Pembrokeshire Against DARC Radar

Dear Planning Minister and Welsh Government Members,

While I write to you first and foremost in relation to the imminent urgency of the requirement for the DARC proposal at Cawdor Barracks in Pembrokeshire to be called in to Welsh Government (Pembrokeshire County Council reference 25/1101/PA), I would like firstly to offer my congratulations for your historic win in the 2026 Senedd election.

I share all of your hopes, expressed on behalf of Plaid Cymru, for a Wales defined by an era of compassion and optimism for the future.

As a matter of the utmost urgency, I would like to make three important requests of you today:

1. I strongly request that the Planning Minister heeds the request made by PARC for the DARC planning application to be called in to Welsh Government, on the basis of its national significance and infeasibility for the sole consideration of Pembrokeshire County Council (PCC)

2. I strongly request, given that the potential for the application to be called in has been delayed over the course of the Senedd election period, that all three of (a) a holding direction, if necessary, is immediately applied to the application for Welsh Ministers to have sufficient time to consider the call-in request, albeit that the case presented for calling in the application is clear-cut and strong; (b) a communication is made with Pembrokeshire County Council to clarify its planning timeline and ensure that a decision will be delayed at least until the next meeting of its Planning Committee, in order to develop a clear and well-understood timeframe within which the application will be called in; and (c) a senior Welsh Government Minister or person of authority within Welsh Government clarifies to Pembrokeshire County Council Welsh Government’s intention to call in the DARC planning application before the 20th of May, which is a safe statutory period within which the application is effectively on hold

3. I strongly invite the Planning Minister, with the DARC planning application having been called in, to conscientiously consider and concur with the planning case due to be presented by campaigners, in full and appropriate accordance with relevant planning law and a consideration of the national priorities of Wales, that DARC is a wholly unsuitable proposal for its proposed environment, and deny planning permission to the proposal

In support of the requests I have made, I offer the following points.

The first point is that the DARC planning application has been live since the 9th of April (a period of several weeks already). As a major planning application, the statutory period for LPA consideration is a maximum of 16 rather than the standard 13 weeks. However, there is to my mind concerning evidence that the applicant (the Ministry of Defence) has been accelerating the passing of the proposal to a great degree. The application was submitted the exact day its statutory consultation period ended, has been in development for three years (including a delay of at least seven months), and has involved extremely extensive documented communication with both PCC and multiple statutory consultees, all of which will be likely to be able submit their representations with little to no delay, as many such responses will have likely been long completed. An extensive US Space Force document confirms in addition that the fielding of DARC is being dramatically accelerated from a US perspective, many of its requirements and checks being down-scaled and shortened. The applicant’s submitted Planning Statement states, in accordance with these priorities, that the application should be ‘granted permission without delay.’

Such acceleration is, in my view, a sign that by far the best time to strike in calling in the application is either now or as early as possible, so that an application that is of clear national importance and outside of the scope or capability of PCC to properly decide can be considered by Welsh Government, avoiding the potentiality for an unpredictable decision arising from a scope of consideration devolved to a local planning authority that, in my view, lacks the appropriate national frame and references to best adjudicate upon the planning matters at hand.

The applicant submitted the application exactly a week before the Senedd’s Easter recess began and before the election was called, meaning that owing to the requirements of the Ministerial Code, a long period where it would have been impossible for Welsh Ministers to call the application in has characterised most of the planning period so far. I find this noteworthy, and while I cannot read the mind of the applicant, it is another fact that lends more weight to the level of urgency of calling in the application as a matter of first Government priority, even on the very first day on which it possible. I therefore urge the Welsh Government to move to call in the application, ideally before the 20th of May, apply a holding direction as necessary to facilitate this process, and communicate directly with PCC to inform them of the Government’s intentions, so as to make it absolutely clear that an application with the most dramatic imaginable global military and strategic consequences for Wales and the UK does not find the sole province for consideration in a single local planning authority.

