Closed consultation

Consultation on the Ministry of Defence's approach to safeguarding the Eskdalemuir Seismological Array

Updated 5 March 2025

1. Introduction

1.1 This document seeks views on the Ministry of Defence’s (“MOD”) proposals regarding its approach to safeguarding the Eskdalemuir Seismological Array (“the Array”) in respect of windfarm development in the Eskdalemuir Consultation Zone. The MOD’s safeguarding role will continue to be as a consultee in the consenting process, as explained in paragraph 2.6 below. A number of specific questions are asked at the end of this document. The MOD invites responses to those questions. The MOD also welcomes comments on matters not specifically raised but which may be relevant to the proposals. All responses and comments will be taken into account by the MOD before deciding on its approach.

1.2 Reference should be made to the explanation given regarding the MOD’s approach to this consultation as set out in section 9 of this document.

1.3 All responses and comments are invited by the deadline of 20th December 2024.

2. Background

2.1 The Array is a seismological monitoring station in the Southern Uplands of Scotland that was established in 1962 to detect seismic signals from nuclear explosions. Continuously operating and safeguarding the Array ensures that the United Kingdom complies with its international obligations under the Comprehensive Nuclear Test Ban Treaty (“CTBT”).

2.2 The CTBT bans any nuclear weapon test explosions or any other nuclear explosions, for military or civil purposes, and establishes a complex verification system to monitor compliance. Ending nuclear test explosions would constrain the development of new types of nuclear weapons and would therefore represent an important step towards global disarmament, as well as contributing significantly to nuclear non-proliferation. The Array is part of the verification and monitoring system envisaged under the CTBT. It is the only such site within the UK.

2.3 The CTBT opened for signature in 1996. 187 countries have signed the CTBT and 178 have ratified it. The CTBT has yet to come into force and cannot do so until the 44 parties countries listed in Annex 2 to the CTBT have signed and ratified it.

2.4 The UK signed the CTBT in 1996 and ratified it in 1998. The Nuclear Explosions (Prohibition and Inspections) Act 1998 (“1998 Act”) implements the CTBT into domestic law. The 1998 Act will not enter into force until the CTBT itself does. Section 47 of the Anti-Terrorism, Crime and Security Act 2001 addresses the interim position by criminalising (amongst other things) causing a nuclear weapons explosion, development, or production of nuclear weapons, or military preparations intending or threatening to use a nuclear weapon. The provision is subject to exceptions but applies throughout the UK, and to acts done outside the UK where they are done by a UK person.

2.5 The Array is the UK’s primary asset for monitoring underground nuclear tests. In addition to the UK’s international obligations under the CTBT, it is also used to inform ministers on possible nuclear testing and explosions by countries of interest. The MOD considers it is essential to national and global security that the Array is protected. This consultation is being carried out in the context of safeguarding the Array as a national and global asset, for which the MOD is responsible.

2.6 Decisions relative to the consent of windfarm development in Scotland are, of course, within the exclusive jurisdiction of the relevant consenting authority under either the Electricity Act 1989 (“the Electricity Act”) or the Town and Country Planning (Scotland) Act 1997 (“the Planning Act”). In terms of the Ministry of Defence Eskdalemuir Seismic Recording Station Technical Site Direction 2005 (“the 2005 Direction”) the MOD is consulted upon applications for consent under the Planning Act for windfarm developments within a 50 km Consultation Zone centred on the Array. The Scottish Ministers also require the MOD to be consulted in respect of Electricity Act applications. The MOD, in its response to any consultation, does not address the planning merits of the application. It does address the impact of the proposed windfarm development on the detection capabilities of the Array. It does so by use of a predictive model, the development of which is set out in section 5 below. If there is a predicted adverse impact on the Array, the MOD will object.

3. Reason for consultation

3.1 In 2020/2021 a windfarm developer, Energiekontor UK Ltd, raised judicial review proceedings against the MOD. Those proceedings challenged the MOD’s approach to the order in which the MOD considered the impact (by use of the predictive model) of a proposed windfarm development on the Array. The MOD’s approach was first come, first served subject to the following order:

3.1.1 Proposals under the Electricity Act were processed by the MOD on notification of a request for an Environmental Impact Assessment scoping opinion, i.e. before an application for consent was submitted; and

3.1.2 Proposals under the Planning Act were processed by the MOD upon notification of a submitted application for consent.

