Memorandum from the Council for National
Parks
1. The Council for National Parks (CNP)
welcomes the opportunity to submit written evidence to the Committee's
inquiry into the Scrutiny of Defence Estates. CNP is the national
charity that works to protect and enhance the National Parks of
England and Wales, and areas that merit National Park status,
and promote understanding and quiet enjoyment of them for the
benefit of all.
2. Military training is an activity which
demands various resource commitments. We suggest that estate rationalisation
across England and Wales provides an opportunity to reduce the
adverse impacts of military training on National Park purposes.
[5]This
process could usefully be informed by an independent review of
military training and National Parks.
3. The Ministry of Defence has a statutory
duty to have regard to National Park purposes, [6]including
during the process of estate rationalisation. We strongly recommend
that the Committee considers this duty in the context of circular
12/96[7]
to ensure that no new, renewed or intensified defence use of land
in National Parks results from the rationalisation of the defence
estate. Instead, the rationalisation process should be used by
government to scrutinise existing training, infrastructure and
resource commitments within National Parks in order to identify
opportunities to rationalise the estate whilst meeting current
training needs. This would help avoid situations such as that
at Dering Lines in the Brecon Beacons National Park, where a planning
application has been submitted for a change of use to allow military
training on a permanent basis. This is despite alternative training
facilities being available outside the National Park at Sennybridge
and the proposal appearing to emanate from an opportunistic land
purchase rather than a carefully considered case of military training
need.
4. To reiterate written evidence submitted
by CNP to the Committee during its inquiry into UK Defence: Commitments
and Resources, we consider that there are opportunities in certain
National Parks for a reconfiguration of military training areas
that could continue to meet current and future training needs
while saving resources. The most prominent example is in the Dartmoor
National Park where there is clear evidence[8]
of a large disparity between permitted use of land for live firing
training and the actual use for this purpose. Between 2002 and
2005, across the three Dartmoor ranges (Okehampton, Willsworthy
and Merrivale) an average of 530 days were permitted for live
firing each year but only an average of 274 days per year was
actually used. Live firing on the three ranges reduces public
access to the area, has an adverse impact on tranquillity and
damages the Park's landscape because of infrastructure such as
look out huts and moorland tracks.
5. However, it should be noted that live
firing also takes place within the Brecon Beacons, Pembrokeshire
Coast, Northumberland and the Peak District National Parks where
similar opportunities could be sought.
6. As part of the rationalisation process,
whilst identifying "anchor locations" and "seeking
to consolidate dispersed units onto its existing garrisons such
as Catterick," [9]CNP
suggests the Committee is mindful of the indirect adverse impacts
that this might have on National Parks, for example through troop
movements or pressure for housing.
7. Some military training activities, for
example, live firing and low flying, can have an adverse impact
on tranquillity, a key feature of the special qualities of National
Parks. The government has stated that "In those areas of
Parks that are tranquil, it is right that there should be a presumption
against activities that would undermine that tranquillity".[10]
The importance of tranquillity has also been recognised in research
recently published by the Campaign to Protect Rural England. [11]It
has prepared a tool to measure tranquillity which could be used
to inform decisions which may affect tranquillity, and could be
a useful aid to the rationalisation process.
8. The context for the Committee's inquiry
is set by a number of factors, including a strategic aim to "have
an estate of the right size ... of fewer, larger sites in the
UK and overseas, appropriately located ...", [12]considerations
of greater use of land abroad for military training requirements
and the aspiration of Defence Estates to rationalise UK training
operations (one recent example being Project Belvedere, the rationalisation
of the Joint Helicopter Command across the UK). This leads CNP
to maintain its recommendation[13]
that an independent review into military training and National
Parks should be undertaken. This would readily feed into existing
and future Defence Estate strategic plans to rationalise, which
themselves appear to be geographically unlimited, and would help
ensure that opportunities for rationalisation which would benefit
National Parks are given high priority.
9. We hope that this submission is helpful
to the Committee. Please do not hesitate to contact me should
you require clarification of any of the above or any further information.
10 May 2007
5 Section 5 of the 1949 National Parks and Access to
the Countryside Act, as amended by Section 61 of the 1995 Environment
Act. Back
6
Section 11A of the 1949 National Parks and Access to the Countryside
Act, as amended by Section 62 of the 1995 Environment Act. Back
7
Para 56, Circular 12/96, DoE, 1996. Back
8
Council for National Parks (2007) A Continuing Need? Military
Training and the Dartmoor National Park. Back
9
Page 17, Defence Estate Strategy 2006 In Trust and on Trust. Back
10
Page 25, Review of English National Park Authorities, Defra, July
2002. Back
11
http://www.cpre.org.uk/campaigns/landscape/tranquillity. Back
12
Page 7, Defence Estate Strategy 2006 In Trust and on Trust. Back
13
Council for National Parks (2007) Wild but Not Free: Military
Training in National Parks. Back
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