use of tall buildings or other existing structures as opposed to constructing an independent antenna support structure. The applicant has used the rooftop of the adjoining building over the years to mount antenna and dishes in orderto provide services to this area. However, considering the nature and increased used of technology the existing rooftop site can no longer meet the modern demands placed on the network. A new antenna support structure is required to accommodate the necessary equipment and the height required. The Guidelines state that ?decisions should not be made on the basis of visual impact alone. It is an inevitable consequence of the limitations of the technology that telecommunications installations will have some degree of visual impact in most circumstances. However, with careful design the bene?ts to the national economy and society 1Published by the Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs. December 2016. in general will often outweigh any localised visual impact'. Considering the pattern of development in the area a slimline shrouded monopole is proposed as opposed to a larger lattice-type structure. It is considered that the slimline appearance of the monopole with the antenna contained inside will be similar in appearance to lighting and camera structures in the area. In accordance with Section 4.6 of the Guidelines, a license to provide services is subject to compliance with stn'ct emission controls. The limits are speci?ed by the lntemational Commission for Non-lonising Radiation Protection Regular measurements of emission levels are required to comply with the lntemational Radiation Associations Guidelines. Health concerns are not considered a planning issue as demonstrated in An Bord Pleanaia's Inspectors Report for (Kildare County Council reg. ref: 07/1027); A number of appellants and observers to the appeal have raised concerns in respect of the proposed impact the development would have on health. Health concerns are not considered a planning issue and the issue pertaining to radiation emissions is a matter for ComReg to monitor.? (Kildare County Council reg. ref: 07/1027). The proposed installation will be within the limits as set out by ComReg and ICNIRP limits. It is therefore fully compliant with the relevant Health Safety legislation applicable to this type of development. 3.3 Compliance with Dublin City Plan 2016-2022 It is the policy (Sl29) of Dublin City Council (DCC) 'To encourage and facilitate telecommunications infrastructure in appropriate locations throughout the city as a means of improving economic competitiveness and contributing to sustainable movement by reducing the need to travel through enabling e-working, e-commerce and distance teaming. it is also the policy (Sl30) of DCC ?To support and facilitate the delivery of a highcapacity infrastructure, broadband networks, and digital broadcasting in the city, having regard to the govemment?s guidelines: Telecommunications Antenna and Support Structures-Guidelines for Planning Authorities, 1996 (DEHLG), and Circular Letter PLO 07/12 (including any updated/superseding documents) and where it can be demonstrated that development will not have signi?cant adverse effects on the environment. Section 16.33 advises that ?The provision and siting of telecommunications antennae shall take account of the Telecommunications Antennae and Support Structures Guidelines for Planning Authorities. Compliance with these guidelines is addressed in the previous section. The Plan advises that ?Telecommunications antennae and supporting structures should preferably be located on industrial estates or on lands zoned for industrial/employment uses. Possible locations in commercial areas, such as rooftop locations on tall buildings, may also be acceptable, subject to visual amenity considerations. The subject site is zoned 23 to ?Provide for and Improve Neighbourhood Facilities' as per Dublin City Council Development Plan. Public service installations are permissible uses under this zoning objective. In accordance with section 16.332 of the plan the existing structures in the area have been discounted in the previous section. The proposal is assessed against the City Development Plan development management guidelines below; Development Management Objectives 16.33 Telecommunications Apparatus The provision and siting of telecommunications antennae shall take account of the Telecommunications Antennae and Support Structures Guidelines for Planning Authorities, (Department of Environment and Local Government, 1996), as revised by DECLG Circular Letter PL 07/12, and any successor guidance. 1633.1 Siting, Design and Visual Amenity Telecommunications antennae and supporting structures should preferably be located on industrial estates or on lands zoned for industrial/employment uses. Possible locations in commercial areas, such as rooftop locations on tall buildings, may also be acceptable, subject to visual amenity considerations. 16.332 Possible Sharing of Installations Where existing support structures are not unduly obtrusive, the City Council will encourage co-Iocation or sharing of antennae on existing support structures, Appraisal A detailed technical justi?cation for the proposed development has been provided in accordance with the telecommunications guidelines. The applicant has also utilised the roof of the adjoining building over the years to provide services, however this type of solution is no longer adequate to meet the demands placed on modern telecommunications networks. A new free- standing antenna support structure is a last resort. There are no existing antenna support structures in this part of the city which would provide the required ?in-?ll? coverage. There are no industrial estates or lands zoned for industrial/employment uses within the target coverage area. The proposed development is permissible on these lands zoned 23. In accordance with the telecommunications guidelines the design of the proposed development has been adapted to re?ect the receiving environment and a slimline shrouded monopole is proposed. masts and tall buildings. Applicants must satisfy the City Council that they have made every reasonable effort to share with other operators. etc PLAN xe Ezerrzd 4 VISUALIMPACT 2e rte .25 The subject site is not located within an architectural conservation area or in proximity to any protected structures. Considering the height and scale of the adjoining buildings, and the surrounding pattern of development and building heights a slimline shrouded monopole is proposed as opposed to a larger lattice-type structure. It is considered that the slimline appearance of the monopole with the antenna contained inside will be similar in appearance to lighting and camera structures in the area. Please see accompanying photomontages which provide a visual representation of the proposed development. The proposed design at the subject site represents a reasonable balance between providing the required in??ll coverage in a sub-urban location within the city. 5.0 SUMMARY AND CONCLUSION Telecommunications infrastructure is no different to transport, energy or water infrastructure in that it requires continued maintenance and improvement to maintain capacity in accordance with demand. Furthermore, as technology continues to advance the nature and use and associated demand for telecommunications services is increasing exponentially. Accordingly, more and more ?in-?ll' coverage sites will be required to meet increased densities of population and demand for capacity for services. The proposed site location is considered the Optimum solution in the search area from a radio planning perspective. It provides the necessary coverage to the target area while having minimal impact on the amenity of the area due to the discreet design of the structure. Please feel free to contact me should you require any additional information that would assist the council in deciding this application. We look forward to receiving the council?s decision in due course. qurs Eincere?ly Three Ireland (Hutchison) Ltd.