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Proposed Optus Telecommunications Facility Lot 22 | DP 94170 172 Stevens Road, Redgate WA 6286 Optus Site Reference Number: P0541 Prepared on behalf of Optus Mobiles by CommPlan Pty Ltd September 2017

Proposed Optus Telecommunications Lot 22 | DP 94170 172 ... · Proposed Optus Telecommunications Facility Lot 22 | DP 94170 172 Stevens Road, Redgate WA 6286 ... September 2017

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Page 1: Proposed Optus Telecommunications Lot 22 | DP 94170 172 ... · Proposed Optus Telecommunications Facility Lot 22 | DP 94170 172 Stevens Road, Redgate WA 6286 ... September 2017

Proposed Optus Telecommunications Facility

Lot 22 | DP 94170

172 Stevens Road,

Redgate WA 6286

Optus Site Reference Number: P0541

Prepared on behalf of Optus Mobiles

by CommPlan Pty Ltd

September 2017

Page 2: Proposed Optus Telecommunications Lot 22 | DP 94170 172 ... · Proposed Optus Telecommunications Facility Lot 22 | DP 94170 172 Stevens Road, Redgate WA 6286 ... September 2017

SUMMARY

Proposal

Optus propose to install a new mobile base station facility at 172 Stevens

Road, Redgate (Lot 22 Diagram 94170). The proposal comprises of the

following:

• Installation of a 40-metre-high monopole (overall height of 43.2m).

• Installation 3 x panel antennas (no more than 2.8m in length) at the

top of the monopole at a height of 42m and the installation of 12

RRU’s on the monopole below the proposed panel antennas;

• Outdoor 6-bay equipment cabinets at ground level adjacent the

monopole;

• A 2.4-metre-high chain-link security fence around the base of the

monopole and equipment cabinets, and

• Installation of ancillary equipment associated with operation of the

facility including; cabling, ladders, safe access methods, bird

proofing, earthing, electrical works and air-conditioning equipment.

Purposes The proposed facility is necessary for Optus to provide mobile and data

services to Redgate and the surrounding areas.

Property Details Legal property description: Lot 22 / DP 94170

Street Address: 172 Stevens Road, Redgate WA 6286

Town Planning

Scheme

Council: Shire of Augusta-Margaret River

Zone: Priority Agriculture

Principal Designated Use: Rural

Shire of Augusta-Margaret River LPS No. 1 Yes

Application Use and development of the land for the construction & operation of a

mobile base station.

Applicant

Optus c/- CommPlan

Contact: Edwina Ross (02) 9363 3815 [email protected]

Our Ref: P0541 Redgate

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INTRODUCTION

Mobile telecommunications plays a central role in society and is becoming increasingly integrated

into our day-to-day lives. It shapes how people communicate, access information and complete daily

tasks. Individuals, families, businesses and society are all benefiting from the improved connectivity

facilitated by mobile technologies. In addition to its personal and social value, the evolution of mobile

technologies has delivered significant benefits to the Australian economy by improving productivity,

business management and customer engagement.

As such, the demand for effective telecommunications services and infrastructure has increased

considerably. An increasing number of people are demanding more mobile services from more

locations nationwide. People are also demanding for coverage to be uninterrupted while they move

around the country.

To cater for the growing demand for mobile services, Optus has embarked on a nationwide rollout

to deliver an improved, reliable telecommunications network to the Australian public. The rollout will

provide improved mobile coverage and enhanced services in metropolitan, regional and rural areas

throughout Australia. This rollout consists of the upgrade of existing telecommunications facilities

and where required the installation of new mobile base station’s to expand the coverage footprint

and offer seamless mobile services.

BACKGROUND

What is a mobile base station and how do they work?

A mobile base station is a facility that provides mobile coverage to a geographical area. A mobile

phone network is made up of base stations which operate together to provide service to users

moving from place to place within a coverage area. A mobile base station typically consists of the

following components: antennas, support structure, base station and transmission equipment. The

antennas are connected by cable to radio equipment usually housed in a room, shelter or outdoor

unit. Base stations are connected to the core network by microwave or fibre.

Mobile phones work by sending and receiving low power radio signals, much like a 2 way radio

system. The signals are sent to and received from antennas that are attached to radio transmitters

and receivers, commonly referred to as mobile phone base stations. The base stations are linked to

the rest of the mobile and fixed phone network and pass the signal/call on into those networks.

