Select Committee on Defence Minutes of Evidence


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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