Dear Sir/Madam,
I refer to the Rochford District Council Spatial Options Consultation. As part of the Ministry of Defence (MOD), the Defence Infrastructure Organisation (DIO) is the
estate expert for defence, supporting the armed forces to enable military capability by planning, building, maintaining, and servicing infrastructure.

Background
The MOD has significant land interests within the district of Rochford, known as MOD Shoeburyness. MOD Shoeburyness is owned by the MOD and operated by
QinetiQ Ltd under a Long-Term Partnering Agreement (LTPA). MOD Shoeburyness offers a broad array of weapon and military equipment test, evaluation and training over land and firm tidal areas.
The Range covers a land area of 7,500 acres with 35,000 acres of tidal sands. MOD Shoeburyness consists of 21 operational firing areas and unique capabilities for Demilitarisation and Environmental Testing of Live and Inert stores. This unique terrain enables the over-water recovery of munitions up to a range of 22km, groundto-ground firings of up to 27km, long-range direct fire up to 3.5km, sea danger areas
up to 35km, and large radial safety areas for explosives trials.
MOD Shoeburyness is a centre of excellence for environmental testing of Ordnance, Munitions and Explosives (OME) and houses the largest Environmental Test Centre in the UK for the testing of Live stores as well as some unique demilitarisation facilities.
60% of MOD Shoeburyness’s 7,500 acres is made up of eight farms and 74 residential properties (let to civilians) in two hamlets and is required to support the operational areas and outputs through the provision of a safe area in which Test & Evaluation activities can be conducted. The site is only accessible through Landwick Gate which is a secured access point.
All access to MOD Shoeburyness is on a formally permitted basis (other than to the public highways and byways) through the Landwick Gate security gate.

National Planning Policy Framework
The Council will be aware of the requirements of paragraph 97 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.”

Spatial Options: Existing Open Space
It is acknowledged that there is an area of existing open space within MOD Shoeburyness defined within the current adopted plan and this area of land is proposed to continue to be defined as open space within the Spatial Options Report.
In studying this piece of land (to the west of Bridge Road), we wonder whether there has been a drafting error as this appears to be an isolated area of land unconnected to any existing community. Instead we question whether the intention was to define the fenced play area between no.s 4a and 19 Churchend?
It is important to note that due to access to the site being on a permitted basis only, it should be acknowledged that this fence play area would not be available for use by
the wider population.

Spatial Options: Other Open Space
It is noted on the interactive map that an area of land to the west of 2 Churchfields is proposed to defined as other open space within the new local plan and has been
informed by the Council’s emerging work on open spaces. The MOD does not consider this area of land meets the criteria to be considered as open space as
defined within the NPPF and National Planning Practice Guidance. This land is a grass field that is not subject to any regular mowing schedule by the landowner, there are no formal pathways or paraphernalia. Residents under their tenancy agreements are not permitted to access this area. It is noted that the existing fenced play area between no. 4a and 19 Churchend is within easy walking distance from the existing community.
Therefore, it does not appear to us that the land is demonstrably special to the local community, provides particular beauty or holds a particular local significance, has recreational value, tranquillity or a richness of wildlife to be defined as open space.

Spatial Options: Promoted sites
There are a number or parcels of land immediately abutting and in close proximity to the MOD boundary that are being promoted for development. The Council will be
aware of the provisions of The Town and Country Planning (safeguarded aerodromes, technical sites and military explosives storage areas) Direction 2002
(Circular 01/2003). Safeguarding zones have been designated at MOD Shoeburyness to safeguard its capacity as a military technical site/explosive storage
area and maps have previously been issued by Ministry of Housing Communities and Local Government to the Council. Within these designated areas the MOD is a
statutory consultee and would expect to be consulted on planning applications. For the avoidance of doubt please find attached the latest safeguarded areas (a copy of
the GIS data can be provided upon request). In accordance with Circular 01/2003 the outer boundary of safeguarded areas should be indicated on proposals maps accompanying local plans and the plan should state why the area has been safeguarded.
It is noted that a number of the promoted sites fall within the safeguarding zones and therefore development within this area could be at risk of harm from MOD activities.
In addition, potential development of these sites could require a change to MOD activities so that MOD can continue to be a good neighbour. This could include, as a
result of a third party development, restricting operations in certain facilities, requiring the implementation of additional engineered safeguards, constraining the ability to manage any future change and restricting the potential of future development requirements – all to the cost of the public purse. 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.
The Council may consider it prudent (considering paragraph 97 of the NPPF) to include a further Strategic Objective within Strategic Priority 4 to specifically
recognise and support 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 Council may also wish to propose a specific planning policy for MOD Shoeburyness 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, any 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. The MOD will be seeking to modernise buildings and facilities across the site to improve their energy efficiencies, ensure they are resilient to climate change, contribute to climate change objectives and for residential buildings make sure they are fit for modern living. It would be beneficial for any policy to support these environmental improvements. Any policy should also ensure that for any 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.

Spatial Options: Regional Parkland
Large parts of the proposed Regional Park includes land within MOD ownership. The South Essex Green and Blue Infrastructure Strategy (SEGBIS) says that Regional
Parks are lands reserved to protect and conserve areas in natural or modified landscapes but are also suitable for sustainable public recreation and enjoyment.
Due to the ongoing operational need of the estate and the associated activities the landholding would not be suitable for any public access over and above that
currently permitted by the existing public rights of way. The MOD is aware that part of the estate is either directly within or adjacent to Foulness SSSI, Foulness Ramsar
and Foulness SPA designated sites and recognise that restricted public access assists with conservation of these areas. The MOD is cognisant of its stewardship
obligations in regard to the management of these designated sites and it works closely with Natural England, the Environment Agency, tenant farmers, the RSPB, Foulness Area Bird Survey, and other members of the MOD Shoeburyness Conservation Group to ensure that key habitats and species on the site are monitored, maintained, and where appropriate, enhanced.
It is important to recognise that the landholding is required for the purpose of national defence and the planning process serves to protect such national infrastructure. The MOD’s land holding would not provide public recreation or enjoyment to meet the criteria of a Regional Park. In addition, the proposed boundary to this designation does not follow easily identifiable and physical features on the ground for the boundaries of the Regional Park to be permanent and to endure throughout and beyond the plan period. For assistance a copy of the MOD ownership boundary has been included. We would strongly recommend that the proposed boundary is
amended to avoid any of the MOD ownership.

Flood Zone
Whilst the site is within Flood Zone 3 it does have the benefit of a flood defence which would need to be considered within any planning applications within the area as mitigation.

I hope the above is of assistance and reflects the MODs position at the time of this letter. Should you need any further clarification please do not hesitate to contact me.
We would be pleased to be included within any further consultation events as the plan progresses