Purpose of the proposal

Additional mobile base stations are required where surrounding facilities cannot provide sufficient

coverage to a target area due to distance limitations. New facilities are also required when existing

base stations are fully utilised and cannot serve further users in the area.

Optus has undertaken analysis of their mobile network in Redgate and surrounding regions,

identifying areas where coverage and network quality needs to be improved. If this investment is not

made, two main issues will arise:

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1. Users may have difficulty connecting to the mobile network or the call may drop out. This

impacts businesses, residents and visitors to the area and the ability of users to contact

emergency services.

2. Users may experience reduced data speeds, longer download times and poor network

performance at busy times of the day with data intensive and time sensitive applications

(e.g. newscasts, social media, mobile banking, weather forecasts, sports highlights etc.)

due to the available capacity being shared across too many customers.

Once Optus identified the need for improved network performance, the optimisation of existing

Optus facilities throughout the region was explored and undertaken where required. In some cases,

this option resolves network deficiencies in an area. However, in this situation the optimisation of

surrounding facilities has not been able to achieve a satisfactory outcome for the network within,

and surrounding, Redgate.

Optus has undertaken investigations into the use of other carrier and broadcast facilities within the

area. However, in this case existing facilities were not deemed as suitable. As such it was concluded

that the deployment of a new Optus mobile base station within Redgate is the only viable solution.

SITE SELECTION

Site Selection Process

As part of Optus’ site acquisition procedure, a comprehensive site selection process has been undertaken in order to identify a suitable location for a new facility in the vicinity of Redgate. This has included looking for ‘co-location’ opportunities, in accordance with Chapter 4 Part 3 Clause 4.13 of the Telecommunications Code of Practice 1997, as well as ‘Low Impact’ solutions, in accordance with the Telecommunications (Low Impact Facilities) Determination 1997 and new Greenfield locations.

In addition to this, Optus also assesses the technical viability of potential candidates through the use of computer modelling tools that produce predictions of the coverage that may be expected from a potential candidate, as well as the technical expertise of the Radio Engineers.

There are a number of other important criteria that Optus uses to assess and select potential sites

and take into account factors other than the technical performance. These include:

Planning:

• Compliance with the EME standards mandated by the Australian Communications and

Media Authority (ACMA).

• Proximity to sensitive community uses such as schools, childcare centres, hospitals and

aged care facilities.

• Regulatory compliance and the ability to obtain relevant planning approvals.

• The ability to minimise any environmental, heritage and visual impacts.

• Acceptability of the proposal to council and the community.

• Opportunities to co-locate facilities.

• Visual aspect and amenity.

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Property:

• Willingness by the owner to enter into a tenure agreement and provide access during

construction and operation.

• Impacts upon the existing use of the site.

Engineering:

• Feasibility of construction and the provision of utilities (power, access to the facility and

transmission links etc.).

• Cost of developing the site.

Radio frequency coverage and objectives:

• Ability to be linked to the existing Optus network and meet the radio frequency coverage

objectives for the area.

During the detailed site selection process for the new facility, Optus carefully considered all of the

above criteria. This analysis is detailed in the following sections.

Opportunities to Co-locate

Federal, State and Local government legislation encourages the use of existing telecommunication facilities for the co-location of new antennas in order to minimise the proliferation of mobile telecommunication towers. As such, Optus’ site selection process flags potential colocation opportunities during the initial stages of candidate selection. Whilst there are existing sites within the region, no sites were available that would have been able to achieve Optus’ service and coverage objectives for Redgate.

Low Impact Solutions

Given the rural nature of the area, no suitable buildings or structures were present with sufficient elevation to be considered as a viable candidate for a low impact facility.

Greenfield Solutions

When the site selection process reveals that a Greenfield solution is the only option, preference is given to the most appropriate sites; those being rural and residential properties. As discussed in Section 3.1, there are many characteristics that determine the suitability of a potential location for a telecommunications facility.

The search criteria for this proposal was located primarily around the residential and rural area of Redgate. This area has been zoned Priority Agriculture and Rural Residential and is predominantly used for agriculture purposes. This agriculture area is a low lying and flat ground. There are many agricultural land uses and wineries in around Regate.

