Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

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Comment

Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

Policy ST9: The Tendring Colchester Borders Garden Community

Representation ID: 12736

Received: 12/01/2026

Respondent: Defence Infrastructure Organisation Head Office

Representation Summary:

The strategic growth site, Tendring Colchester Borders Garden Community land allocated has
elements that fall within the East 2 WAM Network statutory safeguarding zone, where any
development or change of use will trigger a MOD statutory consultation requirement.

Full text:

I write to confirm the statutory safeguarding position of the Ministry of Defence (MOD) in relation to
Colchester City Council’s preferred options local plan regulation 18 consultation document.
The Defence Infrastructure Organisation (DIO) Safeguarding Team represents the MOD as a
statutory consultee in the UK planning system to ensure designated zones around key operational
defence sites such as aerodromes, explosives storage sites, air weapon ranges, and technical sites
are not adversely affected by development outside the MOD estate.
For clarity, this response relates to MOD Safeguarding concerns only and should be read in
conjunction with any other submissions that might be provided by other parts of the MOD.
Paragraph 102 of the National Planning Policy Framework (December 2024) requires that planning
policies and decisions take into account defence requirements by ‘ensuring that operational sites
are not affected adversely by the impact of other development proposed in the area.’ Statutory
consultation of the MOD occurs as a result of the provisions of the Town and Country Planning
(Safeguarded aerodromes, technical sites and military explosives storage areas) Direction 2002
(DfT/ODPM Circular 01/2003) and the location data and criteria set out on safeguarding maps
issued to Local Planning Authorities by the Ministry of Housing, Communities & Local Government
(MHCLG) in accordance with the provisions of that Direction.
Copies of these relevant plans, in both GIS shapefile and .pdf format are issued to Local
Planning Authorities by MHCLG. An assurance review was conducted by the MOD in 2023
which confirmed that, at that time, Local Planning Authorities held the most recent relevant
safeguarding data. Any subsequent updates to those plans were then issued by MHCLG. If
there is a requirement for replacement data, a request can be made through the above email
address.
The Colchester City Council’s preferred options local plan authority contains and is washed over by a
safeguarding zone designated to preserve the operation and capability of the East 2 WAM Network.
Eastern 2 WAM (Wide Area Multilateration) Network is a new technical asset, which contributes to
aviation safety by feeding into the air traffic management system in the Eastern areas of England.
There is the potential for development to impact on the operation and/or capability of this new
technical asset which consists of nodes and connecting pathways, each of which have their own
consultation criteria.
The review or drafting of planning policy provides an opportunity to better inform developers of the
statutory requirement that MOD is consulted on development that triggers the criteria set out on
Safeguarding Plans, and the constraints that might be applied to development as a result of the
requirement to ensure defence capability and operations are not adversely affected.
To provide an illustration of the various issues that might be fundamental to MOD assessment carried
out in response to statutory consultation, a brief summary of the relevant safeguarding zone is provided
below. Depending on the statutory safeguarding zone within which a site allocation or proposed
development falls, different considerations will apply.
• Technical assets that facilitate air traffic management, primarily radar, navigation, and
communications systems are safeguarded to limit the impact of development on their capability
and operation. The height, massing and materials used to finish a development may all be
factors in assessing the impact of a given scheme. Developments that incorporate renewable
energy systems may be of particular concern given their potential to introduce large expanses
of metal or electromagnetic interference, which may be a particular issue where solar PV
systems are developed, or moving surfaces which may be visible to and detectable by radar
systems such as the blades of a wind turbine.
In addition to the safeguarding zones identified, the MOD may also have an interest where
development is of a type likely to have any impact on operational capability. Usually this will be by
virtue of the scale, height, or other physical property of a development. Examples these types of
development include, but are not limited to:
• Any development that would exceed a height of 50m above ground level. Both tall (of or
exceeding a height of 50m above ground level) structures and wind turbine development
introduce physical obstacles to low flying aircraft.
• Development, regardless of height, outside MOD safeguarding zones but in the vicinity of
military training estate or property.
The strategic growth site, Tendring Colchester Borders Garden Community land allocated has
elements that fall within the East 2 WAM Network statutory safeguarding zone, where any
development or change of use will trigger a MOD statutory consultation requirement.
The MOD notes the provisions within Policies Policy NZ1: Net Zero Carbon Development and Policy
NZ4: Renewable Energy.
The MOD has, in principle, no objection to any renewable energy development, though some
infrastructure enabling renewable energy production, for example wind turbine generators or solar photo
voltaic panels can, by virtue of their physical dimensions and properties, impact upon military aviation
activities, cause obstruction to protected critical airspace surrounding military aerodromes, or impede the
operation of safeguarded defence technical installations.
Where turbines are erected in line of sight to defence radars and other types of defence technical
installations, the rotating motion of their blades can degrade and cause interference to the effective
operation of these types of installations potentially resulting in detriment to aviation safety and operational
capability. This potential is recognised in the Government’s online Planning Practice Guidance which
contains, within the Renewable and Low Carbon Energy section, specific guidance that both
developers and Local Planning Authorities should consult the MOD where a proposed turbine has a
tip height of, or exceeding 11m, and/or has a rotor diameter of, or exceeding 2m.
Solar PV development which can impact on the operation and capability of communications and other
technical assets by introducing substantial areas of metal or sources of electromagnetic interference.
Depending on the location of development, solar panels may also produce glint and glare which can
affect aircrew or air traffic controllers.
The MOD request in order to provide a broader representation of MOD interests, and to ensure
prospective developers are aware of the implications of developing within an area containing MOD
safeguarded assets , that any emerging policy makes clear that, where an MOD assessment
indicates that a development would have a detrimental impact on the operation and capability of
defence assets or sites, that such an application would be refused or that conditions may be
attached to any consent that might be issued which may include the removal of permitted
development rights.
I trust this clearly explains our position on this update. Please do not hesitate to contact me should
you wish to discuss or clarify any issue raised in this letter.
C Waldron
Chris Waldron
DIO Assistant Safeguarding Manage