The second point I offer is that an extensive argument for calling in the application has been made by local campaign group PARC Against DARC, an organisation that has primarily been responsible for the raising of awareness of the adverse impacts of DARC and the urgency with which it must be called in to Welsh Government. The document outlining these arguments can be read at www. parcagainstdarc .com / call-it-in .pdf (remove spaces in link).

While the document is comprehensive and referenced, the argument is, in my view, very simple: a radar array confirmed to have been optimised for missile defence (and therefore the capability of being used in targeting capable of effecting missile impacts in space), which is described as a ‘significant escalation’ by a source (a Global Times editorial) directly controlled by the Communist Party of the People’s Republic of China and also confirmed as being touted for inclusion in Trump’s Golden Dome by manufacturer Northrop Grumman’s Kevin Giammo (arguably the most controversial global-level US military proposal ever made), is a proposal of extraordinary global and international significance, and lies well outside of the remit for consideration of a Pembrokeshire-based local authority.

The third point I offer is that extensive argumentation against the proposed development on planning grounds has been made by PARC. As it is understood from questions posed to Welsh Government, the call-in process will involve the opportunity for comments to be submitted by concerned parties, and as such, PARC’s argumentation will in my view be centre stage in such a process. PARC’s planning objection, which is well over a-hundred-and-fifty-thousand words in length, is nearing completion, and already comprises a solid set of arguments. Should any Minister wish to read it early, I encourage them to contact PARC Against DARC at theteam @ parcagainstdarc .com (remove spaces in email).

With the planning application called in, I encourage Welsh Government to give conscientious consideration to all planning arguments made that highlight the proposed development’s many unacceptable adverse impacts for its proposed local and national environments. In accordance with these concerns, I strongly hope that Ministers will, in appropriate consideration of the facts, refuse permission to the development on a basis that is lawful, objective, resistant to appeal or judicial review, and based on an assessment that puts the interests of the optimal possible prosperity of Pembrokeshire, and Wales, at heart.

Many thanks for your consideration. I look forward to contributing to, and sharing with the new Government, a Wales with a bright future.

Dear Planning team,

I am writing voluntarily and as an individual to object to the DARC radar planning proposal. I have objections to the proposal on multiple grounds.

OBJECTION ONE: UNACCEPTABLE VISUAL IMPACT.

Two prior PCC studies (2015 and 2021) into the suitability of wind turbines on Cawdor Barracks have recommended against development on adverse visual impact grounds. The latter assessment would find that (a) DARC’s antennas’ heights are comparable to small wind turbines, and (b) only a very small number (3 to 6 at most) of small turbines might be acceptable, even then assuming they were not densely clustered. DARC, however, would involve 27 unmitigably erratically clustered structures as high as small turbines and on average 1178% greater in lateral and vertical visual volume each versus a turbine of the same height, far and away in excess of acceptability in these assessments.

PCC LCA 1 (Treffynnon) guidance advises against ‘over-intensification of existing developments such as at Cawdor Barracks, especially within the setting of the National Park,’ and to ‘Avoid intrusive skyline or upper slope developments such as wind turbines [and] caravan parks … especially in the National Park’s setting.’ DARC, being comparable to or higher-impact than these developments, would violate the LCA’s requirements. PCNPA LCA 13 (Brandy Brook), of ‘High susceptibility’, would also involve impacts ‘intervisible from a wide extent of this area,’ (ES Vol. 2 Chapter 9) and directly impact Grade I listed Roch Castle.

The applicant admits that 100% of the 33 assessed viewpoints are negatively impacted and 21% significantly negatively impacted (ES Vol. 2 Chapter 9, Table 9.15). I believe, however, that the applicant’s visual assessment submits visualisation evidence that employs demonstrable perspective (extension) distortion through panoramas that emulate wide-angle-like background object minimisations; systematically minimises the sensitivity of assessed human and other receptors; artificially narrows the scope of consideration of potential receptors; unjustifiably denies magnitude of change in multiple cases; and systematically minimises impacts to Landscape Character Areas, Seascape Character Areas and National Park Special Qualities, offering mitigations that are of no to negligible significance.

