Irwin Districts Historical Society
The Society acknowledges the traditional owners of the Irwin Districts, their continuing connection to land, sea and community and pays its respects to elders and their cultures, past and present.


Ventia Consultation Team

Level 8 80 Pacific Highway

North Sydney NSW 2060

Proposed mobile phone base tower, 3 Armstrong Street, Dongara WA 6525, #6525012

Submission from Irwin Districts Historical Society

Dear Madam or Sir,

The Irwin Districts Historical operates three museums and a history research centre.  Our main museum and research centre, the Irwin Districts Museum, is located in the Old Police Station and Courthouse (State Heritage Place No 1235, Local Heritage Place No 023), with a street address of 5 Waldeck Street, and back gate off Armstrong Street.  Our principal museum building is about 35 metres south of the proposed tower base.

This submission was prepared after viewing the information available on your consultation website and researching our own records regarding the built and then removed mobile phone tower on the same site in 1997.  We note from your website that this is a ‘pre-community consultation’ exercise, and that an actual community consultation will only be carried out should the proposal proceed to a development proposal stage for approval by the Irwin Shire Council, and if that does occur, you will be undertaking the consultation as an agent for the Irwin Shire Council.

Based on the information on your website, and in our own records, the Society objects to this location for the ‘monopole’ tower.  This submission simply states some key objections and raised several questions.  If an actual community consultation is undertaken, we will develop these points in further detail.

Key Objections

  1. The Shire’s Local Planning Strategy (2017) has identified the Waldeck Street civic precinct as a proposed cultural precinct in accordance with the Town Centre Revitalisation Plan (s4.1, No Ec1.2).  The proposed tower, which will be in the centre of the precinct, will have an overwhelming and domineering impact on the visual character and amenity of the proposed Waldeck Street civic and heritage precinct, and undermine the rationale for the proposed cultural precinct.  That is not acceptable.
  2. There are eight State heritage registered places within the 500 metre radius shown on your EME Report plan, and a further 30 Local Heritage Survey places within the same radius.  There are also further aesthetically and historically important places in this area not yet adequately evaluated for their heritage and cultural significance.  The visual and aesthetic impacts of the proposed large and top-heavy tower on these places individually, and on the precinct and townscape of which they are an integral part, is not acceptable.
  3. The Old Police Station, State Heritage Place No 1235, is significant because, among other things, “the place contributes to the streetscape of Dongara and forms part of a precinct of nineteenth century public buildings in the town.”  That contribution to the nineteenth century character and heritage value of the precinct is generally repeated in the statements of significance of other State-listed buildings in the precinct.  Collectively these emphasise the aesthetic significance of the Waldeck Street civic precinct, a significance that will be adversely impacted by the visually dominating and completely out-of-character design and materials of the tower.  That is not acceptable.
  4. Beyond the Waldeck Street civic precinct, the proposed tower will visually dominate the area within your radius, and in particular State Heritage Place No 4367 ‘Moreton Terrace & Point Leander Drive Fig Trees’.   Recent work on landscaping Moreton Terrace with special attention to the arboreal needs of the avenue of trees made the town a finalist in this year’s Tidy Towns Competition.  The Statement of Significance for the avenue states, in part, the streetscape “forms a rare, extant example of the ‘City Beautiful’ philosophy that was current at the time in Western Australia”, a philosophy that did not include visually overwhelming avenues of trees with oversized utilitarian structures.  The visual impact would not be acceptable.
  5. The Shire’s Planning Scheme No 5 includes Part 7 Heritage.  We would expect the Shire to request a heritage assessment under clause 7.4, relating to all the listed heritage places within your radius, and especially relating to Local Heritage Survey place 022 ‘Old Post Office & Quarters’, for which the statement of significance includes “the building has landmark qualities owing to its elevated siting and prominent location in the heart of Dongara … and its aesthetic merits.”  We would expect the Shire to pay particular attention to other clauses, especially 9.3 regarding additional material for heritage matters, and clauses 9.2(c) and (d) and 10.2 (h), (i), (j), (k), (n) and (o). We would expect to see these provisions substantially and expertly addressed in any development application.
  6. This shire, which does have a documented history of being affected by cyclones, recently just avoided being hit by Cyclone Seroja (April 2021).  Climate change forecasts are all for increased storm and cyclone intensities in this part of Western Australia.  We have a strong concern that should the tower, or parts of it, fall or be damaged in such an event, this will also add further to the damage and impacts on listed heritage places in its vicinity.  The actual record of the Seroja clean-up, and especially the very slow rate of repairs to heritage places (see for instance Geraldton Guardian, 9 December 2022, page 23), shows that these destructive impacts will be around for a very long time, and we would contend that these risks alone far outweigh the benefits.
  7. It would appear that this site has been chosen for the tower simply because it is a site under the control of Telstra.  That control only arises because this was the post office land taken over by the Commonwealth in 1901 when post and telegraph facilities were transferred from the State.  That suggests that path-dependency rather than considered planning has led to this site being selected.  In any development proposal we would expect to see, in some detail, the strategic planning that has considered all the available sites and the reasons why every other site has been rejected. 
  8. The construction of a tower on this site in 1997 lead to considerable community anger and disruption, resulting in a large and vocal local protest movement developing, investigations by Federal agencies, and the eventual re-location of that tower.  This proposal, in its current form, may also lead to the same consequences which, we would contend, is not a desirable outcome for anyone.