Comment

Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

Policy NZ1: Net Zero Carbon Development (in operation)

Representation ID: 12739

Received: 12/01/2026

Respondent: Defence Infrastructure Organisation Head Office

Representation Summary:

Solar PV development which can impact on the operation and capability of communications and other
technical assets by introducing substantial areas of metal or sources of electromagnetic interference.
Depending on the location of development, solar panels may also produce glint and glare which can
affect aircrew or air traffic controllers.

Full text:

I write to confirm the statutory safeguarding position of the Ministry of Defence (MOD) in relation to
Colchester City Council’s preferred options local plan regulation 18 consultation document.
The Defence Infrastructure Organisation (DIO) Safeguarding Team represents the MOD as a
statutory consultee in the UK planning system to ensure designated zones around key operational
defence sites such as aerodromes, explosives storage sites, air weapon ranges, and technical sites
are not adversely affected by development outside the MOD estate.
For clarity, this response relates to MOD Safeguarding concerns only and should be read in
conjunction with any other submissions that might be provided by other parts of the MOD.
Paragraph 102 of the National Planning Policy Framework (December 2024) requires that planning
policies and decisions take into account defence requirements by ‘ensuring that operational sites
are not affected adversely by the impact of other development proposed in the area.’ Statutory
consultation of the MOD occurs as a result of the provisions of the Town and Country Planning
(Safeguarded aerodromes, technical sites and military explosives storage areas) Direction 2002
(DfT/ODPM Circular 01/2003) and the location data and criteria set out on safeguarding maps
issued to Local Planning Authorities by the Ministry of Housing, Communities & Local Government
(MHCLG) in accordance with the provisions of that Direction.
Copies of these relevant plans, in both GIS shapefile and .pdf format are issued to Local
Planning Authorities by MHCLG. An assurance review was conducted by the MOD in 2023
which confirmed that, at that time, Local Planning Authorities held the most recent relevant
safeguarding data. Any subsequent updates to those plans were then issued by MHCLG. If
there is a requirement for replacement data, a request can be made through the above email
address.
The Colchester City Council’s preferred options local plan authority contains and is washed over by a
safeguarding zone designated to preserve the operation and capability of the East 2 WAM Network.
Eastern 2 WAM (Wide Area Multilateration) Network is a new technical asset, which contributes to
aviation safety by feeding into the air traffic management system in the Eastern areas of England.
There is the potential for development to impact on the operation and/or capability of this new
technical asset which consists of nodes and connecting pathways, each of which have their own
consultation criteria.
The review or drafting of planning policy provides an opportunity to better inform developers of the
statutory requirement that MOD is consulted on development that triggers the criteria set out on
Safeguarding Plans, and the constraints that might be applied to development as a result of the
requirement to ensure defence capability and operations are not adversely affected.
To provide an illustration of the various issues that might be fundamental to MOD assessment carried
out in response to statutory consultation, a brief summary of the relevant safeguarding zone is provided
below. Depending on the statutory safeguarding zone within which a site allocation or proposed
development falls, different considerations will apply.
• Technical assets that facilitate air traffic management, primarily radar, navigation, and
communications systems are safeguarded to limit the impact of development on their capability
and operation. The height, massing and materials used to finish a development may all be
factors in assessing the impact of a given scheme. Developments that incorporate renewable
energy systems may be of particular concern given their potential to introduce large expanses
of metal or electromagnetic interference, which may be a particular issue where solar PV
