Policy A16 Goodwood Motor Circuit and Airfield

Policies affecting the Motor Circuit should provide flexibility in operation and development, whilst retaining an appropriate level of control to protect local residential and other amenities.

Policy affecting Goodwood Airfield should be expanded to include reference to the safeguarding in all forms of runways and their operation, and support the changing role of General Aviation airfields and their future operations as required by Government, including provision for new technologies and STEM-related activities.

Development parameters set by the 2015 safeguarding agreement should be included within panning policy for use in development decisions.

NPRs must be recognised and given weight in development decisions through their inclusion in planning policy

Policy A16 Motor Circuit. The Estate has discussed the need for a specific site policy with the planning authority for some time, to provide flexibility in operation and development whilst retaining an appropriate level of control to protect local residential and other amenities.

Site activity, for the Motor Circuit in particular, is controlled through a planning permission, which while seeking to provide some flexibility, is proving difficult to use in practice when minor changes are required on an ad hoc basis or in response to consumer demand, even when the proposed change is within the spirit and intent of the permission. By its nature the permission is too precise to accommodate a business which requires flexibility, often at short notice.

An over-arching policy providing flexibility but also imposing firm parameters is a sound way forward and Policy A16 is supported as providing a robust starting point for further discussion and consideration. The Estate is keen to continue its engagement with the planning authority on this matter, ideally in advance of the Local Plan examination, to better understand the reasoning behind and likely interpretation of the four criteria listed in PolicyA16. The Estate does not have issues with the criteria per se, but believes interpretation between the Estate and authority could be markedly different, particularly with regard changes to existing operations, rather than new development, to which the Policy responds appropriately.

The Estate has on a number of occasions, had to seek temporary changes to the planning permission, or reach agreement as permitted by the permission with the local authority in order to host events and activities which fall outside of the stated permission parameters, but which fit within the overarching intent and purpose of the consent. While this procedure retains planning control, is can be disproportionately time consuming, carries risk and lacks sufficient comfort when making investment decisions for events, long before there is any certainty of the proposal to take to the planning authority.

The Estate wishes to discuss how the requirement for flexibility within an existing scope of permitted activity can be achieved through a modification to Policy A16, and how the Policy criteria, supported as suitable for application to new development proposals, can be applied equally to existing activities and operations.

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Policy A16 Airfield Policy content relating to Goodwood Airfield is supported generally but we ask that it is expanded to include reference to the safeguarding of runways and their operation, and support the changing role of General Aviation airfields and their future operations, including new technologies and STEM-related activities.

A safeguarding agreement with the planning authority has been in existence since 2015, following on-going dialogue with County and District authorities since before 1979 when a noise study was commissioned to understand operations and noise associated with the airfield, and which made specific reference to planning policies and noise sensitive developments in and around the Airfield.

Within the 2015 safeguarding agreement there are very clear buffers on height restriction in relation to runways and the other safeguarded surfaces around the Aerodrome. These are parameters to be considered in response to planning applications, yet are not referenced through the local plan, and we request these are included. This oversight places the future viability of the Aerodrome in question if these and other safeguarding requirements are not introduced thgough planning policy and overlooked.

This matter was highlighted in respect of the proposed housing development north of Madgwick Lane, which itself would remove one of few remaining open areas that can be used in the case of aircraft emergency, and would place housing directly beneath flight paths of aircraft at very low heights. A factor dismissed by the applicant on grounds of flimsy assumptions, far from proven. The risk that housing might yet materialise, or the absence of robust planning policy to resist any future development proposals, within safeguarded areas is sufficient to already cause aerodrome companies to consider their future.

Also absent and equally important for the consideration of planning applications is any reference to agreed Noise Routeings (NPRs). These routes stem from the original 1979 study (see extract attached by way of introduction to the document) and have been developed over many years through on-going discussions between the local authority, operators and the local community. Their effectiveness is monitored on a regular basis by a committee made up of those bodies.

The NPRs are a key material consideration in planning decisions locally. The NPRs are long established routes (since 1979) over largely undeveloped land for the reason of minimising noise and disturbance to the local community. Whilst the level of activity is variable, but explainable, in the intervening years, it is important for the Plan to acknowledge that the District Council and WSCC recognised then, and should continue to recognise the importance now, that noise routeings carrying aircraft away from noise sensitive areas, should be developed and maintained in the community interest

In recent years the NPRs without due policy protection have been encroached unreasonably and are becoming increasingly compromised, coming into conflict with the NPPF (paragraph 106f). If further land within an existing NPR is selected for development, it is not possible, as has been achieved in the past, to relocate the NPR to other open land. Now any movement will introduce many more households into a noise sensitive area. An Aerodrome such as Goodwood can only survive with the support of the local community that surrounds it, and introducing additional homes or other similar sensitive development into, or close to, an NPR is entirely against the philosophy of how an NPR is designed, constructed and should be used.

