Ministry of Defence Building 49 Kingston Road Sutton Coldfield West Midlands B75 7RL United Kingdom. Telephone: Facsimile:

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1 Ministry of Defence Building 49 Kingston Road Sutton Coldfield West Midlands B75 7RL United Kingdom Telephone: Facsimile: (0) (0) Mr Chris Rand Planning Department Forest Heath District Council College Heath Road Mildenhall Suffolk IP28 7EY 15th February 2017 Dear Mr Rand, Re: Planning Application Reference DC/15/1072/OUT - Outline Planning Application (All Matters Reserved Except for the Principal Means of Access) Development Providing up to 9,264m2 Gross External Area Floor Space (in Total) for Class A1, A3, A4, C1, D1 and Sui Generis Use. Such Development to Include up to 1,650 Dwellings; a Relief Road; Public Transport Facilities; Pedestrian, Cyclist and Vehicular Ways; Green Infrastructure; Groundworks; Drainage Works; Provision and/or Upgrade of Services and Related Media and Apparatus; Miscellaneous Ancillary Development and Associated Engineering and Other Operations on Land West of Brandon, Brandon, Suffolk I write, on behalf of the Secretary of State for Defence, in connection with the above planning application. At the outset, it is worth highlighting to the Local Planning Authority that the Defence Infrastructure Organisation (DIO) Safeguarding Department submitted a consultation response in connection with this planning application on 20 th July This consultation response should, therefore, be read in conjunction with the DIO Safeguarding response. Following a review of this Planning Application on Forest Heath District Council s Planning Register, the Secretary of State for Defence formally objects to this application, for the reasons identified within the contents of this letter, below. RAF Lakenheath, located approximately 1.73 kilometres (1.07 miles) to the south-west of the application site, is an MoD establishment which is occupied by the United States (U.S) Air Force (USAF) 48 th Fighter Wing. Notwithstanding this, located within relatively close proximity of the application site are other MoD establishments including RAF Mildenhall and RAF Feltwell (USAF sites), also located to the south-west and north-west of the application site respectively. RAF Lakenheath is currently an intensively operated USAF airbase. Fixed and rotary wing aircraft from RAF Lakenheath include the McDonnell Douglas F-15 (Variants E and C) Eagle fighter jet and the Sikorsky HH- 60G Pave Hawk helicopter. There are currently 72 no. F-15 and 5 no. HH-60G aircraft based at RAF Lakenheath. In addition, freight (Lockheed C-5 Galaxy and C130 Hercules, Boeing C-17 Globemaster III, chartered Boeing 747/767 and other aircraft) and tanker aircraft operate from RAF Lakenheath as necessary. Normal operational flying hours at RAF Lakenheath are 06:00 to 23:00 hours Monday to Thursday and 06:00 to 18:00 hours Friday, with no operational flying between 23:00 and 06:00 hours Monday to Thursday and 18:00 hours Friday and 06:00 hours Monday unless a waiver is granted to allow for operational flying outside of these hours, or when Higher HQ Directive Missions dictate a requirement to do so. For the Local Planning 1

2 Authority s information, during 2015 there were 9,528 sorties 1 flown from RAF Lakenheath. In addition, there were sorties flown in Please be advised that the operational flying activity at RAF Lakenheath is to meet the specific Defence operational requirements of the USAF at that specific point in time, in which case would not represent historic or possible future operational requirements for RAF Lakenheath. As the Local Planning Authority, you will be aware that RAF Lakenheath is not the subject of planning control with regards to restrictions which limit the nature of operations undertaken at the MoD establishment. It is unrestricted in respect of the nature of operational activity undertaken, days/hours of operation, noise limit restrictions, etc. In addition as you are aware, the USAF intend on intensifying the existing use of RAF Lakenheath from 2021 onwards when it is expected that 2 no. Boeing RC-135 aircraft (with the potential for this to temporarily increase to 4 no. when Higher HQ Directive Missions dictate a requirement to do so) will start to arrive at the site and become operational (in September 2021), and 2 no. Lockheed Martin F-35 Lightning II Squadrons (54 no. aircraft, including 6 no. spare aircraft) will start to arrive at the site and become operational (in 2022). The F-35 and RC-135 aircraft will operate alongside the F-15 E Variant and potentially the F-15 C Variant aircraft in which case there could potentially be a total of up to 132 no. fighter aircraft located at the airbase. If the F- 15 C variant is withdrawn, there will still be up to 112 aircraft, a 46% increase on current numbers. The 5 no. Sikorsky HH-60G Pave Hawk helicopters are expected to be relocated from RAF Lakenheath to Aviano Air Base in