3.2 The MOD had applied that order since 2005, both in Scotland and in England. By 2020 the MOD was unable to explain the reasons for it having adopted that order. It therefore accepted that it could not provide a rational justification and conceded the judicial review proceedings on that basis. The Court noted that the MOD’s approach led to a failure to treat like cases alike and unlike cases differently. The Court noted that the effect of the MOD’s approach was to afford developers of larger developments an opportunity to be considered by the MOD at an earlier stage of the process than developers of smaller wind farm developments simply by making an application to the Scottish Government to adopt a scoping opinion.

3.3 The MOD undertook to the Court, against this background, to consult on a new approach. Since that undertaking, there has been further research carried out in respect of the impact of windfarm developments on the Array. This is the subject of ongoing consideration by, amongst others, the Scottish Government, to inform its planning policy relative to windfarm development within the Eskdalemuir Consultation Zone. This ongoing work and policy development has delayed the MOD’s consultation. The MOD considers that consultation on its proposed new approach should not be delayed any further to await the outcome of that work.

3.4 The proposed new approach would apply across the whole of the 50km Consultation Zone. If adopted by the MOD, it will apply to all windfarm development in England and Scotland in the Consultation Zone.

4. Proposed new approach

4.1 The proposed new approach, if adopted by the MOD, will come into effect following this consultation, on the date of adoption.

4.2 The proposed new approach will apply to all pending and future applications without distinction to the consenting regime under which they are made. Pending applications means all applications for consent submitted after 11 January 2018, that being the date when the MOD calculated the Seismic Ground Vibration (“SGV”) from the proposed windfarm development at Faw Side, until adoption of the proposed new approach. Future applications means those applications for consent submitted after the proposed new approach comes into effect. Requests submitted for scoping will not be considered an application for consent, whether submitted before or after 11 January 2018. Requests submitted for scoping will be removed from the MOD’s list. Requests for scoping which have been or are followed by an application for consent will be assessed in terms of the application for consent in accordance with the process set out at paragraph 4.5 below. Applications which have already been decided by the relevant consenting authorities will be unaffected.

4.3 The Eskdalemuir threshold of 0.336 nm is to be retained.

4.4 The 50km Consultation Zone (which is a matter for the Scottish Ministers) will remain. Within that zone, an advisory 10km exclusion zone currently operates (i.e. no windfarm development within that is permitted). It is understood that the Scottish Ministers may consider whether to extend the advisory exclusion zone beyond 10km. to allow additional generational capacity within the consultation zone. The advisory exclusion zone will remain, which will not be less than 10km.

4.5 Applications will be assessed on a first come, first served basis. The assessment will be a calculation by the MOD of the cumulative SGV from applications. The order of assessment will be undertaken strictly on the basis of the date on which the application for consent was formally accepted as valid by the consenting authority, with no distinction between the consenting regimes under which they are made. The MOD will maintain a list, recording the relevant acceptance dates. In the event of two or more applications sharing the same date on which the applications where formally accepted as valid by the consenting authority/authorities, the application which has the earlier date on which a consultation request was received by the MOD will take priority. The list will also contain a record of the MOD’s calculation of SGV for all applications (past, present and future) and its decision whether or not to object.

4.6 Where the Eskdalemuir threshold is predicted to be breached, the MOD will object to the relevant application on the basis of adverse impact on the Array. The MOD is aware of consenting authorities having attached a condition to a consent which has been relied upon to permit development when headroom has subsequently become available. For the avoidance of doubt, the MOD’s practice is - and will continue to be - to object to development where it is predicted that the Eskdalemuir threshold will be breached. The MOD does not consider the use of a suspensive condition in such circumstances to provide adequate protection for the Array. To the extent that a “waiting list” has been or will be operated, this will only be to consider whether, on headroom subsequently becoming available, the MOD can withdraw any objections to applications which have not yet been determined by the consenting authority.

4.7 The order of assessment will apply to all pending and future applications, as defined in paragraph 4.2 above, being applications for: (a) development; and (b) variation, material or otherwise, modification or amendment of existing consents (including repowering” applications by way of new application).

