Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

BG/GI: Green infrastructure

Representation ID: 57480

Received: 10/12/2021

Respondent: Defence Infrastructure Organisation

Representation Summary:

Barton Road Riffle Range is a core defence facility that is proposed to fall within a strategic Green Infrastructure area. The range does not fall within the definition of Green Infrastructure. Designating the site as GI would introduce constraints and potential incompatible uses that could place unreasonable restrictions on how the MOD currently and in the future use the land. We would strongly recommend that the proposed boundary is amended to avoid the MOD ownership and that any GI boundary ensures GI compatible uses are sufficiently located so as not to constrain defence operations now or in the future.

Full text:

The policy seeks to identify the existing Green Infrastructure (GI) network and the strategic initiative intended to enhance it. It defines Green Infrastructure as the network of green spaces and routes, landscapes, biodiversity, water bodies and heritage which provide a range of benefits for people wildlife and the planet. It seeks to define 14 area-specific dispersed long term priority enhancements to the GI network – described as strategic initiatives that will include providing green space for people to enjoy. Strategic initiative 7 defines the West Cambridge green infrastructure buffer – Coton Corridor. This area is shown in figure 54 of the Great Cambridge Local Plan First Proposals, within which is a substantial Ministry of Defence Land holding which includes Barton Road Rifle Range. Barton Road Rifle range is a core defence facility, being only 1 of 3 ranges in the country where long distance practice firing can take place. It is extensively used for both sniper training and pre-deployment training. The MOD holdings extend outside of the operational range area and are held for operational defence purposes.

The NPPF at paragraph 92 explains that planning policies should aim to achieve healthy, inclusive and safe places which include the provision of safe and accessible (my emphasis) green infrastructure. The NPPF defines GI as a network of multi-functional green and blue spaces. The rifle range by its very nature is not a multi-functional green space and holds a very specific single purpose for the essential training of military personnel. The nature of military activities means the land is enclosed and public access is not permitted. Accordingly, the range is neither safe nor accessible to fall within the definition or functional purpose of GI.

It is important to recognise that the landholdings are required for the purpose of national defence and the planning process serves to protect such national infrastructure (as per paragraph 97 of the National Planning Policy Framework). The MOD’s land holding would not provide public recreation or multi-functional use to be considered GI. In addition, the proposed boundary to this designation does not follow easily identifiable and physical features on the ground for the boundaries of GI to be permanent and to endure throughout and beyond the plan period. For assistance a copy of the MOD ownership boundary has been included.

In accordance with paragraph 97 of the NPPF planning policies should promote public safety and defence requirements. It is fundamental that policies within the new local plan do not affect adversely the operation of this key training facility. Designating the site as GI would introduce constraints and potential incompatible uses that could place unreasonable restrictions on how the MOD currently and in the future use the land. We would strongly recommend that the proposed boundary is amended to avoid any of the MOD ownership and that any GI boundary ensures GI compatible uses are sufficiently located so as not to constrain defence operations now or in the future.

Attachments:

Comment

Greater Cambridge Local Plan Preferred Options

I/SI: Safeguarding important infrastructure

Representation ID: 57486

Received: 10/12/2021

Respondent: Defence Infrastructure Organisation

Representation Summary:

It is important that Bassingbourn Barrack is considered within the Greater Cambridge Local Plan for two principal reasons, firstly, ongoing operational defence needs and secondly, to protect operational defence land from being affected adversely from third party development proposed in the area. To ensure that the site delivers on its defence output there will be times when further developments are required at the site. It is important for national defence that the local plan is able to support the principle of such developments. The Council may consider it prudent within the new local plan to include a specific planning policy.

Full text:

The MOD has significant land interests within the area known as Bassingbourn Barracks.

National Planning Policy Framework
The Council will be aware of the requirements of paragraphs 97 and 187 of the National Planning Policy (NPPF) as quoted below:

“97. 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.