Italy by Furthermore, RAF Lakenheath will experience further intensification in future with the relocation of some aircraft or aircraft traffic from RAF Mildenhall, which is due for closure by 2023 (as announced on 8 January 2015). Please be advised that upon the intensification of RAF Lakenheath, as outlined above, this will result in the site operating on a 24-hour, 7-days a week schedule. With regard to the proposed development, it is important to acknowledge that the MoD supports the basic principle of new residential and commercial development within the District. However, in these circumstances, the MoD wishes to outline its concerns regarding this Planning Application. The Applicant proposes residential development of up to 1,650 dwellings, and commercial development of up to 9,264 m2 (and associated development) on the application site, land within relatively close proximity of RAF Lakenheath. In view of the nature of operational activity undertaken at RAF Lakenheath, and its close proximity to the application site, the MoD has significant concerns regarding the proposed development and its appropriateness for the application site. These concerns include: the potential noise levels that the future occupants of the proposed dwellings will be exposed to, and the potential impact of the proposed development on RAF Lakenheath; vibration; public safety; and highway concerns. These concerns will be explored in further detail below. Noise It is the MoD s contention that the proposed development would represent the introduction of sensitive receptors to the prevailing acoustic environment in the immediate locality of RAF Lakenheath. The operational flying activity undertaken at RAF Lakenheath will likely constitute a source of noise disturbance to the local area for a number of reasons. For example, fixed and rotary wing departure and recovery profiles, aircraft remaining operational pre/post landing (e.g. helicopters), engine ground runs, etc. would generate noise, possibly for prolonged periods of time, which would likely result in disturbance, of some description, to local residents. Please be advised, such activities produce a significant low frequency noise signature with a distinct dominant tone, which can be particularly disturbing. It is important to highlight to the Local Planning Authority that during 2015 the MoD received 51 no. complaints associated with operational activities associated with RAF Lakenheath. In 2016, the MoD received 161 no. complaints, which would suggest that the issue of noise has become a prevalent issue within the local and wider community over recent years. To date, in 2017, the MoD has received 12 no. complaints regarding aircraft at or from RAF Lakenheath. RAF Lakenheath lies to the south-west of the application site, located approximately 1.73 kilometres (1.07 miles) to the application site at its closest point. Runway 06/24 at RAF Lakenheath is approximately orientated south-west to north-east, located approximately 2.18 kilometres (1.35 miles) from the application site at its 1 A Sortie is a flight taking off and landing at RAF Lakenheath, i.e. at least two flights from/to/over the airbase. 2

3 closest point. Accordingly, it is expected that the application site will be subject to noise associated with instrument departure, and potentially recovery, profiles. Notwithstanding the above, the MoD s Noise Amelioration Scheme (Military): RAF Lakenheath and Mildenhall (USAF) Report (Report No. OEM/47/15 published 27 th October 2015) provides the latest noise contour levels for RAF Lakenheath and RAF Mildenhall, this is based on the latest available environmental noise study undertaken of both MoD establishments back in Whilst this information can be considered to be out of date, it highlights that parts of the application site sit within the 66 db or 72 db LAeq, 16 hour daytime noise contours around RAF Lakenheath. Accordingly, it is expected that parts of the application site would be, at a minimum, subjected to these levels of noise. (This information is about to be updated in relation to operations at Lakenheath. In view of the above, it is the MoD s contention that the issue of noise should represent a material planning consideration in respect of the Local Planning Authority s assessment of the proposed development. It is acknowledged that the Applicant originally submitted an Environmental Statement in support of this application. Chapter 9 Noise and Vibration, prepared by Sharps Redmore, is particularly pertinent in connection with the technical matter of noise. Following a review of this Chapter, the MoD has the following comments: Paragraph The National Planning Policy Framework (NPPF), March 2012 has been acknowledged in respect of the overarching policy associated with the technical matter of noise. With regard to the specific reference to relevant sections of the NPPF, Sharps Redmore has failed to acknowledge Paragraphs 109 and 120 of the NPPF, only