As a result of these assessment deficiencies, I believe that viewpoints 1-3, 5-6, 13-14 and 16 should be reclassified as of at least ‘substantial to very substantial’ adverse impact, and many other viewpoints should be increased by at least one level of severity of adverse impact.

Despite these deficiencies, the applicant’s visual assessments still admit that: operational constraints almost entirely prohibit the possibility of mitigation; the negatively impacted landscape is mostly uninterrupted and highly visible; the design form of the antennas would be ‘inconsistent with existing views’ (ES Vol. 2 Chapter 9); there is a lack of natural visual cover; residential impact would be substantial in all cases close to the site; tourism receptors would be net adversely impacted; 5 out of 6 NP Special Qualities would be adversely impacted; and the proposal would be visible over a wide ZTV both in and out of the National Park area.

These adverse impacts would necessitate an exceptional level of local economic benefit, and in my view there is neither any benefit, nor has the applicant demonstrated any.

OBJECTION TWO: SOCIOECONOMIC HARM.

The proposal, which in all cases and at any rate operationally and spatially requires the evacuation of the 14th Signal Regiment whether the applicant can possibly prove or know the Regiment’s move is certain in view of yet-undecided UK Defence Investment Plan review outcomes (which it cannot and has not), entails a substantial net cut of jobs of, in my estimation, 570-580 positions. The applicant’s ES also confirms that a substantial number of construction jobs would have to be non-local. As a result the applicant concedes even the claimed number of jobs would be of ‘low numbers’ and ‘not significant.’

An FOI release from the MOD, sent to St Davids City Council, confirms staff would be US personnel. The application gives no timeline as to the training of local staff, which enables no staff to be native locals.

There is evidence, for example in the form of case studies, that a proposal such as DARC’s spoilage of the area’s visual value is liable to dissuade some visitors. Damage to tourism interests can, in such cases, result in economic stagnation and eventual employment effects. In locations such as Edinburgh (Scotland), Mazandaran (Iran), Toulourenc Gorges (France) and Koh Lipe (Thailand), for example, adverse local development out-of-keeping with local character and priorities has, according to commentators, significantly negatively impacted socioeconomic quality of life.

Further, the economic shock generated by the substantial job loss would increase relative local dependency on the tourism sector, exacerbating labour flight, undermining local economic diversity and resilience, accelerating the worsening of socioeconomic inequality by the attraction of out-of-area economic actors with business models that emphasise shareholder profitability rather than local autonomy, and lead to adverse effects liable to disproportionately impact the proposed environment as a rural area facing a generalised trend of greater socioeconomic inequality.

In accordance, a majority of local tourism-centred businesses in the assessed environment have either officially opposed the development since mid-2024 or displayed anti-DARC flyers. These include most St Davids tourism businesses, and particularly Twr y Felin Hotel, Penrhiw Priory, Falcon Boats, Studio 6, The Peepal Tree, Etcetera, The Really Wild Emporium and The Mill Café (St Davids); Roch Castle (Roch); and Bay View Stores (Solva). Opposition has also been voiced by the organiser of Unearthed Festival.

OBJECTION THREE: NO MILITARY AND STRATEGIC CASE.

Given the applicant significantly acknowledges visual impact harms and that there would exist further harms such as those demonstrated, the applicant relies on alleged national-only benefits. I reject such claims, however, on the basis that the applicant’s almost non-existent evidence base for military and orbital surveillance concerns, which lack even dedicated chapters of their own, have demonstrated neither military nor strategic need for the proposal, let alone robustly.

DARC, which would cost nearly $9 billion according to the ES, dwarfs the entire worth of the Space Situational Awareness market itself at $1.8 billion. Given many analysts such as Mark R. Ackermann et al. have suggested that space traffic management requires less that more legacy systems like ground radar or telescopes are required but instead better integration and multilateral coordination between global states’ orbital data sets and space-based sensors (which are superior in any case), the applicant has provided evidence for no other argument than that DARC is a waste of investment versus other alternatives for one its claimed purposes.