Key Questions

  1. Why have no other sites been identified or considered in your website information?  Will other sites be identified with a cost/benefit assessment of each as part of the development application or any other process?
  2. Why have no heritage issues been addressed in the information on your website?
  3. It is not clear from your website, but it is implied that you will also be acting as the agent for Telstra as well as the Shire.  How will the community be assured that your consultations will be independent and have integrity if you will be acting on behalf of both the developer/proponent and the local decision maker?

Thank you for the opportunity to make a submission at this ‘pre-community consultation’ stage,

Yours sincerely


Bruce Baskerville


13 December 2022

Response from VENTIA

15 December 2022

Mr Bruce Baskerville


Irwin Districts Historical Society Inc

Email sent to        

Dear Mr Bruce Baskerville,

Re: Submission to Ventia regarding the proposed Amplitel mobile phone base station at Dongara Exchange, 3 Armstrong Street, Dongara WA 6525

Thank you for your submission dated the 13th of December 2022 with regards to the proposed mobile phone base station at the above address. 

Please see a response to your individual questions below in bold which you raised in your submission.

•     Why have no other sites been identified or considered in your website information? Will other sites be identified with a cost/benefit assessment of each as part of the development application or any other process?

Ventia can assure that once tasked by Amplitel/Telstra with finding a solution to inadequate mobile coverage in Dongara that their team of planners, property consultants, field staff, designers and radiofrequency engineers performed all the necessary due diligence checks before selecting Dongara Exchange as a prime candidate. 

While the public website does not share all environmental analysis findings by the different disciplines due to the preliminary stage of this project, Ventia do not consider any candidates examined to be feasible back-up candidates due to several constraints and sensitivities within the candidate search area.

Candidates examined included the potential for a Telstra co-location on the Dongara Police

Station mast tower or a Telstra co-location on to the steel guyed mast tower near Dongara Golf

Course, along with new greenfield tower options within Dongara Town Park or any of the private ‘town centre’ zoned premises within the ‘Moreton Terrace Mainstreet Commercial’ sub precinct per the Dongara Town Centre Precinct Plan.

No back-up candidates thus far have been considered to be appropriate due to issues relating to structural inadequacies, failure to meet coverage objectives, heritage constraints, landowner support challenges, lack of space, distance to existing telecommunication assets and proximity to residents, Dongara District High School and a childcare centre.

        •     Why have no heritage issues been addressed in the information on your website?

While the public website does not share Ventia’s assessment against environmental findings by the team, the Ventia planner has been liasing with the Shire of Irwin council planner and heritage teams of the Department of Planning, Lands and Heritage (DPLH) since the projects inception. 

As the Dongara exchange site was one of few non-residential premises within the search area not overlayed by a heritage item featured in a list, municipal inventory or state heritage register, the proposal is therefore considered immune from the Heritage Act 2018. Irrespective of this, Ventia and Amplitel have the obligation to ensure the siting and design of their new mobile phone base station is as sympathetic as possible to the surrounding heritage landscape of the Dongara Town Centre. 

Following earlier input from Ventia’s planner and in consideration of DPLH’s Historic Heritage division’s feedback regarding the preliminary design, the monopole has been re-positioned 2-3 metres within the exchange so that the structure will be visibly in between Dongara Public Library and the Dongara Port Denison Visitor Centre, when facing westwards towards the State Heritage registered premises façade from Waldeck Street. Please see Figure 2 of the photomontage on the public website for reference.

As such, the proposal will not materially affect any heritage item and is not anticipated to encroach largely over an adjacent heritage premise over another. The Ventia planning team at this stage will continue to encourage reasonable design modifications where possible to ensure visual impact from a finalised design is minimised as much as possible. 

•     It is not clear from your website, but it is implied that you will also be acting as the agent for Telstra as well as the Shire. How will the community be assured that your consultations will be independent and have integrity if you will be acting on behalf of both the developer/proponent and the local decision maker?