referencing Paragraph 123. Paragraph 109 states that the planning system should contribute to and enhance the natural and local environment by: preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, water or noise pollution or land instability. Paragraph 120 goes on to state the following: to prevent unacceptable risks from pollution planning decisions should ensure that new development is appropriate for its location. The effects (including cumulative effects) of pollution on health or general amenity, and the potential sensitivity of the area or proposed development to adverse effects from pollution, should be taken into account. These paragraphs are materially relevant in respect of the Local Planning Authority s consideration and assessment of the proposed development. On the basis of the above, it is the MoD s contention that Sharps Redmore has afforded no consideration to Paragraphs 109 and 120 of the NPPF within their assessment. Notwithstanding the above, whilst Sharps Redmore have referred to Paragraph 123 of the NPPF, they do not appear to have attempted to assess the impact of the proposed development on nearby noise emitting operations including those at RAF Lakenheath, in line with bullet point 2 of Paragraph 123. Paragraphs 9.4 and The Noise Policy Statement for England (NPSE), 2010 has been acknowledged in respect of policy guidance associated with the technical matter of noise; however, Sharps Redmore have been particularly selective with regard to specific reference to relevant sections of the NPSE. The NPSE forms the overarching statement on noise policy for England (and hence is of direct relevance to the assessment of planning applications under the NPPF for developments in England only). It introduces three Effect Levels relevant to the assessment of noise. There are: NOEL No Observed Effect Level - This is the level below which no effect can be detected. In simple terms, below this level, there is no detectable effect on health and quality of life due to the noise; 3

4 LOAEL Lowest Observed Adverse Effect Level - This is the level above which adverse effects on health and quality of life can be detected; and SOAEL Significant Observed Adverse Effect Level - This is the level above which significant adverse effects on health and quality of life occur. The aim of the NPSE is to avoid all noise occurring at the SOAEL level and to minimise, as far as possible, all noise occurring between the LOAEL and SOAEL brackets. Paragraph Planning Practice Guidance - Noise (PPG-N) has been acknowledged in respect of policy guidance associated with the technical matter of noise; however, Sharps Redmore have been particularly selective with regard to specific reference to relevant sections of the PPG-N. Notwithstanding the above, in connection with the above bullet point, PPG-N introduces a fourth effect level which has not yet been updated in the NPSE: This is: UOAEL Unacceptable Observed Adverse Effect Level - This is the level above which extensive and regular changes in behaviour and/or an inability to mitigate the effect of noise leading to psychological stress or physical effects occurs. The PPG-N gives a noise exposure hierarchy based on the likely average response as detailed in the Table supporting Paragraph 005. In consideration of whether or not noise could result in significant concern, this is dependent on how a number of factors combine in any particular situation. These factors, amongst others, could include; The source and absolute level of the noise together with the time of day it occurs; For non-continuous sources of noise, the number of noise events, and the frequency and pattern of occurrence of noise; The spectral content and general character of the noise; Where applicable, the cumulative impacts of more than one source of noise; Consideration of mitigation measures to completely remove adverse internal effects; and In cases where existing noise sensitive locations already experience high noise levels, a development that is expected to cause even a small increase in noise may result in a significant adverse effect occurring even though little to no change in behaviour would be likely to occur. The PPG-N advises that whether or not the adverse effects of noise impact can be mitigated will be dependent on the type of development being considered and the character of the proposed location. It advises that for noise sensitive developments mitigation measures could include avoiding noisy locations. Paragraph Whilst Sharps Redmore refer to Local Planning Policy for Forest Heath District Council, specifically the saved policies of the Forest Heath Local Plan 1995 and the adopted Core Strategy (2010), they do not appear to have taken into consideration, or referred to, the Joint Development Management Policies document, in particular Policy DM2. Point h. of Policy DM2 states not site development where its users would be significantly and adversely affected by noise