First thing's first: let's load up that one-click prewritten email.
Simply press the button below, DON'T FORGET TO PUT YOUR NAME AND FULL ADDRESS AT THE END, send it off, and voilà—done!
Technical issues with the email button above? No worries. The full text we recommend you send can be copied/pasted from just a bit below, and can be sent to planning.support.team@pembrokeshire.gov.uk. Don't forget to put your name and address at the bottom of the email!
But here's what we'd really like you to do. Once you've sent the above easy email (getting those important key points out the way), we next recommend you send a second email to the planners, with a few of your own reasons for opposing DARC.
There's no limit on how many representations you can make, and even short comments will really help add diversity and a sense of people's real opposition.
If you have clever material (legal) considerations, or have done a detailed objection before, all the better: send that, and anything you've got, as this is effectively the final consultation, and from May 20th onwards (which we'll call midnight on May 19th to be safe) you won't be able to send any more representations.
Any issues with buttons? Just copy and paste the very thorough argument below (length is fine—there are no limits on it!), to planning.support.team@pembrokeshire.gov.uk. Don't forget to put your name and address at the bottom of the email!
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.
All done? Brill!
Think of anyone else who might share your opposition to DARC? Let them know about this objection page!
Feel free to pop this message right into a post on a platform like Facebook, and let friends and family know about the consultation...
I just voiced my opposition to DARC radar in the FINAL public consultation (this is it now). It was done in seconds!
Looking for a super handy one-click email with all the arguments written up ready?
www.parcagainstdarc.com/planning
Thanks so much!
Looking for an image to help your post along? Feel free to use this one (click or tap to open in a new window)...
Well folks, this is it.
Given that Plaid Cymru and the Greens have opposed DARC at the highest party levels, and their polling figures together are looking good, there is absolutely every chance we can stop DARC with a Senedd call-in if you vote for one of them on May 7th. Tempting prospect right!
Thanks so much for being the voice, as you were in 1991, with the power as a community to stop the radar. Keep up the pressure, don't forget your name and address at the bottom of the email, and here's another chance to send it...
