Other

ID sylw: 107020

Derbyniwyd: 06/03/2025

Ymatebydd: Ministry of Defence

DTC RESPONSE:

Figures 5 and 6 within the plan provide an overview of the plan’s spatial growth strategy options, setting out
proposed spatial growth strategy priority areas (Figure 5) and potential new settlements and strategic growth
locations (Figure 6). The MOD has concerns about the potential for significant growth / increase in
development in the vicinity of Kineton and the implications that this could have on national defence interests,
particularly in terms of the potential for noise complaints, disturbance, and impacts on safety, security, site
access / highways, and operational capability.
The MOD requests engagement with the Council in order to gain clarity on the level, type and extent of
development likely to come forward in this area, to be able to better understand the potential implications for
defence and how the plan will ensure protection of national defence interests, in accordance with Paragraph
102 of the National Planning Policy Framework (NPPF), 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’.
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A separate response was submitted by the MOD specifically related to the MOD Safeguarding concerns in the Kineton area (SG13):

The South Warwickshire Local Plan (SWLP) preferred options authority area contains an explosive
safeguarding zone that is designated to preserve the operation and capability of Defence Munitions
Kineton.
The review or drafting of planning policy provides an opportunity to better inform developers of the
statutory requirement that MOD is consulted on development that triggers the criteria set out on
Safeguarding Plans, and the constraints that might be applied to development as a result of the
requirement to ensure defence capability and operations are not adversely affected.
To provide an illustration of the various issues that might be fundamental to MOD assessment carried
out in response to statutory consultation, a brief summary of the safeguarding zone is provided below.
Depending on the statutory safeguarding zone within which a site allocation or proposed development
falls, different considerations will apply.
Statutory safeguarding zones are designated around Military explosives storage and handling sites, to
ensure that development and land uses will be compatible with MOD capability. Within these zones,
where applicable, requirements relating to the siting, design, and construction of buildings, or changes
to land use may apply.
The statutory explosives safeguarding zones that surround DM Kineton are defined as the yellow and
purple arcs on the current explosive safeguarding plan for DM Kineton.
There are two zones - the inner explosive zone, also known as the Inhabited Building Distance (IBD)
and outer explosive safeguarding zone, also known as the Vulnerable Building Distance (VBD).
Any buildings within this zone must be ‘non-vulnerable’ to blast effects, that is of robust construction, so
should an explosive event occur, the structure would not collapse or sustain damage that could cause
critical injury to the occupants. At the planning application stage, MOD would raise concerns with any
building/structure determined to be of ‘vulnerable’ construction. For potentially vulnerable construction,
there may be a requirement for a condition to be imposed on a consent for blast work analysis to be
carried out to demonstrate a buildings performance under prescribed blast loads. Of particular concern
within this zone are tall buildings (in excess of 3 storeys), light weight construction and large areas of
glazing. Developments and land use that directly support large gatherings of people outside can also
be of relevance to the management of explosives safeguarding requirements for this zone. The
introduction of renewable energy developments within the IBD and VBD would also need to be
compatible with explosives safeguarding requirements.
The MOD will object to development proposals which support people living, working and congregating
within the inner explosives safeguarding zone.
Strategic Growth 13 (SG13): Gaydon Lighthorne Heath Group has been identified as a location for
potential strategic growth and could accommodate South Warwickshire’s housing and employment
strategic needs. The MOD notes that further work will be undertaken, prior to publication of the
Regulation 19 Local Plan stage, to identify the sites that are proposed to be allocated and confirm the
development requirements for each proposed allocation.
The SG13 South-Western boundary area has a section that falls within the explosive VBD statutory
safeguarding zone. Any development of land occupying the MOD statutory explosives safeguarding
zones will need to be compatible with MOD explosives safeguarding requirements.
MOD recommend that future detailed policies for Strategic Growth 13 includes wording which
indicates that development should be designed to ensure that it would have no impact on the
operation or capability of defence sites or assets.
In addition, the MOD would wish to review and should be consulted on any development within the
statutory safeguarding zones that surrounds DM Kineton.