Please note that neither Amplitel or Ventia can act on behalf of local, state and federal consent authorities. Should a development application be submitted with the Shire of Irwin for the proposal, the Shire of Irwin will be the decision maker as to whether the works can be approved, conditionally approved, or rejected. The Shire of Irwin would also typically conduct their own consultation over the assessment period prior to any community and council meetings that might follow before a verdict is reached.

We understand that you have expressed a number of concerns, particularly with the location of the proposed base station, its anticipated visual impact, affect on heritage listed places and structural integrity. As such, we provide you with the following information.

During the preliminary stages of the project, a number of sites were investigated for their potential to host the proposed telecommunications facilities. Following a review of candidate sites between a team of specialists, many were discounted on a number of grounds, such as unfavorable land zoning, disinterested landowners, site access and radio frequency coverage challenges, heritage constraints and also proximity to community sensitive places of interest such as schools and childcare centres.

While carriers are generally encouraged to co-locate new facilities on to existing buildings and structures before opting for proposing a new tall structure, in this instance there were no available structures of a sufficient height or structural integrity within the coverage area that could accommodate the proposed Telstra antennas. As a result, Amplitel have selected Dongara exchange as the prime candidate for a new greenfield structure.   

Amplitel consider this prime candidate to be the best suited site for a number of reasons. 

The site itself is an existing exchange, therefore it is already visually associated with being a site for telecommunications facilities, housing an existing shelter and assets which will facilitate the development, with fencing already established and driveway access for larger vehicles. 

The site will also allow Telstra (and other carriers) to achieve its coverage objectives, improving reception within Dongara and urgently addressing currents gaps in cellular coverage. 

As Amplitel were also confined to a candidate search area radius of just a few hundred metres within Dongara, the prime candidate at 3 Armstrong Street successfully avoids residential zoning and is one of very few sites within the Shire of Irwin’s local planning schemes civic and town centre zone which is not intersected with a heritage item.

With regards to key objection points 2 to 5, Ventia and Amplitel can acknowledge the candidate search area for a new mobile phone base station proposal comprises many heritage items, especially within the Dongara Town Centre precinct. In order to provide 4G and 5G Telstra coverage to Dongara, it is highly unlikely that a new structure fit for this purpose could yield zero visual impact towards the heritage items. 

This proposal therefore aims to alleviate these impacts as much as possible using all applicable design measures necessary to ensure that the level of impact is within an acceptable range and strongly negated by an immediate and lasting benefit to the community which has been experiencing a prolonged lag in adequate local cellular coverage. The tall mast tower with yagi antennas at Dongara Police Station as an example intersects with the ‘Dongara School’ heritage item (place no. 12316) and may be considered acceptable today, despite playing no direct role in everyday cellular coverage for Dongara locals. 

As identified in key objections point 1 of the submission, section 2 Vision and Objectives of the 2017 Shire of Irwin Local Planning Strategy does call for the conservation of heritage and promotion of diverse tourism opportunities for the locality. The proposal’s provision of 4G and 5G services however, is also believed to strongly align with the strategy’s vision for housing, tourism and employment growth and diversity, along with increased hazard protection and safety. The Opportunities and Challenges section of the LPS’s executive summary notes ‘The Shire will also benefit from improved hard and soft infrastructure (such as telecommunications) to attract business and industry, and provision of sufficient community infrastructure to support population growth.’

The structural integrity of amplitel towers in close proximity to heritage listed buildings are a genuine concern. Amplitel and Telstra are reputable infrastructure and services providers who diligently adhere to national building standards along with the Australian Radiation Protection and Nuclear Safety Agency standards adopted by the Australian Communications and Media Authority. Following geotechnical investigations and structural assessment at this site, both will be able to ascertain the most appropriate extent of concrete foundation, strengthening measures and construction methodologies necessary for the structure. This unmanned base station will then typically require 2-4 maintenance visits annually. 


Amplitel and Ventia recognise the importance of notifying and consulting with the community and we appreciate the time you have taken to voice your concerns about this proposal.  

Amplitel maintain that the proposed facility at the exchange at 3 Armstrong Street, represents the most appropriate location for the siting of this telecommunications facility, having regard for the coverage requirements and any associated impacts on the surrounding environment. 

We believe we have addressed your submission, however If you wish to discuss any aspect of the above, please do not hesitate to contact us on (02) 6124 4423.

Kind regards,

Consultation Team


Ph: (02) 6124 4423


Postal address: Level 8, 80 Pacific Hwy, North Sydney NSW 2060

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