systems are developed, or moving surfaces which may be visible to and detectable by radar
systems such as the blades of a wind turbine.
In addition to the safeguarding zones identified, the MOD may also have an interest where
development is of a type likely to have any impact on operational capability. Usually this will be by
virtue of the scale, height, or other physical property of a development. Examples these types of
development include, but are not limited to:
• Any development that would exceed a height of 50m above ground level. Both tall (of or
exceeding a height of 50m above ground level) structures and wind turbine development
introduce physical obstacles to low flying aircraft.
• Development, regardless of height, outside MOD safeguarding zones but in the vicinity of
military training estate or property.
The strategic growth site, Tendring Colchester Borders Garden Community land allocated has
elements that fall within the East 2 WAM Network statutory safeguarding zone, where any
development or change of use will trigger a MOD statutory consultation requirement.
The MOD notes the provisions within Policies Policy NZ1: Net Zero Carbon Development and Policy
NZ4: Renewable Energy.
The MOD has, in principle, no objection to any renewable energy development, though some
infrastructure enabling renewable energy production, for example wind turbine generators or solar photo
voltaic panels can, by virtue of their physical dimensions and properties, impact upon military aviation
activities, cause obstruction to protected critical airspace surrounding military aerodromes, or impede the
operation of safeguarded defence technical installations.
Where turbines are erected in line of sight to defence radars and other types of defence technical
installations, the rotating motion of their blades can degrade and cause interference to the effective
operation of these types of installations potentially resulting in detriment to aviation safety and operational
capability. This potential is recognised in the Government’s online Planning Practice Guidance which
contains, within the Renewable and Low Carbon Energy section, specific guidance that both
developers and Local Planning Authorities should consult the MOD where a proposed turbine has a
tip height of, or exceeding 11m, and/or has a rotor diameter of, or exceeding 2m.
Solar PV development which can impact on the operation and capability of communications and other
technical assets by introducing substantial areas of metal or sources of electromagnetic interference.
Depending on the location of development, solar panels may also produce glint and glare which can
affect aircrew or air traffic controllers.
The MOD request in order to provide a broader representation of MOD interests, and to ensure
prospective developers are aware of the implications of developing within an area containing MOD
safeguarded assets , that any emerging policy makes clear that, where an MOD assessment
indicates that a development would have a detrimental impact on the operation and capability of
defence assets or sites, that such an application would be refused or that conditions may be
attached to any consent that might be issued which may include the removal of permitted
development rights.
I trust this clearly explains our position on this update. Please do not hesitate to contact me should
you wish to discuss or clarify any issue raised in this letter.
C Waldron
Chris Waldron
DIO Assistant Safeguarding Manage

Comment

Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

Policy NZ4: Renewable Energy

Representation ID: 12741

Received: 12/01/2026

Respondent: Defence Infrastructure Organisation Head Office

Representation Summary:

The Ministry of Defence acknowledges the Local Plan policies on net‑zero carbon development and renewable energy and raises no in‑principle objection to such schemes. However, it highlights that certain renewable energy infrastructure, including wind turbines and solar photovoltaic installations, can adversely affect military aviation, safeguarded airspace, radar systems, and defence technical installations. Turbines may interfere with radar through blade movement, while solar panels can cause electromagnetic interference or glint and glare affecting aviation safety. The MOD therefore requests that planning policy explicitly requires consultation and allows refusal or conditional approval where development would harm defence operations or capabilities.