Other

ID sylw: 107021

Derbyniwyd: 06/03/2025

Ymatebydd: Ministry of Defence

DTC RESPONSE:

Section 4.10, Policy Direction 8 – Density
The MOD recognises the need for quality design within the planning system. However, there may be
occasions where specific operational or technical requirements of buildings and structures required for
defence purposes can restrict MOD’s ability to change the density of developments to meet local design
2
criteria. It is important therefore that local design codes are not too restrictive and that they recognise the need
for flexibility in such cases.

Other

ID sylw: 107022

Derbyniwyd: 06/03/2025

Ymatebydd: Ministry of Defence

DTC RESPONSE:

Section 6.1, Policy Direction 12 – Locations for employment growth
The MOD would like to see this policy provide recognition of, and support for, additional development at
existing sites providing employment in the South Warwickshire area, rather than focussing solely on new
locations for growth.

Other

ID sylw: 107023

Derbyniwyd: 06/03/2025

Ymatebydd: Ministry of Defence

DTC RESPONSE:

Section 6.7, Policy Direction 18 – Supporting rural employment and diversification
Similar to Policy Direction 12 above, the MOD would like to see this policy support additional development on
existing sites providing employment that are not within the Spatial Growth Priority Areas.

Other

ID sylw: 107024

Derbyniwyd: 06/03/2025

Ymatebydd: Ministry of Defence

DTC RESPONSE:
Section 6.9, Draft Policy H – Water efficiency
The MOD would like the policy to recognise that there are schemes similar to BREEAM, such as the Defence
Related Environmental Assessment Methodology (DREAM) and would request that the policy is amended to
refer to ‘BREEAM or equivalent’.

Other

ID sylw: 107025

Derbyniwyd: 06/03/2025

Ymatebydd: Ministry of Defence

DTC RESPONSE:

Section 8.2, Policy Direction 26 – Design codes
The MOD recognises the need for quality design within the planning system. However, there may be
occasions where specific operational or technical requirements of buildings and structures required for
defence purposes can restrict MOD’s ability to amend the design of developments to meet local design
criteria. It is important therefore that local design codes are not too restrictive and that they recognise the need
for flexibility in such cases.

Yes

ID sylw: 107026

Derbyniwyd: 06/03/2025

Ymatebydd: Ministry of Defence

DTC RESPONSE:

Section 9.1, Policy Direction 29 – Pollution
The MOD supports the inclusion of a reference within this policy direction to ensuring that new development
proposals do not have an adverse impact on existing operations. It is vital that the ‘agent of change’ principle
referenced in Paragraph 200 of the NPPF is applied to planning applications for noise-sensitive uses to
ensure that appropriate mitigation is put in place so that long-established development and uses are not
compromised as a result of noise complaints from new development. The MOD would like to see this policy
direction developed into a strongly worded policy which requires robust noise assessments for potentially
noise-sensitive developments, that take into account all relevant sources of noise.

Yes

ID sylw: 107027

Derbyniwyd: 06/03/2025

Ymatebydd: Ministry of Defence

A separate response was submitted by the MOD specifically related to the MOD Safeguarding concerns:

Within the Draft Policy D: Large Scale Renewable Energy Generation and Storage, the MOD notes
and welcomes the provision for Solar-Based and Wind-Based Energy Development. Wind energy
section 6.6 identifies. “Wind energy developments must minimise and/or mitigate amenity and
environmental impacts, including to: g) Avoid or adequately mitigate shadow flicker, noise and
adverse impact on air traffic operations, radar and air navigational installations; and. i) Ensure safety
in relation to the distance to power lines and buildings, the impact on air traffic, Ministry of Defence
operations, weather radar and the strategic road network.”
The MOD has, in principle, no objection to any renewable energy development, though some
infrastructure enabling renewable energy production, for example wind turbine generators can, by virtue
of their physical dimensions and properties, impact upon military aviation activities, cause obstruction to
protected critical airspace surrounding military aerodromes, or 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 potentially resulting in detriment to aviation safety and operational
capability. This potential is recognised in the Government’s online Planning Practice Guidance which
contains, within the Renewable and Low Carbon Energy section, specific guidance that both
developers and Local Planning Authorities should consult the MOD where a proposed turbine has a
tip height of, or exceeding 11m, and/or has a rotor diameter of, or exceeding 2m.
Additionally, it may be necessary in certain circumstances for MOD to require the removal of permitted
development rights, where the use of these rights introduces elements that would not be compatible with
MOD safeguarding requirements