from existing sources, unless adequate and appropriate mitigation can be implemented; Point h. of Policy DM2 is materially relevant in respect of the Local Planning Authority s consideration and assessment of the proposed development. Accordingly, it is the MoD s contention that the statement made by the Agent is inaccurate, and misleading. Paragraph In view of the MoD s comments made in connection with Paragraph 9.7 (the above bullet point), the MoD disputes Sharps Redmore s statement. Policy & Legislative Context Section Sharps Redmore do not appear to have taken into consideration, or referred to, the following guidance in respect of the matter of noise: o The World Health Organisation Night Noise Guidelines for Europe (2009); o The World Health Organisation Guidelines for Community Noise (1999); o ISO 9613:1996 Acoustics - Attenuation of Sound During Propagation Outdoors ; o ISO 1996 Acoustics - Description, Measurement and Assessment of Environmental Noise ; o British Standard (BS) 8233:2014 Guidance on Sound Insulation and Noise Reduction for Buildings ; and 4

5 o BS :2003 Description and Measurement of Environmental Noise. Guide to Quantities and Procedures. Paragraph Sharps Redmore state the potential noise sources identified for assessment were discussed and agreed with Environmental Health Officers at Forest Heath District Council, in accordance with the Scoping Opinion. The noises sources listed within this Paragraph include noise associated with aircraft activity in connection with RAF Lakenheath. The MoD welcomes this approach. Notwithstanding the above, it is important to highlight to the Local Planning Authority that the MoD were not provided with an opportunity in which to comment on Sharps Redmore s proposed methodology and assessment in advance of the preparation of the Environmental Statement. Paragraph Sharps Redmore outline that vibration affecting the development will not be of any significant concern and vibration is not considered beyond the construction phase. Sharps Redmore fail to define what a significant concern constitutes. Furthermore, there appears to be no reasoning as to how this decision was reached. Accordingly, perhaps Sharps Redmore could provide further clarification in respect of this matter. Notwithstanding the above, Sharps Redmore continue to state It was discussed and agreed (see Scoping Opinion at Appendix 2.2) that baseline vibration surveys were not necessary. The MoD disputes this position for reasons that will be explored later, below. Paragraph Sharps Redmore outline that noise monitoring surveys were undertaken at a number of locations arcross the application site. Whilst they outline 3 no. noise monitoring positions were utilised, it is the MoD s contention that the number of noise monitoring positions utilised is insufficient in this case given that the relative size of the application site, and the scale of the proposed development. Paragraph 9.14 Sharps Redmore provide reference to BS 7445 within this Paragraph; however, it is suggested that their position is misleading. BS 7445 includes a requirement for information on the full results, procedures employed and prevailing conditions to be reported within a noise report. However, in this case, Sharps Redmore do not appear to have followed this guidance. Paragraph This paragraph outlines that a noise monitoring survey was carried out between 11 th and 13 th November Appendix 9.1 outlines that the survey took place between 18:00 hours on 11 th November 2016 and 16:55 on 13 th November 2016, a period of less than 48-hours it is very pertinent to note that no planned flying operations took place from RAF Lakenheath over the period November 2016 inclusive.. Paragraph of BS 8233:2014 states: Prediction of noise from airports is complex, though aircraft noise modelling software packages are available. Many airports periodically produce contours showing the noise exposure around the airport. Care is needed in interpreting these contours as they tend to show average exposure, taking account of the different modes of airport operation. This means that, on a particular day, the noise exposure at a particular location might be higher than implied by the contours, and consideration should be given to designing the building envelope for those operational days. These contours show the noise of aircraft departing from and arriving at an airport without the presence of shielding effects from buildings or topographical features. They also do not include the noise from ground operations such as taxiing, auxiliary or ground power units or engine testing. Where appropriate, these sources need to be considered separately. Where it appears that sound insulation treatment is necessary, noise exposure data should be obtained by on-site noise measurements, taking account of wind direction and runway usage. The survey duration of on-site measurements should be sufficient to take account of the various permutations of runway use that can occur, as certain flight paths might only be used under certain wind direction conditions. Where treatment of the building envelope is required to achieve internal design standards then site-specific measurements should be recorded, including provision for the frequency content of the noise (predominantly low frequency noise). It should be noted that for a jet aircraft the frequency content of noise when landing is generally different from that when departing. 5