Full text:

I write to confirm the statutory safeguarding position of the Ministry of Defence (MOD) in relation to
Colchester City Council’s preferred options local plan regulation 18 consultation document.
The Defence Infrastructure Organisation (DIO) Safeguarding Team represents the MOD as a
statutory consultee in the UK planning system to ensure designated zones around key operational
defence sites such as aerodromes, explosives storage sites, air weapon ranges, and technical sites
are not adversely affected by development outside the MOD estate.
For clarity, this response relates to MOD Safeguarding concerns only and should be read in
conjunction with any other submissions that might be provided by other parts of the MOD.
Paragraph 102 of the National Planning Policy Framework (December 2024) requires that planning
policies and decisions take into account defence requirements by ‘ensuring that operational sites
are not affected adversely by the impact of other development proposed in the area.’ Statutory
consultation of the MOD occurs as a result of the provisions of the Town and Country Planning
(Safeguarded aerodromes, technical sites and military explosives storage areas) Direction 2002
(DfT/ODPM Circular 01/2003) and the location data and criteria set out on safeguarding maps
issued to Local Planning Authorities by the Ministry of Housing, Communities & Local Government
(MHCLG) in accordance with the provisions of that Direction.
Copies of these relevant plans, in both GIS shapefile and .pdf format are issued to Local
Planning Authorities by MHCLG. An assurance review was conducted by the MOD in 2023
which confirmed that, at that time, Local Planning Authorities held the most recent relevant
safeguarding data. Any subsequent updates to those plans were then issued by MHCLG. If
there is a requirement for replacement data, a request can be made through the above email
address.
The Colchester City Council’s preferred options local plan authority contains and is washed over by a
safeguarding zone designated to preserve the operation and capability of the East 2 WAM Network.
Eastern 2 WAM (Wide Area Multilateration) Network is a new technical asset, which contributes to
aviation safety by feeding into the air traffic management system in the Eastern areas of England.
There is the potential for development to impact on the operation and/or capability of this new
technical asset which consists of nodes and connecting pathways, each of which have their own
consultation criteria.
The review or drafting of planning policy provides an opportunity to better inform developers of the
statutory requirement that MOD is consulted on development that triggers the criteria set out on
Safeguarding Plans, and the constraints that might be applied to development as a result of the
requirement to ensure defence capability and operations are not adversely affected.
To provide an illustration of the various issues that might be fundamental to MOD assessment carried
out in response to statutory consultation, a brief summary of the relevant safeguarding zone is provided
below. Depending on the statutory safeguarding zone within which a site allocation or proposed
development falls, different considerations will apply.
• Technical assets that facilitate air traffic management, primarily radar, navigation, and
communications systems are safeguarded to limit the impact of development on their capability
and operation. The height, massing and materials used to finish a development may all be
factors in assessing the impact of a given scheme. Developments that incorporate renewable
energy systems may be of particular concern given their potential to introduce large expanses
of metal or electromagnetic interference, which may be a particular issue where solar PV
systems are developed, or moving surfaces which may be visible to and detectable by radar
systems such as the blades of a wind turbine.
In addition to the safeguarding zones identified, the MOD may also have an interest where
development is of a type likely to have any impact on operational capability. Usually this will be by
virtue of the scale, height, or other physical property of a development. Examples these types of
development include, but are not limited to:
• Any development that would exceed a height of 50m above ground level. Both tall (of or
exceeding a height of 50m above ground level) structures and wind turbine development
introduce physical obstacles to low flying aircraft.
• Development, regardless of height, outside MOD safeguarding zones but in the vicinity of
military training estate or property.
The strategic growth site, Tendring Colchester Borders Garden Community land allocated has
elements that fall within the East 2 WAM Network statutory safeguarding zone, where any
development or change of use will trigger a MOD statutory consultation requirement.
The MOD notes the provisions within Policies Policy NZ1: Net Zero Carbon Development and Policy
NZ4: Renewable Energy.
The MOD has, in principle, no objection to any renewable energy development, though some
infrastructure enabling renewable energy production, for example wind turbine generators or solar photo
voltaic panels can, by virtue of their physical dimensions and properties, impact upon military aviation
activities, cause obstruction to protected critical airspace surrounding military aerodromes, or impede the
operation of safeguarded defence technical installations.
Where turbines are erected in line of sight to defence radars and other types of defence technical
installations, the rotating motion of their blades can degrade and cause interference to the effective
operation of these types of installations potentially resulting in detriment to aviation safety and operational
capability. This potential is recognised in the Government’s online Planning Practice Guidance which
contains, within the Renewable and Low Carbon Energy section, specific guidance that both
developers and Local Planning Authorities should consult the MOD where a proposed turbine has a
tip height of, or exceeding 11m, and/or has a rotor diameter of, or exceeding 2m.
Solar PV development which can impact on the operation and capability of communications and other
technical assets by introducing substantial areas of metal or sources of electromagnetic interference.
Depending on the location of development, solar panels may also produce glint and glare which can
affect aircrew or air traffic controllers.
The MOD request in order to provide a broader representation of MOD interests, and to ensure
prospective developers are aware of the implications of developing within an area containing MOD
safeguarded assets , that any emerging policy makes clear that, where an MOD assessment
indicates that a development would have a detrimental impact on the operation and capability of
defence assets or sites, that such an application would be refused or that conditions may be
attached to any consent that might be issued which may include the removal of permitted
development rights.
I trust this clearly explains our position on this update. Please do not hesitate to contact me should
you wish to discuss or clarify any issue raised in this letter.
C Waldron
Chris Waldron
DIO Assistant Safeguarding Manage