4.8 It is proposed that the only exceptions to this order of assessment will be: (a) applications to extend the duration of consents (whether before or after commencement of development) to which the MOD will not object if it has not objected to the original application on the basis that there is headroom available for the original application and there is no increase in predicted SGV as a consequence of the extension of duration application; (b) applications for variation, material or otherwise, modification or amendment of existing consents to which the MOD will not object if it has not objected to the original application on the basis that there is headroom available for the original application and there is no increase in predicted SGV as a consequence of the variation, etc. application (the MOD may require a condition to be attached to the subsequent permission to put beyond doubt that either the original or the replacement project could be implemented, not both).

4.9 For the avoidance of doubt, where an application to discharge a condition (as referred to in paragraph 4.6 above) is submitted, the assessment as to whether any headroom is available will be determined with reference to first come, first served in respect of the underlying consent (or subsequent application for variation, modification or amendment).

4.10 Applications will be removed from the MOD’s list on final refusal (including the final refusal of any appeal, statutory challenge or Judicial Review, and the MOD will not remove an application from its list until the statutory period for appeal/statutory challenge/Judicial Review has expired without an appeal, statutory challenge or Petition for Judicial Review having been submitted). The MOD will remove from its list those consented applications where development has not been commenced and the consent has expired.

4.11 Consented developments will be removed from the list where (a) if development has not taken place, there is no potential for the consent to be implemented, the consent having expired; or (b) where development has been implemented, the development has been finally decommissioned, and any underlying consent has clearly and unambiguously expired.

4.12 In order that the MOD can calculate the SGV, and its impact on the detection capabilities of the Array, from proposed developments, it will require certain information to be provided with the application. A decision not to object will be taken strictly on the basis of the information provided. The MOD will require that the development will be constructed in accordance with the information provided for the calculation and this will be secured by an appropriate condition on the consent. Re-consultation will be required if any changes to the information are proposed during the application process. In the event of re-consultation which has the effect of increasing the predicted SGV of the development, the MOD will consider the application afresh as if it had been validated on the date of re-consultation. The MOD will move the application on its list to this new date. The MOD will re-determine whether any headroom is available within the threshold on this basis.

4.13 The information required is:

4.13.1 Number of turbines;

4.13.2 Layout and location of individual turbines and ancillary development, including grid coordinates (Ordnance Survey grid references accurate to 1m) and any micro-siting allowance;

4.13.3 Maximum hub height and maximum rotor diameter; and

4.13.4 Maximum rated-power of proposed turbines.

5. Impact of wind farms on the Array

5.1 This section provides further background to safeguarding the Array and its detection capabilities, in the context of its importance as discussed in section 2 above. The UK Government and Scottish Government have both set ambitious targets to reduce carbon emissions. As part of the UK’s drive to achieve a significant element of its energy from renewable energy, in 2003 several major wind farm developments were planned for the Southern Uplands of Scotland.

5.2 Following the publication of a number of international cases concerned with SGV caused by wind turbines (including Black Forest Germany, the USA Washington State LIGO facility case, data obtained from the US Stateline wind farm, and the UK St Breock’s Down wind farm experiment), a preliminary assessment based on results from these cases was conducted by Dr Bowers of the Atomic Weapons Establishment (AWE Blacknest) on behalf of the MOD.

5.3 Following this assessment, it was recognised that further research was urgently required in order to assess the impact of SGV from future wind farm developments in the vicinity of the Array. To this end the Eskdalemuir Working Group (“EWG”) was set up in 2004. The EWG is a group of informed parties who set out to reach a consensus on the scientific basis for the Eskdalemuir threshold and the algorithmic (i.e. the predictive) model designed to protect the Array, with a view to assessing the impact of windfarm developments in the vicinity of the Array. Its precise membership has changed over the years but it has comprised UK and Scottish Government departments and relevant industry bodies. The EWG has commissioned research over the years, funded by, amongst others, the then Department of Trade and Industry, the then British Wind Energy Association and the MOD.

5.4 In 2005 a team of scientists at the University of Keele led by Professor Styles, with overview by experts from the BWEA and the MOD (“the Keele Group”) reported (“the 2005 Styles report”). The 2005 Styles Report demonstrated that wind turbines generate SGV which could have an adverse effect upon the detection capabilities of the Array.

