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 defence equipment. 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. The Ministry of Defence and Defence Estates
have a statutory duty[7]
to have regard to National Park purposes. The government has clarified
that National Park purposes should be recognised as "an essential
consideration" in reaching decisions or undertaking activities
that have an impact on the Parks.[8]
3. It is essential that a thorough assessment
of the potential environmental impacts of new weapons is undertaken
before any decisions are made on where training with those weapons
might take place. This should help to identify the most appropriate
location for training with new weapon systems, rather than basing
such decisions on logistical requirements, which currently appears
to be the case.
4. CNP welcomes the Project Orientated Environmental
Management System (POEMS), which aims to manage the environmental
performance and liabilities of equipment and services throughout
the acquisition process. We suggest that this should be extended
to include an assessment of the potential environmental impacts
of training with new weapon systems, and that this should include
a specific assessment of any potential implications for National
Parks, in view of the statutory duty referred to in paragraph
2.
5. The training with the heavy artillery
systems AS90 and Multi Launch Rocket Systems at the Otterburn
Training Area is a good example of where an assessment of the
environmental impacts of training with new weapons systems should
have been undertaken prior to and in order to inform the decision
on where to train with them. Due to the nature of these weapons
systems, training with them at Otterburn required major infrastructure
works in a National Park, including the widening of 40km of road,
building of 46 new gun spurs, creation of 28km of new tracks,
the building of technical observation points, bridge refurbishment
and replacement and building a new central maintenance and accommodation
depot. These developments had a significant adverse impact on
the National Park, which could have been avoided had an environmental
assessment taken place prior to the decision on where to train
with these weapon systems. This could also have resulted in significant
cost savings, as the two lengthy public inquiries into training
with these weapons at Otterburn could have been avoided or reduced
in scope.
6. It is of concern that the MoD has resisted
complying with the policies which apply to its operations in National
Parks. Under Department of Environment Circular 12/96, Environmental
Act 1995, Part III: National Parks, a formal environmental impact
assessment is required for: "new, renewed or intensified
use of land within the National Parks for defence purposes".
However, the MoD does not appear to consider that any of its training
constitutes new, renewed or intensified use of land. This includes
cases where prima facie evidence exists to the contrary, for example
for newly procured weapon systems such as the Apache helicopter,
or for renewals of existing training, such as the proposed renewal
of the licence for training from the Duchy of Cornwall on Dartmoor.
7. In conclusion, it is vital that the environmental
impacts of training with new weapon systems are assessed prior
to making decisions on where to train with them. In 1998, when
the MoD procured the Apache helicopter, CNP wrote to the then
Secretary of State for Defence calling for an Environmental Impact
Assessment to be carried out for training with this new weapon.This
would have enabled environmental impacts to be identified at an
early stage, adverse impacts avoided and any residual impacts
mitigated. Such a sequential approach to identifying environmental
impacts is widely accepted as best practice. However, this did
not take place and subsequent training with Apache has had an
adverse impact on tranquillity and has generated concerns about
potential harm to ground-nesting birds.
8. 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.
11 October 2007
7 Section 11A of the 1949 National Parks and Access
to the Countryside Act, as amended by Section 62 of the 1995 Environment
Act. Back
8
Duties on relevant authorities to have regard to the purposes
of National Parks, AONBs and the Norfolk and Suffolk Broads, Defra
guidance note 2005. Back
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