Comment

Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

1. Introduction

Representation ID: 12743

Received: 12/01/2026

Respondent: Defence Infrastructure Organisation Head Office

Representation Summary:

his response addresses Ministry of Defence safeguarding considerations relevant to the Local Plan, emphasising statutory requirements to protect defence assets under the National Planning Policy Framework. Colchester lies within a safeguarding zone associated with the Eastern 2 Wide Area Multilateration (WAM) network, a critical aviation safety asset. Development within these zones, including tall structures or renewable energy infrastructure, may adversely affect radar, communications, or navigation systems due to height, massing, materials, or electromagnetic interference. The submission highlights the need for clear policy wording to ensure early MOD consultation, inform developers of constraints, and allow refusal or conditioning of proposals where defence operational capability or aviation safety could be compromised.

Full text:

I write to confirm the statutory safeguarding position of the Ministry of Defence (MOD) in relation to
Colchester City Council’s preferred options local plan regulation 18 consultation document.
The Defence Infrastructure Organisation (DIO) Safeguarding Team represents the MOD as a
statutory consultee in the UK planning system to ensure designated zones around key operational
defence sites such as aerodromes, explosives storage sites, air weapon ranges, and technical sites
are not adversely affected by development outside the MOD estate.
For clarity, this response relates to MOD Safeguarding concerns only and should be read in
conjunction with any other submissions that might be provided by other parts of the MOD.
Paragraph 102 of the National Planning Policy Framework (December 2024) requires that planning
policies and decisions take into account defence requirements by ‘ensuring that operational sites
are not affected adversely by the impact of other development proposed in the area.’ Statutory
consultation of the MOD occurs as a result of the provisions of the Town and Country Planning
(Safeguarded aerodromes, technical sites and military explosives storage areas) Direction 2002
(DfT/ODPM Circular 01/2003) and the location data and criteria set out on safeguarding maps
issued to Local Planning Authorities by the Ministry of Housing, Communities & Local Government
(MHCLG) in accordance with the provisions of that Direction.
Copies of these relevant plans, in both GIS shapefile and .pdf format are issued to Local
Planning Authorities by MHCLG. An assurance review was conducted by the MOD in 2023
which confirmed that, at that time, Local Planning Authorities held the most recent relevant
safeguarding data. Any subsequent updates to those plans were then issued by MHCLG. If
there is a requirement for replacement data, a request can be made through the above email
address.
The Colchester City Council’s preferred options local plan authority contains and is washed over by a
safeguarding zone designated to preserve the operation and capability of the East 2 WAM Network.
Eastern 2 WAM (Wide Area Multilateration) Network is a new technical asset, which contributes to
aviation safety by feeding into the air traffic management system in the Eastern areas of England.
There is the potential for development to impact on the operation and/or capability of this new
technical asset which consists of nodes and connecting pathways, each of which have their own
consultation criteria.
The review or drafting of planning policy provides an opportunity to better inform developers of the
statutory requirement that MOD is consulted on development that triggers the criteria set out on
Safeguarding Plans, and the constraints that might be applied to development as a result of the
requirement to ensure defence capability and operations are not adversely affected.
To provide an illustration of the various issues that might be fundamental to MOD assessment carried
out in response to statutory consultation, a brief summary of the relevant safeguarding zone is provided