Table 1 provides a summary of the candidate sites that were identified as part of the site selection process:

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Candidate Allotment &

Address

Development

Type Description

A Stevens Rd,

Margaret

River WA

6285

45m

monopole

Candidate A is zoned Priority Agriculture

and is privately owned by Leeuwin Estate.

The site is a part of a winery and vineyard.

The proposal will need a development

application.

The tower is proposed to be located away from the main winery and near the border of the lot. This facility will require tree removal for its installation and access track. The land is located within a bushfire prone area. This location is well set back from any public road or dwelling surrounding the site. There are no community sensitive sites identified within 500m of the site.

This candidate was not chosen due to the

removal of trees being required, surrounding

heights of the trees and the winery owners

showing no interest for the proposal.

B 157 Stevens

Road,

Witchcliffe,

WA 6286

45m

Monopole

Candidate B is located within a privately-

owned lot zoned Priority Agriculture and is

currently vacant land. The proposal is

located in a bushfire zone and is near dense

vegetation. The proposal will need a

development application.

There are several residential properties and

wineries within visual distance of the

proposed facility. There are no community

sensitive sites identified within 500m of this

proposed site.

This candidate was also not chosen due to

the land owner not willing to enter into a

lease agreement with Optus and the

proposals proximity to other dwellings.

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C Stevens Rd,

Margaret

River WA

6285

45m

Monopole

Candidate C is located on RE1 Public

Recreation and would need a development

application. This lot is privately leased from

Crown Lands and is currently vacant.

The proposed site location is near the

entrance to the lot approximately 100m from

the access track to the Winery and its car

park. There are no community sensitive

uses identified within 500m of the site. The

site contains dense and tall vegetation to be

removed which would be required to be

removed for the installation of an access

and construction of a facility.

Candidate C was not considered to be a

suitable location, due to its position near

Leeuwin Estate Winery and required tree

removal.

D

80 Rowe Road,

Witchcliffe WA 6286

31m

monopole

Candidate D is located within a privately-

owned lot of land used as for agricultural

purposes. The facility is located in along the

Western border near Rowe Road, away

from the existing buildings. The site is zoned

Priority and will require a development

application.

There are no community sensitive uses or

residential properties within 500m of the site

but the site will be visible from surrounding

vantage points. The site may be visible from

Bussell Hwy and impact the surrounding

natural landscape, which has resulted in the

reduction of the height of the facility.

Candidate D has not been selected due to

its visibility from Rowe Road West. The

coverage of this site did not meet the

radiofrequency target for the area.

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E 270 Stevens Road,

Redgate WA 6286

36m

monopole

Candidate E is zoned Priority Agriculture

and is privately owned. The site is used for

agricultural purposes and the position of the

facility will be on vacant land. The proposal

will need a development application.

The land is affected by a bushfire prone vegetation. There are no community sensitive sites within 500m of the site and there are 2 residential dwellings within 500m of the site.

This candidate was not chosen due to not meeting radio frequency coverage objectives and surrounding vegetation which hindered the projected coverage.

F 172 Stevens Road,

Redgate, WA 6286

42m

monopole

Candidate F is zoned Priority Agriculture

and is privately owned. The site is used for

agricultural purposes and the position of the

facility will be on a vacant space of land. The

proposal will need a development

application.

The land is within a bushfire prone area. There are no community sensitive sites within 500m of the site and there are 2 residential dwellings within 500m of the site. The proposed site is close to power.

Candidate F has been selected as the prime

candidate, due to its minimal visual impact

on surrounding areas and this site provided

the best coverage to Redgate. The

candidate will be discussed in Section 4

below.

Page 9: Proposed Optus Telecommunications Lot 22 | DP 94170 172 ... · Proposed Optus Telecommunications Facility Lot 22 | DP 94170 172 Stevens Road, Redgate WA 6286 ... September 2017

Figure 1: Aerial View of the Proposed Candidates (Source: Google Earth 2017)

Site Selection Conclusion

Optus have selected a new prime candidate based on the radiofrequency objectives, planning and

environmental constraints, proximity to potential community sensitive uses, engineering criteria and

the ability to obtain tenure on a property as noted in Section 2 of this report. Additionally, the design

and location of the proposal include the proximity to residential housing (both existing and future)

and the visual impact on the amenity of the area.