187. Planning policies and decisions should ensure…Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established.”

Operational land
Due to the presence of a significant operational defence site within the Borough, MOD is of the view that the new Local Plan should make greater reference to the site. It is noted that there is no mention of the site within the First Proposals. The MOD has an enduring requirement for the operational defence outputs delivered at Bassingbourn Barracks.

In line with the National Planning Policy Framework (NPPF) it is important that planning authorities and development plans recognise that MOD Establishments are of strategic military importance to the UK.

It is important that Bassingbourn Barrack is considered within the Greater Cambridge Local Plan for two principal reasons, firstly, ongoing operational defence needs and secondly, to protect operational defence land from being affected adversely from third party development proposed in the area. To ensure that the site delivers on its defence output there will be times when further developments are required at the site. It is important for national defence that the local plan is able to support the principle of such developments. In addition the MOD is committed to reducing its carbon footprint and will be looking to implement measures on site to achieve this.

It is essential for operational reasons that current and any future defence related activities can be undertaken at the site without any additional restrictions or controls. For example third party developments within the vicinity of the site have the potential to restrict operations of certain facilities and potentially requiring the implementation of additional engineered safeguards that together could constrain the ability to manage any future change and restricting the potential of future development requirements – all to the cost of the public purse and to the detriment of national defence preparedness. In such circumstances this operational defence site could be affected adversely by the impact of development proposed in the area, contrary to paragraphs 97 and 187 of the NPPF.

Accordingly, the Council may consider it prudent within the new local plan to include a specific planning policy for Bassingbourn Barracks that provides and protects both on-going and future operational defence needs for the site and serves to ensure that any neighbouring development does not adversely impact upon these operations or, in turn, would be affected by the established use. For example, the policy could include that proposals associated with defence and military operations at this existing site will be supported where they would enhance or sustain operational capabilities. Any policy should also ensure that for proposed non-military or non-defence related development within or in the areas of a defence or military site will not be supported where it would adversely affect military operations or capability.

Comment

Greater Cambridge Local Plan Preferred Options

I/SI: Safeguarding important infrastructure

Representation ID: 60040

Received: 13/12/2021

Respondent: Defence Infrastructure Organisation

Representation Summary:

Having reviewed the supporting documentation in respect of Greater Cambridge Shared Planning Local Plan
First Proposals Regulation 18 Preferred Options 2021 there are two areas of interest for the MOD.

One of these areas of interest is Cambridge Airport for which Statutory Aerodrome Height and Birdstrike
Safeguarding Zones have been designated. The statutory Aerodrome Height safeguarding zone serves to protect the airspace above and around aerodromes to maintain an assured, obstacle free environment for aircraft manoeuvre. This airspace is to be kept free of obstruction from tall structures to ensure that aircraft transiting to and from or circuiting the aerodrome can do so safely.

The other specific interest MOD have in the plan area is a new technical asset known as the East 2 WAM
Network which contributes to aviation safety by feeding into the air traffic management system in the Eastern
areas of England. There is the potential for development to impact on the operation and/or capability of this new
technical asset which consists of nodes and connecting pathways, each of which have their own consultation
criteria. Elements of this asset are located within and/or pass through the Greater Cambridge Local Plan area of
interest.

Attachments:

Comment

Greater Cambridge Local Plan Preferred Options

CC/RE: Renewable energy projects and infrastructure

Representation ID: 60042

Received: 13/12/2021

Respondent: Defence Infrastructure Organisation

Representation Summary:

Where development falls outside designated safeguarding zones the MOD may also have an
interest, particularly where the development is of a type likely to have an impact on operational capability.
Examples of this type of development are the installation of renewable energy generation systems and their
associated infrastructure. The MOD has, in principle, no issue or objection to renewable energy development
though 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. 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. Planning Practice Guidance published on the Gov.uk
website acknowledges the potential effect of wind turbine generators and directs developers and Local
Planning Authorities to consult the MOD where a proposed turbine has a tip height of or exceeding 11m or
has a rotor diameter of 2m or more.

Attachments:

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