Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1281

Received: 06/02/2019

Respondent: HMPC Ltd

Representation Summary:

The plan's acknowledgement of the importance of Goodwood Motor Circuit and airfield and the formal establishment of a 400m noise buffer is welcomed and supported. The policy is broadly acceptable to the Estate but we believe it can be strengthened to provide greater robustness as well as flexibility.

Full text:

Goodwood Motor Circuit and Airfield

The plan's acknowledgement of the importance of Goodwood Motor Circuit and airfield is welcomed and supported. The policy is broadly acceptable to the Estate but we believe can be strengthened to provide greater robustness as well as flexibility.

Paragraph 4.107 supports ongoing operations at the airfield and motor circuit within the terms of existing legal agreements. For the foreseeable future that situation is likely to continue. However, to remain effective, both activities must evolve and respond to changes in the market to ensure both can be sustained. Of course, noise is a matter we must consider and this is appropriately controlled through the existing legal agreements. The plan should not infer that the agreements will remain unchanged, as it may be interpreted from the current draft. While the principles, and probably the quantum of operations, will remain for the plan period, changes to operational practice and the consequential agreements may be necessary, often at short notice, to respond to market demands and patron expectations. Such changes will be justified and discussed with the planning authority as fully as possible and may result in new applications and agreement amendments.

Much of the character and use of the circuit and airfield is linked to its heritage, its construction as a World War II Fighter Station and its evolution into a racing circuit through the 1950s and 60s. This heritage is used fully at events such as Goodwood Revival and we believe it is important that the policy (Plan S15) truly reflects that heritage area to allow the Estate flexibility in the authenticity of future events. This larger area is important if the true historic context is to be considered in the context of future proposals as use of the site historically extended well beyond the current site boundary to include areas such as The Valdoe to the North. It would be difficult to include all such land within the policy boundary but we suggest that land forming part of the original airfield is so identified; land to the east of Claypit Lane, north of Lavant Straight and at Fordwater Cottages (as shown on the accompanying drawing: Goodwood Estate Plan 3) should be included within the policy area. The policy should also recognise that land adjoining the policy area will be used, from time to time, in association with events, but will be subject to strict management as required in compliance with the legal agreements.

Paragraph 4.110 - The Local planning authority will be aware of the Estate's concerns for noise sensitive developments being located close to the motor circuit (the current housing development east of Madgwick Lane being a case in point). Each of the activities at the circuit and airfield generate noise and the concept of a 400m buffer to the circuit has been developed with the council over a number of years. Its inclusion in the local plan as policy is therefore welcomed and supported.

Noise is a very subjective concept and should not be interpreted simply as a measurement with which to comply. There is a complex interrelationship of factors that are at play when noise becomes a nuisance rather than an acceptable consequence of lawful activity. Unfortunately, the developer at Madgwick Lane chose to ignore such interpretation assuming that if a certain level of noise (according to normal noise levels for residential use) could be proven to exist at a specific point, then residential development was acceptable. This disregarded totally the differing perceptions of noise according to the circumstance and manner in which that noise is experienced by future residents. Consequently, the Local Plan should ensure the buffer is robust and it should be included within policy as well as within the supporting text of paragraph 4.110. We say this because despite the council's removal of land from the previous North East Chichester Strategic Allocation, the land (as discussed elsewhere in these representations) is likely to be subject to development promotion. A large proportion of the land now excluded from the former allocation lies within the buffer area and it is imperative the buffer is given policy robustness, as outlined below.

The buffer zone indicated on the plan diagram (S16) is defined by a line drawn 400m from the edge of the paved circuit. Activities associated with use of the circuit for motor sport (the principle source of significant noise generation) extend beyond the circuit edge to include, run-off areas, and circulation routes and assembly areas outside of the circuit itself. The areas used differ between events and from year to year. To provide appropriate safeguards to sensitive receptors from inappropriate noise disturbance we submit that the buffer should be drawn 400m from the Circuit Policy Boundary (as shown on Plan S15 and as we suggest it is amended: Goodwood Estate Plan 2).

Inclusion of the buffer within policy is supported by paragraph 182 of the NPPF. It states that planning policies and decisions should ensure new development is integrated effectively with existing businesses, which should not have unreasonable restrictions placed on them as a result of development permitted after they were established. This is exactly the situation we have highlighted in respect of development at Madgwick Lane. Inclusion of the buffer within policy and a recognition of paragraph 182 within the support text, will provide an additional level of robustness.

The airfield operates subject to regulations that differ from the motor circuit; the airspace around Chichester and Westhampnett is distinct from the motor circuit and its operation.