6 Typically, landing jet aircraft procedure relatively higher levels of high-frequency noise and departing jet aircraft produce relatively higher levels of low-frequency noise. Despite its reference to commercial airports, there are similarities in respect of military airbases. It is, therefore, the MoD s contention that this quotation is particularly pertinent in this case. Notwithstanding the above, Section of BS :1991 states the long-term interval shall be chosen to take into account variations in source emission and sound propagation. For situations where variations of the received sound pressure levels are mainly determined by meteorological conditions, or where emitted noise varies in a complex manner, this time interval may be from one week to one year. Furthermore, Section of BS :1991 states NOTE - The long-term time interval should be chosen so that long-term variations in noise emissions are covered. It will frequently be of the order of several months. If the noise situation considered is restricted to a well- defined part of the year, for example the summertime with special activities, the long-term time interval may be restricted to that part of the year. In view of the above, it is the MoD s contention that the survey period identified above would represent an insufficient noise monitoring period. The MoD does not consider that such a short timescale would be representative of the operational activity undertaken at RAF Lakenheath throughout the calendar year. Accordingly, it is suggested that further noise monitoring surveys would be required, inclusive of sampling periods (day and night time) throughout the calendar year in order that measurements are taken in a range of environmental conditions. In doing so, this would likely ensure that the measurements would be an accurate reflection of fixed and rotary-wing aircraft activity undertaken at RAF Lakenheath. Paragraph 9.15 states the weather was cold and clear with light winds. Conditions were considered to be suitable for environmental noise monitoring. Sharps Redmore s conjecture in respect of the meteorological conditions at the time of the noise monitoring surveys is not supported by any detailed information on such conditions. Over the period in question only 3 hours match the description given, otherwise threwas rain mist and fog. Light winds were a feature throughout. The Noise Impact Assessment report does not appear to have taken into consideration the following guidance which relates to the conduct which meteorological measurements should be made: o o ISO 1996 Acoustics - Description, Measurement and Assessment of Environmental Noise ; and British Standard (BS) :2003 Description and Measurement of Environmental Noise. Guide to Quantities and Procedures. It is the MoD s contention that this guidance is material in this case. Paragraph 9.17 This Paragraph acknowledges that noise from aircraft activity associated with RAF Lakenheath is likely to be audible on the application site. Notwithstanding the above, this Paragraph makes reference to future road traffic noise; however, fails to make any reference to future air traffic activity associated with the future intensification proposals for RAF Lakenheath. Paragraph 9.18 Sharps Redmore state the noise surveys included aircraft noise generated by RAF Lakenheath and Mildenhall. Reference is also made to the published noise contours for those airfields as part of the baseline assessment. In respect of the noise contour levels for RAF Lakenheath and RAF Mildenhall, referred to by Sharps Redmore, these represent the former noise contours, i.e. those published prior to 27 th October Indeed, the MoD s Noise Amelioration Scheme (Military): RAF Lakenheath and Mildenhall (USAF) Report (Report No. OEM/47/15), published 27 th October 2015 (post the date when the planning application was submitted), provides the latest noise contour levels for RAF Lakenheath and RAF Mildenhall. (This information is about to be updated)accordingly, whilst Sharps Redmore referred to extant information at that time, this is no longer relevant. Therefore, it is suggested that the Noise Impact Assessment should be updated in order to take account of subsequent relevant noise information. 6