The proposal is for the installation of a new 42m monopole with a headframe (total height of 37.5m),

the panel antennas and the equipment shelter on the ground at 172 Stevens Road, Redgate

(Latitude/Longitude co-ordinates -34.014167°, 115.050278°). Access to the site will be gained via a

gate off Stevens Road, the proposed facility is to be located within the existing fenced property. No

tree clearing is required to access the site, nor to construct the facility as the site has previously

been cleared for agricultural purposes.

The reasons for selecting the site are as follows:

• The proposed site meets Optus’ radio frequency coverage objectives, providing the quality of

service expected of customers within the area.

• The proposed facility is sited near the Southern boundary of the agriculture lot. This location

was identified in order to alleviate the visual impact and proximity to residential dwellings. The

setting on the agricultural lot which has other tall structures like the power poles and light poles

which will help blend the facility into the surrounding landscape.

• No vegetation clearing is required for the facility and access to the site is existing as the land

has been previously cleared for the sales yard.

Page 10: Proposed Optus Telecommunications Lot 22 | DP 94170 172 ... · Proposed Optus Telecommunications Facility Lot 22 | DP 94170 172 Stevens Road, Redgate WA 6286 ... September 2017

• The facility will not inhibit the current or future use of the site for current purposes as it is

located on the Northern boundary of the lot.

• There is access to existing electricity infrastructure and the site can be accessed via Stevens

Road.

Optus, have undertaken a detailed assessment of the site location and the proposal, which has

included an investigation into the compliance of the proposed facility with the relevant processes

and objectives of applicable Commonwealth, State and Local Government planning and

environmental legislation, policies, standards and guidelines. It also involved an investigation of the

possible impacts of the proposed facility on areas potentially affected by the proposal.

PROPOSAL SUMMARY

In general terms, the proposed development will comprise the installation of a new 40m monopole

with associated antennas and an equipment housing sited on the ground.

The proposed facility is located on a small hilltop in a large rural paddock, approximately 100m west

of Stevens Road. The majority of the lot is occupied by vineyards. The telecommunications facility

is proposed on the southern boundary adjacent to an area of vacant land and a small single-storey

building. The surrounding land is occupied by natural vegetation, vacant paddocks and vineyards.

There are residential dwellings scattered around the site. Leeuwin Estate winery is located

approximately 1.4km east of the site. A large area of dense trees is located immediately to the south

of the proposed location.

A map of the property and surrounding area is provided in Figure 2 below.

Figure 2: Subject site and surrounds.

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Plans showing the location of the facilities, the type, location and configuration of antenna structures

on the pole and the location of the equipment housing are provided in the attached Design Plans.

There are no community sensitive land uses located within the immediate vicinity of the site. There

are two neighbouring residential dwellings within 500m of the location of the proposed facility. A map

is provided below in Figure 3. The site is not heritage listed and not located within a heritage

conservation area. There are no significant environmental constraints relating to the site.

Figure 3: Subject site and surrounds - 500m radius map

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Figure 4: Approximate location of the proposed facility shown with the grey arrow.

Shire of Augusta-Margaret River Local Planning Scheme No. 1 (LPS 1)

Priority Agriculture Zone – Objectives (4.2.2.1)

The subject site is zoned Agriculture under the Shire of Augusta-Margaret River Local Planning

Scheme No. 1. The objectives of the zone are outlined below:

(a)To provide for a strong sustainable agricultural industry that is sufficiently flexible in response to changing industry circumstances by protecting the long-term availability of suitable land for a diverse range of agricultural purposes; (b)To oppose subdivision proposals which would adversely affect the utility of existing agricultural land for productive purposes through specific subdivision criteria to ensure long term agricultural sustainability and appropriate lot sizes; (c)To manage land use changes so that the rural productivity and the rural character and amenity of land within the zone is preserved; (d)To maintain and enhance the environmental qualities of the landscape and attractive rural scenery of land within the zone, and to promote sustainable environmental management practices; (e)To minimise the clearing of land;

