Ministry of Defence Building (01/D/06) Kingston Road Sutton Coldfield West Midlands B75 7RL

Telephone [MOD]: 07970171173 E-mail: [email protected]

West District Council College Heath Road, Mildenhall, Suffolk IP28 7EY

By E-Mail only 15th Dec 2020

Dear Sir or Madam,

West Suffolk Issues and Options Consultation

The Defence Infrastructure Organisation (DIO) on behalf of the Ministry of Defence (MOD), welcomes the opportunity to respond to the above consultation. The MOD has significant land interests within the District including RAF Lakenheath, RAF Mildenhall, RAF Honington and RAF Barnham Camp. DIO has reviewed the consultation document and would like to comment as follows:

On reading Part 1 Development Spatial Strategy with regards to the distribution of growth we would have concerns if development were to impact adversely on MOD establishments. The MOD would like to see recognition of, and support for, Defence related development within the new local plan. This would accord with paragraph 95 of the National Planning Policy Framework, which states:

“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.”

On reading Part 2 Local Issues, The MOD supports the recognition of the presence of the MOD within the West Suffolk District Authority area. United States Visiting Air Force (USVF) /RAF Lakenheath and RAF Mildenhall are designated as ‘Core Sites’ which means that they have a long-term enduring future for Defence. It is important to note that USVF/RAF Mildenhall will be retained to align with USVF requirements.

In line with the National Planning Policy Framework (NPPF)i it is important that planning authorities and development plans recognise that MOD Establishments are of strategic military importance to the UK. As such operational development on MOD establishments should be supported.

In turn, due to the need to maintain operational capabilities, development in proximity of MOD Establishments should be required to demonstrate that they align with the ‘agent of change’ principle found in paragraph 182 of the NPPFii. As such third-party development should provide adequate mitigation from MOD activities, in particular noise. It is therefore suggested that emerging development plans include a specific policy to address those needs which could be worded as follows;

POLICY Military Establishments: New development at military establishments that helps enhance or sustain their operational capability will be supported. Redevelopment, conversion of change of use of redundant MOD sites and buildings will be supported. Non-military or non-defence related development within or in the areas around a MOD site will not be supported where it would adversely affect military operations or capability, unless it can be demonstrated that there is no longer a defence or military need for the site.

West Suffolk Council will be aware of the MOD’s commitments to bring forward proposals to reduce its built estate, as part of those proposals sites could be declared as surplus. Due to the unique challenges of the disposal of surplus military land MOD seeks policies within local plans where land disposals are likely. Such a policy should recognise the challenges of former MOD sites which reflect their brownfield nature as well as their unique constraints. Such policies have been adopted elsewhere in development plans across the UK.

The MOD wish to comment on Barnham village which has a military presence at RAF Barnham Camp. RAF Barnham camp was referenced as surplus to requirements within the published “A Better Defence Estate” (2016) and forms part of the MOD disposal programme, being available in 2022. The MOD would wish to engage with West Suffolk to consider favourable development at this site while recognising the adjacent ecological designations. A call for sites submission will be lodged as part of the current local plan consultation.

Part 1 and 2 of the Issues and Options consultation refer to climate change. It should be noted that the MOD has, in principle, no issue or objection to renewable energy developments. However, some methods of renewable energy generation, for example wind turbine generators or solar photo voltaic panels can, by virtue of their physical dimensions and properties, impact upon military aviation activities, cause obstruction to protected critical airspace encompassing military aerodromes, and impede the operation of safeguarded defence technical installations. In addition, where turbines are erected in line of sight to defence radars and other types of defence technical installations, the rotating motion of their blades can degrade and cause interference to the effective operation of these types of installations with associated impacts upon aviation safety and operational capability. It is requested that, where sites are designated for renewable energy generation or an overarching renewable energy policy is drafted, it is made clear that development should not restrict or otherwise compromise the operational capability of defence sites and installations.

Part 3 Site Allocations

It is recognised there are significant site allocations within Lakenheath, Brandon, and Mildenhall. However, the MOD military aviation noise contours surrounding RAF Lakenheath and RAF Mildenhall have been reflected as a potential constraint. It should be observed that the controls on levels of noise from MOD establishments are not the same as for other properties. These noise levels can vary significantly according to operational needs. It is therefore important to consider the possible impacts on proposed adjacent development of such noise and the need to incorporate appropriate mitigation (if possible). It would be good practice for Planning Authorities to consult DIO on all significant planning applications in accordance with the RAF Lakenheath and Mildenhall Noise contours The email address for such consultations is: [email protected]

It is important to note development next to MOD establishments should allow a 250m buffer for security. On reviewing proposed residential allocations for Mildenhall option WS141, WS420 and WS138 are located near the boundary of RAF Mildenhall. Most of the development within Mildenhall is also within the 72dB noise contour as mentioned above appropriate consideration is required if development is pursued in this area regarding noise from the airfield. The cost of providing appropriate mitigation against noise should also be considered in the viability of delivering these sites.

Another concern relates to safeguarding the Defence Infrastructure Organisation (DIO) Safeguarding Team represents the Ministry of Defence (MOD) as a statutory consultee in the UK planning system to ensure designated zones around key operational defence sites such as aerodromes, explosive storage sites, air weapon ranges, technical sites and meteorological radar sites are not adversely affected by development outside the MOD estate.

As required by Regulation 10A of the Town and Country Planning (Local Planning) () Regulations 2012, West Suffolk Council commenced a review of existing policy by July 2020, this review included examination of the Joint Development Management Policies Document against the context provided by the NPPF (2019). The Council determined that the existing document demonstrated a high level of compliance with the national planning policy requirements and as such the Joint Development Management Policies Document will remain in use.

There is concern that the adopted and saved Development Management policies do not make explicit that compatibility with designated safeguarding zones would be a material consideration where applications are being considered. It is acknowledged that paragraph 95 of the National Planning Policy Framework set out this requirement and that this is replicated and detailed through the Town and Country Planning (Safeguarded Aerodromes, Technical Sites and Military Explosives Storage Areas) Direction 2002 (Circular 01/2003) as well as the directions attached to specific safeguarding designations.

West Suffolk contains several safeguarded sites which include RAF Honington, RAF Lakenheath, and RAF Mildenhall. The Council will be aware that a substantial part of the council’s area of interest is washed over by safeguarding zones and their attendant directions. On that basis, and in the interest of providing as much information as possible to developers, it is requested that the area and site specific constraints and opportunities sections of the Local Plan (as contained within the Part three: Settlements section) reflect the presence of safeguarding zones and make clear that applications will be subject to assessment to ensure that no detriment to operational capability results from the development of a given site.

I hope all the above is clear, however should you require any further clarification or information on the points raised, please do not hesitate to contact me.

Yours faithfully,

Louise Dale Town Planner Estates