Any claim as to DARC’s impact on space traffic management (STM) is rendered negligible to counterproductive by the facts that (a) an STM is impossible without multilateral coordination in any case; (b) any data produced by DARC is liable not to be shared, on the widely understood basis of undisclosed volumes of the US Space Force’s object tracking catalogue not being shared (including ‘some of the best data’ according to Gugunskiy et al.); (c) no legal obligations are considered to compel operators to abide by collision warnings under any existing regimes of international law in any case; (d) DARC cannot be shown to overcome the ‘cry wolf’ scenario wherein low probability collision warnings have the reverse effect on space safety of desensitising spaceflight operators to further collision warnings; (e) many satellites are not equipped with onboard thrusters or have the sufficient fuel budgets to conduct avoidance manoeuvres; (f) STM management globally is already overwhelmed with inadequately processed and coordinated ephemeris data, including of GEO (36,000 km), and including from GEODSS, GBOSS, SBSS, Sapphire, GeOST, SensorSat, the Space Fence, Lincoln Space Surveillance Complex, and Globus II; (g) operators such as Starlink (60% of satellites) have already proven space-based STM is operationally superior to what they call ‘legacy’ ground-based radar; and (h) US Space Force General Stephen Purdy has admitted that DARC is an ‘expensive’ and ‘legacy’ system. It would have been impossible for the applicant to provide an evidence base that undermines these concerns, because technologically, they are currently both fundamental and fatal to its claimed purposes.

On the contrary to a stated STM purpose, DARC is in fact a weapons system. The last United States Government Accountability Office report, as one of many examples, confirms it was being optimised for ‘missile defence’ (which involves interception, i.e. kinetic impacts) and is listed as an MDAP (a weapons system). Given even the handful of anti-satellite missile tests conducted internationally have drawn intense condemnation on all sides owing to orbital debris generation and the risk of Kessler Syndrome, any offensive use of DARC could only increase rather than decrease risk to satellite infrastructure.

Further, given a Chinese government source in the Global Times called DARC specifically a ‘significant escalation’ in military terms, any offensive use of DARC is confirmed diplomatically to only increase rather than decrease risk of war. Most analyses of economic impacts of war find that war causes GDP to fall without long-term recovery (as one example), meaning any use of DARC would contribute only to net adverse economic effects.

Accepting DARC purely on the basis of the applicant’s identity (the MOD) without a sufficient evidence base is not a legitimate basis on which to grant permission, and would be challenged in court. The application is not permitted development.

On these bases, DARC presents no military or strategic benefits, and only risks.

OBJECTION FOUR: LACK OF EXAMINATION OF ALTERNATIVES.

The applicant concedes there are other disused airfields where DARC could be sited, yet examines none of, as just one siting example, the Airfields of Britain Conservation Trust database of some 1,879 major UK airfields. Given the relatively light perimeter security profile, I do not accept the argument that security could not be ported to a more suitable site, nor are the budgetary concerns involved the problem or responsibility of PCC. Further, PCC has examined numerous superior proposals, including for example a solar array or new-build housing, the probability of which would increase were DARC refused, the visual impact of which would be zero, and the net economic benefit of which would be superior.

CONCLUSION.

The DARC proposal entails only adverse effects in every assessed area. For all these given reasons, I strongly assert that permission for any iteration of the proposal should be refused.

Furthermore, I direct your attention to further expected objections for a referenced evidence base in support of my claims, and I expect all objections, no matter their length, to be given conscientious consideration inline with PCC’s obligations under the fourth Gunning principle of public engagement.

Anti-DARC government elected. Now get them to call DARC in!

Thanks so much for all the actions you're taking to help protect the St Davids peninsula. Let's make DARC history!