7 Paragraph 9.30 Sharps Redmore would appear to suggest that the WHO Guidelines for Community Noise 1999 is the most suitable guidance in respect to assessment methodology simply because it is the most comprehensive. The MoD disputes this conjecture. BS documents should not be disregarded where they are only relevant to part of the proposed development, instead they should be applied to that part of a proposed development for which they are applicable. In view of the above, BS 8233:2014 should be referenced in connection with new residential proposals, BS 4142:2014 should be referenced where new noise sources are to be located in the vicinity of existing housing, and Building Bulletin (BB) 93 should be referenced where the construction of new schools is proposed. Paragraph 9.32 and Table 9.2- Table 9.2 only provides reference to the residential elements of the proposed development. Paragraphs 9.33 to 9.45 The criterion presented within these paragraphs are derived from either BS 5228 or BB93. Accordingly, Paragraph 9.30 seems to be invalidated as BS 8233 does in fact cover all the aspects of the development whereby the criteria has been derived from the WHO Guidelines for Community Noise Paragraph 9.40 It is acknowledged that this planning application is in Outline, with the site layout and design forming Reserved Matters (subject to a future planning application assuming planning permission was to be granted in this case). Paragraph 9.43 Sharps Redmore have set out the guideline values, db LAeq,T that they consider to be applicable for private amenity spaces. It is the MoD s contention that any potential mitigation measures to reduce the sound pressure levels experienced on the application site/proposed development, as a result of the aircraft activity associated with RAF Lakenheath, within this acceptable level is unlikely to be achievable. Paragraph 9.57 Sharps Redmore state that the Local Planning Authority do not have any policy restricting development inside the 70 db contour (reference to the former noise contour, not the updated noise contour that was published 27 th October 2015). Whilst this position is indeed correct, it is the MoD s contention that the reasoning behind this position can be found within BS 8233:2014 which states contours show the noise of aircraft departing from and arriving at an airport without the presence of any shielding effects from buildings or topographical features. However, this statement does not mitigate the impact that the proposed development will have on RAF Lakenheath, which will be based on the locations of the contours and the number of dwellings and/or complainants within those contours. Paragraph 9.58 Sharps Redmore suggest that a Noise Model has been constructed utilising SoundPlan noise modelling software. Sharps Redmore have failed to outline the version number of SoundPlan utilised. It is unclear as to whether or not SoundPlan was used to model aircraft noise inclusively, or whether it was used solely in respect of road traffic noise. If SoundPlan was used to model aircraft noise, Sharps Redmore have failed to outline whether or not they have a license for the Aircraft Noise module which is a module of SoundPlan. Accordingly, the MoD would request clarification on these points from Sharps Redmore as to how they have accurately modelled noise from aircraft. Notwithstanding the above, following further investigations (noticeably a telephone conversation with Mr David Winterbottom at SoundPlan UK on 12 th August 2016), it would appear that this module is commercial airport, rather than military airbase, based software. Accordingly, the MoD wishes to question the appropriateness of this software in the first instance should Sharps Redmore have used this software. Paragraph 9.59 The MoD will comment further in respect of the matter of vibration later on within this consultation response. 7

8 Paragraph 9.71 The MoD s comments made in respect of Paragraph 9.58 are equally considered to be applicable in connection with this Paragraph. Paragraph The MoD s comments made in respect of Paragraph 9.18 are equally considered to be applicable in connection with this Paragraph. Paragraphs 9.75 to 9.77 In view of the MoD s comments in connection with this document as a whole, the MoD do not consider it appropriate at this time to comment further on these paragraphs of the document. Paragraphs to In view of the MoD s comments in connection with this document as a whole, the MoD do not consider it appropriate at this time to comment further on these paragraphs of the document, and the mitigation measures proposed by Sharps Redmore. Paragraphs to In view of the MoD s comments in connection with this document as a whole, the MoD do not consider it appropriate at this time to comment further on these paragraphs of the document. Paragraphs to (and Table 9.11) - In view of the MoD s comments in connection with this document as a whole, the MoD do not consider it appropriate at this time to comment further on these paragraphs of the document. General Comment REC Ltd do not appear to provide any contextual information in respect of RAF Lakenheath and its operational activity within the report. In view