Flight paths will vary according to weather and a larger area is potentially subject to operational activity than occurs from the circuit. There are a number of safeguarding zones around the airfield to be considered when any development around the aerodrome is proposed. These are much more extensive than the 400m buffer zone. The Estate is concerned that the extensive zones may not be widely known and not used consistently. We say this because it is often necessary for the aerodrome management to contact developers who appear unaware or choose to disregard the safeguarding zones (e.g use of cranes during construction). The zone map (copy attached) should be referenced in the local plan encouraging prospective developers to consult the zoning information and satisfy themselves of the suitability of the development prior to any development proposal being made. The aerodrome should be consulted on any development proposal (application) within the zones, subject to the height parameters stated. It must be noted that the zones will be subject to change in respect of the use of drones in the facility of the aerodrome and this will apply to any developments located within the defined zones and the activities of persons within those developments.

Policy S15 is supported in principle but we seek further clarification on elements of the policy and its interpretation as set out below.

Policy S15: Goodwood Motor Circuit and Airfield
The Council is supportive of the role that Goodwood Motor Circuit and Airfield plays in the plan area's economy and in attracting visitors to the area. For as long as current use of the circuit and aerodrome remains an active part of the Estate business model, the Council will permit proposals for outdoor sport, recreation and leisure activities in connection or ancillary to the existing motor sport use1 at Goodwood Motor Circuit and Airfield, provided the proposal does not conflict with other policies of the Plan.
The following criteria will also apply to such proposals:
1. The proposed development must not result in increased noise levels experienced by nearby residential properties over and above that already permitted;
2. The character of the area should be retained and reinforced 2;
3. The proposed development should be appropriate in scale and character to the existing uses or buildings3;
4. Any anticipated additional demand for traffic movements should be appropriately mitigated with opportunities for non car based travel options secured and additional private vehicular traffic confined to utilising the existing access
The Council will continue to support the use of the site as an airfield as long as it remains a viable element of Estate activities. Proposals for airfield related development4 will be supported where it can be demonstrated that:
* it represents the replacement of existing facilities on the site which are designed to be similar in terms of size and scale to those they are replacing 5;
* it ensures the ongoing safe and operational efficiency of the airfield and circuit; and
* it would not lead to an increased number of flights in excess of the existing legal agreement or any subsequent management agreement as may be discussed and agreed with the local planning authority from time to time
Any development proposals within the vicinity of the site 6 must clearly reflect the heritage and character of the airfield and motor circuit and demonstrate how the development would protect, and where possible enhance, the operation and heritage of the site as a motor-circuit and airfield.

1 At present the motor circuit and aerodrome are central to the Estate Business model. However, this may change within the lifetime of the plan. While existing uses will continue for the foreseeable future, the Estate wishes to see a greater degree of flexibility within the policy to reflect the commercial and operational needs of the Estate as a whole, including the use and or addition of buildings and the land for other Estate purposes, rather than focus on motor sport or flying as follows:

"The Council is supportive of the role that Goodwood Motor Circuit and Airfield plays in the plan area's economy and in attracting visitors to the area. The Council will continue to support and permit to evolve the existing uses of the circuit and aerodrome. The council will further permit proposals for outdoor sport, recreation, leisure and other Estate activities in connection or ancillary to the existing motor sport and aerodrome uses at the site, or other similar activity related to the Goodwood Brand, its commercial activities and operation, provided the proposal does not conflict with other policies of the Plan."

2 Suggested revision to take account of the wider setting of the former historic airfield (this could be explained in supporting text to include the fields and woodland surrounding the airfield)


"The historic character of the area and its setting context should be retained and reinforced"


3 It is recognised that any new development at the site should reflect the existing character and scale of existing development, uses and buildings, but future operational requirements may make this difficult to comply. For example, a new airfield hanger may require a building larger than those erected previously. That is not to say the character of the site would be set aside but that operational (and economic) needs must be balanced against the heritage and character considerations. At present the drafting is too inflexible.

"All new development should be appropriate in scale and character to the site's historic setting but reflective of contemporary operational needs and requirements. A high standard of design and layout will be required to ensure any new development is not incongruous at the site."

4 Airfield related development will comprise any development reasonably required for the safe and continued viable use of an aerodrome as defined in article 255 of the Air Navigation Order 2009 (interpretation d) or as may be required by the Civil Aviation Authority or other Governing body. This will include development linked to uses and activities at the aerodrome as required by day to day Estate activities.

5 In common with (3) above it may not be possible or practical to replace buildings of exactly the same size. Suggest a redraft as follows:

"it is necessary for the continued operation of the site and is designed to complement existing buildings or are designed to be similar in character, size and scale to those they are replacing"

6 The vicinity of the site is generally described as land falling within its curtilage, within the 400m noise buffer of the site, or is known to have had a historical connection and or operational linkages to the airfield or motor circuit. Any development that will conflict with the safe, efficient and economic operation of the site will be resisted.


The plan's acknowledgement of the importance of Goodwood Motor Circuit and airfield and the formal establishment of a 400m noise buffer is welcomed and supported. The policy is broadly acceptable to the Estate but we believe it can be strengthened to provide greater robustness as well as flexibility.