Q 5. Do you agree that new rights should be created that will enable MOD to develop more single living accommodation within the perimeter of their sites up to 25% of the existing floorspace for single living accommodation at a Defence site to support service personnel? Please give your reasons.
Q 6. Do you agree that new rights should be created that will enable MOD to develop other types of workspace up to 35% of the existing floorspace within the perimeter of their sites? Please give your reasons
Q7. Do you agree that supporting the redevelopment of Defence assets and Defence bases will provide an opportunity for new jobs in regions across the UK and will underpin Defence’s active role in communities across the UK? Please give your reasons
Q 8. Do you agree that the permitted development rights should be applied to the wide range of buildings needed by MOD? Please give your reasons
Q9. Do you agree that a greater percentage should apply for the workspace provision? Please give your reasons.
Q 10. Do you think restricting the location of development to 15m from the perimeter of the military site is sufficient or would a greater distance be better? Please suggest what would be an appropriate distance and give your reasons.
Q11. Do you think there is scope to raise the 4000 sqm footprint trigger for prior approval on the very largest operational military sites? Please suggest what would be an appropriate alternative limit, and give your reasons.
Q12. Do you agree that locating taller buildings together would be a good idea? Please give your reasons
Q13. Do you think that the exercise of the permitted development rights in flood risk zones should be subject to prior consultation? Please specify which bodies should be consulted.
Q.14. Do you think that the exercise of permitted development rights in relation to sites with land contamination should be subject to prior consultation? Please specify which bodies should be consulted.
Q 15. Do you think it is appropriate that only SSSI, Article 2(3) land, listed buildings and Scheduled Monuments should be excluded from the permitted development rights? Please give details if you think it is appropriate or if not.
LGA view
The government is proposing to introduce two new permitted development rights relating to Ministry of Defence (MOD) land and property. Firstly, a right that will enable the MOD to develop more single living accommodation (and its supporting infrastructure e.g. dining, welfare, storage facilities) within the perimeter of their sites by up to 25% of the existing floorspace for those facilities. Secondly, a right that will enable the MOD to develop other types of workspace up to 35% of the existing floorspace within the perimeter of their sites. We do not support these two proposals because they will impact on the immediate and surrounding areas and any changes therefore need go through the existing planning application process.
Any plans for expansion should be required to have been identified in a council’s Local Plan so that councils and communities can identify where there may be impacts on the wider community and their response. These proposals will, for example, impact on existing infrastructure that support and provide services to communities as well as the timing for delivery of other planned infrastructure. Additional impacts such as parking and transport access will also need to be considered as these changes could impact on the wider transport network. Councils will also want to ensure that new development supports their local climate change ambitions and supports environmental aspects such as biodiversity net gain.
We recognise that in an emergency situation there might be a justified need to introduce temporary permitted development rights to enable the quick mobilisation of new MOD infrastructure, similar to the way in which the temporary PDR allowed for emergency development by local authorities or health service bodies to respond to the spread of the Coronavirus. However, under normal circumstances the MOD should be considering planning timescales as part of its Defence infrastructure plans, so that the impact of development can properly be taken into account as part of a full planning application process.If the Government does decide to take the proposal forward then councils should have the ability to determine together with their communities whether a building can increase in size and if so, by how much, and to what extent.
The consultation document states that Defence also makes a significant contribution by providing local jobs. We agree that Defence may provide a level of employment to some local communities. However, as noted in our response to the Government’s recent consultation proposing the extension of PDR for other public service infrastructure, Defence does not provide the same community co-benefits for shared use that other public sector infrastructure such as schools, colleges and universities, and hospitals do. As with other public sector infrastructure, expansion of Defence infrastructure which may have an impact on the wider infrastructure network and local communities should be required to be consulted on through the existing planning process. Councils will need the ability to ensure that new development does not undermine national and local ambitions to achieve net zero and address climate change, whilst supporting biodiversity net gain and achieving wider environmental outcomes.
The consultation document states that estimates show that Defence infrastructure projects alone will support up to 100,000 jobs over the next 20 years. However, the Defence’s employment strategy is at odds with this claim, with an aim to continue to reduce its civilian workforce across its 570 sites throughout the UK and overseas.
The LGA supports the putting skills at centre stage, as noted in our On the Day Briefing for the Autumn Budget and Spending Review. The LGA supports the Government’s ambitions to level up the country and build back better by building back local. Investing in local places is one of the most powerful tools of the Government’s levelling up agenda. As outlined in the LGA’s briefing paper on levelling up, with adequate long-term resources and freedoms, councils can deliver world-class local services for our communities, tackle the climate emergency, and ensure all parts of the country are able to prosper in the future.
We also raised the point that national government has lacked a strategic and joined-up plan to drive local economies and empower local leaders to take effective action. Instead, national support for local growth has been characterised by a lack of coordination between departments and a complex framework of national funding and support. Previous LGA research found that £23 billion of public money was spent on growth, regeneration and skills, fragmented across 70 different national funding streams and managed by 22 government departments and agencies. More recently, Government’s new Plan for Growth has yet to demonstrate how it will connect an ambitious national plan with delivery on the ground.
Councils should have flexibility to determine with their communities which other types of areas the right should not apply to, such as Green Belts or areas of flood risk such as floodplains or flood zones. Should the Government go ahead with the proposals, then we would agree that PDR should be subject to prior approval in cases where land contamination is present.
All buildings will also need to adapt to increasing flooding. We previously recommended to Government that building regulations should be changed to include mandatory flood protection measures for new properties. These would require introducing measures like raised electrical sockets, fuse boxes, controls and wiring, sealed floors, and raised damp-proof courses. This can be co-ordinated with relevant government departments such as the Department for Environment, Food and Rural Affairs (DEFRA).
The LGA supports the proposals for modernisation of existing workspaces and the Defence estate, for example in relation to carbon emissions. We have welcomed the Government’s Heat and Buildings Strategy which sets out the Government’s plan to decarbonise housing and buildings as an essential component to the delivery of the UK’s legal requirements to achieve Net Zero. This objective is also linked to a range of opportunities for instance in creating jobs, supporting businesses, and the wider levelling up agenda.
As with other public sector infrastructure, expansion of Defence infrastructure which may have an impact on the wider infrastructure network and local communities should be required to be consulted on through the existing planning process. Additional impacts such as transport access to the local roading network will need to be considered as these changes could impact on the wider transport network.
Councils will need to be properly resourced for any additional burdens due to any of these proposals being taken forward. Planning fees also do not cover the true cost of processing planning applications, and taxpayers currently subsidise the cost at a rate of nearly £196million a year.