below. Depending on the statutory safeguarding zone within which a site allocation or proposed
development falls, different considerations will apply.
• Technical assets that facilitate air traffic management, primarily radar, navigation, and
communications systems are safeguarded to limit the impact of development on their capability
and operation. The height, massing and materials used to finish a development may all be
factors in assessing the impact of a given scheme. Developments that incorporate renewable
energy systems may be of particular concern given their potential to introduce large expanses
of metal or electromagnetic interference, which may be a particular issue where solar PV
systems are developed, or moving surfaces which may be visible to and detectable by radar
systems such as the blades of a wind turbine.
In addition to the safeguarding zones identified, the MOD may also have an interest where
development is of a type likely to have any impact on operational capability. Usually this will be by
virtue of the scale, height, or other physical property of a development. Examples these types of
development include, but are not limited to:
• Any development that would exceed a height of 50m above ground level. Both tall (of or
exceeding a height of 50m above ground level) structures and wind turbine development
introduce physical obstacles to low flying aircraft.
• Development, regardless of height, outside MOD safeguarding zones but in the vicinity of
military training estate or property.
The strategic growth site, Tendring Colchester Borders Garden Community land allocated has
elements that fall within the East 2 WAM Network statutory safeguarding zone, where any
development or change of use will trigger a MOD statutory consultation requirement.
The MOD notes the provisions within Policies Policy NZ1: Net Zero Carbon Development and Policy
NZ4: Renewable Energy.
The MOD has, in principle, no objection to any renewable energy development, though some
infrastructure enabling renewable energy production, for example wind turbine generators or solar photo
voltaic panels can, by virtue of their physical dimensions and properties, impact upon military aviation
activities, cause obstruction to protected critical airspace surrounding military aerodromes, or impede the
operation of safeguarded defence technical installations.
Where turbines are erected in line of sight to defence radars and other types of defence technical
installations, the rotating motion of their blades can degrade and cause interference to the effective
operation of these types of installations potentially resulting in detriment to aviation safety and operational
capability. This potential is recognised in the Government’s online Planning Practice Guidance which
contains, within the Renewable and Low Carbon Energy section, specific guidance that both
developers and Local Planning Authorities should consult the MOD where a proposed turbine has a
tip height of, or exceeding 11m, and/or has a rotor diameter of, or exceeding 2m.
Solar PV development which can impact on the operation and capability of communications and other
technical assets by introducing substantial areas of metal or sources of electromagnetic interference.
Depending on the location of development, solar panels may also produce glint and glare which can
affect aircrew or air traffic controllers.
The MOD request in order to provide a broader representation of MOD interests, and to ensure
prospective developers are aware of the implications of developing within an area containing MOD
safeguarded assets , that any emerging policy makes clear that, where an MOD assessment
indicates that a development would have a detrimental impact on the operation and capability of
defence assets or sites, that such an application would be refused or that conditions may be
attached to any consent that might be issued which may include the removal of permitted
development rights.
I trust this clearly explains our position on this update. Please do not hesitate to contact me should
you wish to discuss or clarify any issue raised in this letter.
C Waldron
Chris Waldron
DIO Assistant Safeguarding Manage

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