of the above comments, the MoD does not consider the Chapter 9 Noise and Vibration of the Environmental Statement report to be sufficient, and fails to fully address the issue of noise in connection with the operational aircraft activity associated with RAF Lakenheath. Accordingly, it is the MoD s contention that this Planning Application should be supported by a new/revised Environmental Statement. Following the submission of a new/revised Environmental Statement, the MoD would appreciate the opportunity to review its content and be afforded an opportunity in which to provide comments on this document. Notwithstanding the above, in the absence of this information, the MoD does not believe that the Local Planning Authority are currently in a position whereby they can fully consider the impact of noise in connection with the operational aircraft activity associated with RAF Lakenheath on the proposed development. In addition, it is the MoD s contention that the Applicant has, thus far, failed to demonstrate that the issue of noise has been sufficiently considered and can be satisfactorily mitigated accordingly; however, the MoD has concerns as to whether or not the issue of noise can be satisfactorily mitigated in any case. In summary of the above, it is the MoD s contention that it would not be unreasonable for the Local Planning Authority to refuse planning permission in this case. The DIO will leave the above for the Local Planning Authority s consideration. Notwithstanding the previous concern, the MoD has the following additional concerns in respect of the proposed development: Vibration In connection with the previous concern, Noise, the MoD has concerns regarding the potential for the proposed buildings to experience building vibrations as a direct result of air borne noise emissions from fixed and rotary wing aircraft activity in/around RAF Lakenheath. Noise emissions, associated with predominant low frequency sound components, can be transmitted through the structure of buildings causing vibrations of the primary components of the building, e.g. the vibration of floors, walls and windows, which in turn may result in the rattling of internal objects within the building. This effect can lead to an annoyance response in the occupants of the proposed dwellings/buildings. This annoyance can be a subjective response, which can be classified as: intrusion, distress, startle, disturbance, loss of control. Please be advised that the annoyance caused by vibration can often result in more disturbance than the noise itself. 8

9 In view of the above, it is the MoD s contention that the Applicant should undertake a full vibration assessment, in accordance with British Standard (BS) 6472:2008 (Part 1), in support of this planning application. Following the submission of the requested Vibration Assessment, the MoD would appreciate the opportunity to review its content and be afforded an opportunity in which to provide comments on this document. The DIO will leave the above for the Local Planning Authority s consideration. Public Safety RAF Lakenheath is located approximately 1.73 kilometres (1.07 miles) to the south-west of the application site. Whilst strict flying regulations and standards to ensure flight safety is maintained, flying activity is an inherently dangerous activity and is not without risk. At present the application site comprises agricultural land. Should planning permission be granted and the proposed development be built out, it is suggested that the occupants of the proposed dwellings/buildings will be at a greater risk of incursion in the event of an aircraft emergency (for example in the case of an aircraft suffering a bird strike or a mechanical fault, etc.) in comparison with the existing land use. Highways It is the MoD s contention that any proposals that would adversely impact upon the access to RAF Lakenheath should be refused planning permission, unless appropriate mitigation is provided by the Applicants of the proposed developments. The MoD would respectfully request that in the event of any mitigation proposals being put forward by the Applicant, to address highway concerns, that the MoD are afforded with an opportunity to review its content and to provide comments. This would be most appreciated. The DIO will leave the above for the Local Planning Authority s consideration. In view of the above, the Secretary of State for Defence formally objects to this Planning Application and in doing so respectfully request that the Local Planning Authority refuse planning permission for the proposed development. The DIO will leave the above for the Local Planning Authority s consideration. However, should you wish to discuss the above comments further, please do not hesitate to contact me. Yours sincerely, (Signed by electronic transmission) Mark Limbrick MRTPI Assistant Head, Environment and Planning Support On behalf of the Secretary of State for Defence Cc: Breckland Council 9