5.5 The principal recommendation of the 2005 Styles Report was the establishment of a limit on the cumulative impact of the SGV produced by wind farm developments within a 50 km zone (the “Consultation Zone”) centred on the Array. This limit is referred to as the Eskdalemuir threshold and was set at 0.336 nm. The threshold was adopted as was the Consultation Zone and an advisory 10km exclusion zone within that.

5.6 As noted in paragraph 2.6 above, direction was issued in April 2005 (Ministry of Defence (Eskdalemuir Seismic Recording Station) Technical Site Direction 2005) that the MOD would be a statutory consultee where wind turbine development is proposed within a zone defined by a 50km radius circle drawn around the centre of the Eskdalemuir Seismic Array.

5.7 Where wind turbine development is proposed within the statutory consultation zone, the MOD adopted the use of the model developed in the 2005 Styles Report (described as the “Eskdalemuir SGV predictive model”) to calculate the cumulative SGV taking account of the contribution from any proposed wind farm within the Consultation Zone (on the assumption that the wind farm proposal did not incorporate a vibration mitigation measure). This allowed the MOD to assess whether or not the Eskdalemuir threshold would be exceeded as a result of a proposed development, and, if so, object to that proposed development on the basis that breach of the threshold would have an unacceptable impact on the detection capabilities of the Array.

5.8 In 2011-2012 further research was undertaken on the impact of wind turbine development on the Array. In 2012 the Scottish Government reconvened the EWG in light of the continuing interest in wind farm development in the Consultation Zone and its commitment in the 2020 Routemap for Renewable Energy to deliver a secure, sustainable energy future for Scotland and to re-examine the 2005 Styles predictive model.

5.9 The EWG undertook a substantive piece of work to re-examine the 2005 Styles predictive model and to examine policy around the Eskdalemuir threshold in order to deploy wind turbines efficiently whilst protecting the Array. A staged approach was taken to this research, which considered whether capacity existed within the Eskdalemuir threshold due to developments in wind turbine technology since the 2005 Styles Report. In 2013, research undertaken on behalf of the MOD (referred to as Stage 0) found that there was a likelihood of capacity to allow further wind consents within the Consultation Zone without breaching the Eskdalemuir threshold. Following the conclusion of the Stage 0 research, increased cooperation with wind farm operators and developers within the Consultation Zone allowed further technical research and assessment to be undertaken by Xi Engineering Consultants Ltd, on behalf of and under the guidance of the EWG.

5.10 In 2013/2014 Xi Engineering Consultants Ltd carried out further research. Xi Engineering Consultants Ltd concluded, on the basis of more up to date data, that the predictive model could be revised. They developed an extension to the model using a precautionary “worst case turbine model” as, at that time, wind farm developers did not wish the Eskdalemuir SGV predictive model to tie them to a particular make and model of wind turbine for developments within the Consultation Zone. The extension to the Eskdalemuir SGV predictive model which resulted from the 2014 Xi Engineering Consultants Ltd research was therefore conservative by design, when it came to predicting the SGV impacts of proposed windfarms within the Consultation Zone. The outcome of this research led to the publication by the Scottish Government of “Eskdalemuir Interim Guidance” on 22 May 2014.

5.11 This Interim Guidance confirmed that the Consultation Zone should continue to apply and committed to a public consultation on an extension of the advisory 10 km exclusion zone out to 15km. This was on the basis that the research which had been carried out and reported to the EWG had demonstrated that the amount of SGV from wind turbines predicted at the Array decreased rapidly with distance from it. The research undertaken by Xi Engineering Consultants Ltd had also shown that the installation of turbines in close proximity to the Array would rapidly exhaust any headroom available within the Eskdalemuir threshold. This conclusion has been confirmed in more recent research undertaken since 2020.

5.12 The MOD proceeded to assess proposed windfarm developments in accordance with the 2014 revised predictive model. This situation continued until 2018 when a section 36 application for a proposed development at Faw Side resulted in the Eskdalemuir threshold being breached.

5.13 In June 2018, in recognition of the fact that the threshold had been breached, the Scottish Government reconvened the EWG with a remit to consider two issues: (a) the technical elements of the calculation of the Eskdalemuir threshold; and (b) the policy aspects regarding the management of the Eskdalemuir threshold.