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(f)To ensure that areas of indigenous vegetation are carefully evaluated before any clearing proposals are approved and to encourage the provision of replacement plantings of native vegetation to maintain and preferably enhance the Shire’s biodiversity and landscape values; and (g)To allow for the provision of sustainable low impact tourist development such as chalet development but only where there is an established and continued agricultural, horticultural, viticultural or other similar rural production, or significant tracts of native vegetation that can be protected on the land holding and where such uses will be incidental and complementary to that established use or protection of the significant native vegetation. The proposed telecommunications facility is considered to be compatible with the objectives of the Priority Agriculture zone outlined above. The proposed facility will provide improved communications services in the area which will have a positive impact on the agricultural practices and ultimately productivity. It is not considered that the proposed facility will significantly detract from the rural character of the area or the environmental qualities of the landscape as the site is not a focal point. Furthermore, a visually sensitive design has been proposed and the site is surrounded by tall trees that provide adequate screening from nearby viewpoints. Subdivision is not proposed as part of this proposal and therefore lot sizes will remain unimpacted. The proposal will not have any adverse environmental impacts as no vegetation clearing is required. Telecommunications Infrastructure (5.17)

• It is considered that the information accompanying the development application satisfies the requirements of clause 9.2 of LPS 1.

• As outlined above, the proposed development is considered to be consistent with the objectives of the Priority Agriculture zone.

• As outlined below, the proposed facility will have vast social and economic benefits for people working, living and visiting the area and is considered to be within the public interest.

• The subject site and surrounding land has no identified significant environmental or heritage values. The area does have landscape and rural character values but the proposed facility is not considered to significantly impact these values. The site is surrounded by tall trees and dense bushland which reduces the visual prominence of the facility from a range of viewpoints. Furthermore, a visually sensitive design has been adopted with a slimline appearance and without a bulky headframe to minimise visual impact on the locality.

• As outlined in the table below, the facility is proposed in coordination with other telecommunications facilities in the area and is proposed due to a ‘gap’ in the existing infrastructure.

• In relation to clause 5.17.3 of LPS 1, the land is privately owned and not Crown land and therefore this clause is not applicable.

State Planning Policy 5.2: Telecommunications Infrastructure (SPP 5.2)

SPP 5.2 is the key planning instrument providing guidance on the development of

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telecommunications facilities in Western Australia. The key policy measures are outlined in clause 5.1.1 and summarised below having regard to the proposal.

Provision Comment

i) Assessment of the visual impact of development for telecommunications infrastructure should be made on a case by case basis.

The visual impact of the proposed facility has been

assessed as part of this report. Due to the siting of the

facility and existing vegetation it is not expected that the

proposal will have an unreasonable visual impact.

ii) Telecommunications infrastructure should be sited and designed to minimise visual impact and whenever possible: a) be located where it will not be prominently visible from significant viewing locations such as scenic routes, lookouts and recreation sites; b) be located to avoid detracting from a significant view of a heritage item or place, a landmark, a streetscape, vista or a panorama, whether viewed from public or private land; c) not be located on sites where environmental, cultural heritage, social and visual landscape values maybe compromised and d) display design features, including scale, materials, external colours and finishes that are sympathetic to the surrounding landscape;

The facility has been proposed in a location that will

minimise visual impact. The facility is proposed in a

secluded location that is partially screened from a range of

viewpoints by existing vegetation.

a) The facility has been sited to on a rural property that

is not located nearby any major scenic roads or

lookouts. The proposed location is over 1.7km from

Caves road, 1.4km from Redgate Road, and 1.5km

from Boodjidup Road.

b) The facility is not considered to be within close

proximity of any heritage items. The proposed

facility is located 1.4km from Leeuwin Estate winery

and is separated by existing tall trees and dense

vegetation on the subject site and the Leeuwin

Estate site. The proposed facility will not disrupt any

major vistas or panoramas from Leeuwin estate.

c) The site is not considered to have significant

environmental, cultural heritage, social and visual

landscape values.

d) The design of the facility is sympathetic to the

surrounding environment and is of a scale that will

not have adverse impacts. The facility has a total

height of 43.2m and will be screened by some of the

tall mature trees located around the site and on

neighbouring properties. A visually sensitive design

has been adopted for this proposal. A slim line

monopole design solution has been adopted rather

than a traditional lattice tower that are bulkier in

appearance. In addition, a turret mount has been

utilised to mount the antennas on the monopole

which maintains the slim line design rather than a

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standard headframe. Refer to Attachment C for site

photos.

