Mrs Annette Feeney Programme Officer Babergh and Mid Suffolk District Council Endeavour House Russell Road Ipswich IP1 2BX
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Ministry of Defence Building 49, 1st floor Kingston Road Sutton Coldfield West Midlands B75 7RL United Kingdom Telephone [MOD]: 07970171173 E-mail: [email protected] Mrs Annette Feeney Programme Officer Babergh and Mid Suffolk District Council Endeavour House Russell Road Ipswich IP1 2BX By E-Mail only 25th May 2021 Dear Mrs Feeney Babergh and Mid Suffolk Joint Local Plan Examination Hearing (Regulation 24) I write regarding the proposed examination hearing for the Babergh and Mid Suffolk Joint Local Plan. The MOD wish to make a representation on Matter 8 within the Examiners Matters and Questions. Matter 8 Healthy Communities and Infrastructure Policies of the Babergh and Mid Suffolk Joint Local Plan Examination Matters and Questions, refers to several policies including specifically LP30 Open Spaces. The MOD wish to comment on the designation of land for Open Space within LP30 for Wattisham as identified within the Mid Suffolk District Council Place Maps and Policies (Wattisham Airfield) page 485. Wattisham Station lies within Babergh and is home to the Army Air Corps and Joint Helicopter Command (JHC) it remains an Operational defence site of critical importance to the National Defence interests. The MOD wish to comment on Question 8.2 specifically reflecting on policy LP30: “Policy LP30 - Designated Open Spaces 1. The total or partial loss of designated open spaces (as defined on the Policies Maps) may be permitted where: a. The development will support the enjoyment and functionality of the space, be sensitive to its character and function and would not result in detrimental impacts on local amenity or distinctiveness; b. The space is demonstrably no longer performing a role as a functional or visual public amenity, or is surplus to requirements; c. An alternative space of equal or greater quality, accessibility and quantity can be provided to serve the communities’ needs; or d. The development is for alternative sports and recreation provision, and the applicant can evidence that the benefits of the new provision clearly outweigh the loss of the current or former use. e. Proposals improve the biodiversity interest of designated open space, including as part of wider ecological networks, and improve accessibility for all. 2. Developments in excess of 1 hectare will be required to provide on-site open space provision to meet identified needs/deficits, unless there is a Council preference to make improvements to existing open space within the locality in an equally or more accessible location than the proposed development. 3. Open space provision is to be provided in line with the open space standards identified in the Open Space Assessment (as amended).” Question 8.2 a) Are the requirements of the policy clear, justified and would they be effective? I would agree the policy is clear and justified based on the results of the Open Space Assessment Study (2019) showing a deficit in designations. However, whilst the MOD understands the need to designate and allocate land as open space for community interests. MOD land has been designated as open space this being a sports field within the airfield boundary used purely by MOD employees only and is not available for public use or accessible to the public. The second parcel of land The Spinney is located within Service Family Accommodation and again is used purely by these occupiers. There is no access for the public to use this space. 8.2 b) Is part 2 of the policy in particular consistent with national policy? On what basis was threshold of 1ha set and is this reasonable? In response to the first part of this question, generically the policy meets the national criteria. It is the designation of MOD land for Open space that does not meet the requirements of planning policy with specific regard to paragraph 97 Open Space and Recreation: “97. Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless: a) an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or b) the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or c) the development is for alternative sports and recreational provision, the benefits of which clearly outweigh the loss of the current or former use” and paragraph 100 of the National Planning Policy Framework 2019 (NPPF) sets out the criteria for the designation of Local Green Space as follows: “100. The Local Green Space designation should only be used where the green space is: a) In reasonably close proximity to the community it serves; b) Demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and c) Local character and is not an extensive tract of land.” The sports field within the station boundary is purely for operational requirement and does not fall within proximity to the local community nor is it accessible to the community it is used for the physical training of operational staff, ensuring our personnel meet their fitness targets. The play area within the military service family accommodation is highly transient in nature and access to the site is highly restricted. In MOD’s view it could not be considered of ‘local significance’. Taking the above into consideration supports the MOD concerns and justification for the removal of the land parcels from designation. Furthermore, as an Operational site Wattisham station is in exclusive military use and designation as Open space would be directly at odds with existing National Policy within Para 95 of NPPF (2019) which reflects the need to maintain operational sites for defence purposes stating; “95. Planning policies and decisions should promote public safety and take into account wider security and defence requirements by: b) recognising and supporting development required for operational defence and security purposes, and ensuring that operational sites are not affected adversely by the impact of other development proposed in the area” The designation of the site as open space is at odds with para 95 of the NPPF, failing to take into account the overarching military use of the site and the requirement to take into account wider security and defence requirements. Finally, in response to 8.2.c) Does the policy take appropriate account of viability? I refer to the above and state the designation of MOD land for Open Space and the constraints of the policy LP30 and the conditions of Open Space and Recreation within para 97. and Local Green Space within para 100 of the NPPF (2019) the MOD considers the land allocations do not meet the basic conditions required. This would also undermine military use of the site. To summarise, whilst the MOD in principle have no concerns with the planning policy this should only be applied to appropriate parcels of land. The designation of military land as open space is wholly inappropriate, and MOD seek the removal of land parcels within Wattisham airfield. Should you have any queries regarding the above, please do not hesitate to contact me. Kind Regards Louise Dale Town Planner DIO Estates .