5.14 In 2019, under the auspices of the EWG, the Scottish Government commissioned Xi Engineering Consultants Ltd to undertake a technical analysis of the 2014 revised predictive model used by the MOD. This technical work is being undertaken, with the cooperation and input from the MOD, in order to assess the SGV generated by particular commercially available wind turbines actually operating within the Consultation Zone as an alternative to the Xi Engineering Consultants Ltd 2014 “worst case turbine model”.

5.15 In July 2020, the findings of this technical analysis were presented to the EWG by Xi Engineering Consultants Ltd showing that there could be additional capacity within the Eskdalemuir threshold which would allow for additional generation capacity of between 0.8 and 1.2 Gigawatts (GW). These results acknowledged that the amount of additional capacity depends on the distance of turbines from the Array and suggested that the additional capacity could be protected by increasing the advisory exclusion zone around the Array. Xi Engineering Consultants Ltd concluded that a single typical (2.5 MW) turbine at 10 km from the Array station location has the same impact upon the Array as around 7000 turbines at 50 km. It was agreed therefore that further technical analysis would be undertaken by Xi Engineering Consultants Ltd and reported to the EWG in due course.

5.16 At a further meeting of the EWG in February 2021, a discussion on the need for a technical analysis involving measurement of seismic output at seven sample wind farm sites agreed with the MOD took place. The Scottish Government expressed the view that the undertaking of this work was essential to provide the evidence upon which any of its future policy decisions would be based.

5.17 As presently advised, as a result of the Xi Engineering Consultants Ltd technical analysis undertaken for the EWG, the MOD agrees that the current predictive model over-estimates the SGV from existing wind farms within the Consultation Zone, and that it is appropriate for a new predictive model to be developed.

5.18 However, the technical analysis and its conclusions requires to be reviewed and considered before it can be accepted by the MOD. The MOD will require to review and validate the baseline list of existing and consented wind turbine developments in the Consultation Zone on which that technical analysis relies in order to ensure that it - and the associated calculation of headroom which is not currently referable to already-consented development - is correct. The Scottish Ministers may bring into effect a new approach for the development management within the Consultation Zone to reflect the output of the technical analysis. Until then, the MOD will, in order to ensure continued protection of the detection capability of the Array, continue to apply the current 2014 predictive model (as referred to in paragraph 5.10 above).

5.19 The MOD’s review of the technical analysis and baseline is ongoing.

6. Current position

6.1 The MOD has objected to all wind farm development applications in the Consultation Zone since the Faw Side application exhausted the available headroom and breached the Eskdalemuir threshold. That application was refused by the Scottish Ministers on 22 December 2023 following a public inquiry.

6.2 Since the Judicial Review in 2020, the MOD has not operated its previous first come, first served approach. The MOD no longer operates a ‘queue’ or ‘waiting list’ whereby development proposals had been noted on a list, pending any headroom within the Eskdalemuir threshold becoming available. It does maintain a record, by date of formal acceptance by the consenting authority of a valid application, of applications which it will use if the proposed new approach is adopted and brought into effect.

6.3 Chronologically, after Faw Side Wind Farm, the next pending application, submitted in terms of section 36 of the Electricity Act, is for a proposed development at Scoop Hill. Applying the current predictive model, the cumulative SGV for that development is 1.1083502nm which results in the threshold being breached. There is accordingly no headroom available within the threshold, meaning that the MOD is continuing to object to further applications for consent.

6.4 While it might be suggested that it is premature for the MOD to consult on its proposed new approach pending the ongoing review of the technical analysis, validation of the baseline, and the introduction by the Scottish Ministers of a new development management policy, the MOD undertook to the Court to consult. In any event, it is appropriate to do so now. This will enable assessment of applications to proceed in a fair, practical and timely manner once the review has been concluded.

7. Publication and adoption by the Scottish Government of new guidance and policy

7.1 The MOD understands that the Scottish Government intends to consult on new guidance and policy in respect of wind farm development located within the Consultation Zone during 2024.

7.2 The MOD will carefully consider any guidance and policy adopted by the Scottish Government, and will consider what changes appropriately should, as a consequence, be considered and, after appropriate further consultation, made to its safeguarding approach. This could include the need for appropriate suspensive planning conditions and/or a legal agreement between the MOD and the applicant in order to protect MOD interests in safeguarding the Array.