Refer to Attachment D for a report demonstrating

compliance with the Mobile Phone Base Station

Deployment Industry Code (C564:2011).

iii) In addition to the existing exemptions under the Telecommunication Act, local governments should consider exempting telecommunications infrastructure from the requirement for development approval where: a) The infrastructure has a maximum height of 30 metres from finished ground level; b) The proposal complies with the policy measures outlined in this policy; and c) The proponent has undertaken notification of the proposal in a similar manner to ‘low impact facilities’ as defined and set out in the Mobile Phone Base Station Deployment Industry Code (C564:2011);

The Shire does not currently have planning provisions that

exempt the proposed facility from development approval.

iv) Telecommunications infrastructure should be located where it will facilitate continuous network coverage and/or improved telecommunications services to the community;

The facility is proposed in a location where there is currently

a lack of coverage from the existing telecommunications

infrastructure. The facility will improve coverage to the

residents in local area and people visiting the area.

v) Telecommunications infrastructure should be co-located and whenever possible: a) Cables and lines should be located within an existing underground conduit or duct; and b) Overhead lines and towers should be co-located with existing infrastructure and/or within existing infrastructure corridors and/or mounted on existing or proposed buildings.

Optus generally as first preference seeks to co-locate on

existing telecommunications towers or existing

infrastructure with an appropriate elevation. In this

instances, there were no existing telecommunications

facilities that met the required radio frequency coverage

objectives. As a result, a new facility must be established in

Redgate. A map of the existing facilities in the area is

provided in Figure 4 below. Note: Optus already have

existing equipment on the towers at Witchcliffe and Prevelly

and this facility is required in order to address the ‘gap’ in

coverage between these towers.

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Figure 4: Map of existing telecommunications facility in the area.

Public Interest

The expansion of mobile services in the Redgate area is well within the public interest for a number

of reasons as outlined below:

• Mobile telecommunications services support local economies with all business relying on

mobile services for communication. This tower will provide services to the area;

• People rely on mobile services for social connectivity; and

• During emergency events such as fires, floods and storms, mobile communications can be

vital to ensuring the safety of persons and property.

The public interest of this facility is well established and considered proven by the use of mobile

services by almost every person in Australia.

Health and Safety

In relation to public safety and specifically Electromagnetic Emissions (EME) and public health,

Optus co-operates within the operational standards set by the Australian Communication and Media

Authority (ACMA) and Australian Radiation Protection and Nuclear Safety Agency (ARPANSA).

ARPANSA is a Federal Government agency incorporated under the Health and Ageing portfolio and

is charged with the responsibility for protecting the health and safety of both people and the

environment from the harmful effects of radiation (ionising and non-ionising).

All Optus installations are designed and certified by qualified professionals in accordance with all

relevant Australian Standards. This ensures that the Optus facility will not result in any increase in

the level of risk to the public. This facility is to be operated in compliance with the mandatory standard

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for human exposure to EME – currently the Radio communications (Electromagnetic Radiation

Human Exposure) Standard 2003.

The EME Report associated with this site is attached to this report. The report shows that the

maximum predicted EME levels will equate to 0.3% of the maximum exposure limit, which is well

below the allowable exposure limit under the Australian Standard (100% - which is still considered

to be safe).

Moreover, all Optus equipment has the following features, all of which minimise the amounts of

energy used and emitted:

• Dynamic/Adaptive Power Control is a network feature that automatically adjusts the power

and hence minimises EME from the facility;

• Varying the facility’s transmit power to the minimal required level, minimising EME from the

network; and

• Discontinuous transmission, a feature that reduces EME emissions by automatically

switching the transmitter off when no data is being sent.

The proposed facility will also have restrictions aimed at preventing public access, including a

secured compound fence with a locked gate and warning signs placed around the facility.

CONCLUSION

The proposed Optus telecommunications facility at Redgate will form an integral component in the

ongoing development of the mobile telecommunications infrastructure in the locality and wider

Redgate region. The facility will provide an important community benefit by providing access to

critical mobile telecommunications infrastructure, and therefore greatly improved mobile coverage

in the area.

The proposed development is considered appropriate in light of the relevant legislative,

environmental, technical, radio coverage and public safety requirements and is considered

acceptable in social, economic and environmental terms as demonstrated in this report.

There are no major environmental impacts likely to occur which could render the construction and

operation of the proposed facility unacceptable, and the proposal satisfactorily meets the

requirements of the relevant state and local planning instruments and policies.

For these reasons, it is respectfully requested that Council looks favourably at this application and

that it be progressed to a positive resolution.