8. Conclusion and questions

8.1 The MOD has set out its proposed new approach to safeguarding the Array.

8.2 The MOD invites comments from all interested parties on its proposals. Specifically:

8.2.1 Is the MOD’s proposal to consider applications on a first come, first served basis and add applications to its list, used to calculate the cumulative SGV of all such development, according to the date on which the application for consent was formally accepted as valid by the consenting authority, with a consistent approach for all types of application, clearly understandable and fair overall, and is it a practical approach?

8.2.2 Do consultees have any comment on the proposal that, in the event of two or more applications sharing the same date on which the applications where formally accepted as valid by the consenting authority/authorities, the application which has the earlier date on which a consultation request was received by the MOD will take priority?

8.2.3 Do consultees have any comment on the proposal for “applications” (as referred to in sub-paragraph 8.2.1 above) to include applications to vary, modify or amend existing consents (including “repowering” applications) subject to the exceptions proposed in paragraph 4.8?

8.2.4 Do consultees have any comment on the MOD’s position regarding the use of suspensive conditions when there is no headroom available and the MOD’s approach to a “waiting list”?

8.2.5 Do consultees have any other comment on the definition of applications in paragraph 4.7 above?

8.2.6 Do consultees have any comment on the proposal to remove applications from the MOD’s list (and therefore the calculation of cumulative SGV) on final refusal (including the final refusal of any appeal, statutory challenge or Judicial Review or the end of the period within which any such application can be made)? Is this clear, fair and practical?

8.2.7 Do consultees have any comment on the proposal that re-consultation will be required if any changes to the information (referred to in in paragraph 4.13 above) were to be proposed during the application process and that, in the event of re-consultation which has the effect of increasing the predicted SGV of the development, the MOD will consider the application anew as if it had been validated on the date of re-consultation and that the MOD will move the application on its list to this new date?

8.2.8 Do consultees have any comment on the proposal to remove developments from the MOD’s list if development has not taken place, there is no potential for the consent to be implemented, the consent having expired; or where development has been implemented, the development has been finally decommissioned and any underlying consent has clearly and unambiguously expired.

8.2.9 As noted at paragraph 4.13 above, in order that the MOD can calculate the SGV from proposed developments, it will require certain information to be provided with the application, and that information will need to be captured by way of planning condition or otherwise in any consent. Is the MOD’s proposal clear, fair and practical?

8.2.10 Do consultees have anything to add?

8.3 All comments are invited by the deadline of 20 December 2024.

9 Approach to consultation

9.1 The MOD is grateful for stakeholders’ engagement in this matter.

9.2 Stakeholders can respond to the consultation in two ways:

9.3 By email, to DIOEstates-EskdalemuirArray@mod.gov.uk

9.4 By posting your response to: Safeguarding team, Defence Infrastructure Organisation, St George’s House, DMS Whittington, Lichfield, Staffordshire, WS14 9PY.

9.5 Please ensure that your response reaches the MOD before the deadline. When responding, please state whether you are responding as an individual or representing the views of an organisation.

9.6 This consultation is being conducted in line with the government’s key consultation principles.

9.7 Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000 (FOIA) or the Environmental Information Regulations 2004. If you want information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory code of practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence. In view of this it would be helpful if you could explain in your response why you regard the information you have provided as confidential. If the MOD receives a request for disclosure of the information, the MOD will take full account of your explanation but cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the MOD. The MOD will process your personal data in accordance with the Data Protection Act (DPA) and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties.

9.8 This consultation and the processing of personal data that it entails is necessary for the exercise of the MOD’s functions as a government department. In responding to this consultation, you may provide personal data. We shall collect and process your personal data in accordance with data protection legislation and our privacy notice. Please refer to the privacy notice which can be found on the MOD’s website: MOD privacy notice which explains your rights and gives you information you are entitled to under the Data Protection legislation. Should you require a printed copy of the MOD privacy notice, please write to the MOD Data Protection Officer; Ground floor, Zone D; Main Building; Whitehall; London SW1A 2HB or email cio-dpa@mod.gov.uk.