Reference to NPRs for Goodwood Airfield within the local plan is critical, with appropriate policy being offered to control development within or adjoining those routes. Within this reference attention should be drawn to the circuits flown from each runway of the airfield, and there should be a distinction between rotary and fixed wing operations due to the differing impacts on the surrounding community

To date the NPRs have helped minimise noise impact from departing aeroplanes, but the traffic pattern flown around the runways, even at points 2nm from the runways, should be a consideration in development decisions. This is not only from a noise perspective but also blight from continually overflying traffic (e.g housing at Tangemere will be so affected).


The policy should include references to its compliance with NPPF guidance, particularly Paragraph 106(f) and to align generally with Government policy about the importance of UK GA airfields.

Reference to the heritage of the site is most important as it is this heritage that adds significantly to its economic value. This is similar to a locally designated heritage asset adding additional value to a locality, but at the circuit, heritage underpins much of the economic asset and this should not be eroded through ill-placed new development

Propose additional policy requirement to A16/A17:

• Ensure that development avoids harm to protected species and existing important habitat features; facilitates the achievement of a minimum of 10% biodiversity net gain; and facilitates the creation of high levels of habitat connectivity within the site and to the wider green infrastructure network and identified strategic wildlife corridors. This includes the provision of appropriate buffers as necessary in relation to important habitats which are being retained and/or created.

See attached representation.

See attachment.

See attached.

Please note that as a Non-Ministerial Government Department, we provide no opinion supporting or objecting to planning applications or local plans including their soundness or legal compliance.

Rather we are including advice and information that we advise the Council consider to ensure their pre-submission local plan avoids potential impacts and promote enhancements/expansion as part of the proposed local plan regarding trees and woodland, including ancient woodland. We acknowledge that the purpose of Regulation 19 consultations does not usually extend to making substantial changes which are not related to soundness so we offer our advice as helpful guidance to ensure the local plan takes every opportunity to secure the protection, enhancement and expansion of Chichester’s valuable trees and woodlands to comply with planning policy, good practice and to make the most of the many benefits they provide to the environment, local economy and community.

Overall Comments
Ancient woodlands, veteran and ancient trees are irreplaceable habitats, and it is essential that they are considered appropriately to avoid any direct or indirect effects that could cause their loss or deterioration, in line with Government Standing Advice. Ancient Woodland has very high potential ecological value and should act as integral focal points, alongside other locally and nationally designated sites, as part of delivering landscape scale nature recovery.

Any development or plan that include these irreplaceable habitats on or near to the site should aim to deliver high standards of net gains and ecological connectivity that supports wider ecological networks, in line with good practice. This will also be a requirement as part of the local nature recovery strategies being driven by the Environment Act 2021 and we advise that plans should anticipate this to maximise environmental benefits to contribute to reversing the national trend of ecological decline as part of broader nature recovery networks. The Local Plan should be considered as a crucial and timely opportunity to secure significant and strategic, plan-led environmental gains due to their scope and scale, particularly given the timescales of development being influenced that coincide with UK Government commitments regarding halving emissions and protecting 30% of nature by 2030, towards a net-zero carbon and nature positive economy.

The development strategy should prioritise the protection of trees and woodlands with the highest priority being given to ancient woodland, ancient and veteran trees as individual habitats and as part of wider ecological networks.

Site Allocation comments:

Policy A7 Land at Shopwyke (Oving Parish)
Site specific considerations could recognise the existing trees, hedgerows and woodland and prioritise their protection, enhancement and expansion as part of biodiversity net gains. Acoustic screening referred to could also use trees to make the most of multi-functional benefits they bring.

Policy A8 Land East of Chichester
We welcome efforts to bolster the existing woodland and the proposed strategic wildlife corridor to the East and the enhancements that development could bring.

Policy A11 Highgrove Farm, Bosham
Bolster planting to North, South and East is welcome. This policy could be improved by requiring bolster planting to the West as well, where there appears to be an existing line of trees, making it well placed to further contribute to wider connectivity with existing and additional planting.

Policy A12 Chidham and Hambrook and Policy A13 Southbourne Broad Location for Development
We note that more detailed proposals will emerge as part of a Neighbourhood plans. We would like to highlight that this area contains some parcels of ancient woodland which is an irreplaceable and high priority habitat according to the NPPF and Government Policy (see attached Annex and below for more guidance on this). The policy could be improved by highlighting its importance and high priority as part of efforts to protect, enhance, expand and connect habitats as part of a wider ecological network and the strategic wildlife corridor. Developments within this area could contribute pockets of woodland and linear planting to help connect existing trees and woodland as part of a mosaic of habitats throughout the wildlife corridor and wider area. The requirement to ensure development does not have an adverse impact on the strategic wildlife corridor is also welcome but could be strengthened by requiring developments to significantly contribute to its enhancement, expansion and connectivity including with green infrastructure provided by development

Policy A14 Land West of Tangmere
The requirement for significant levels of green infrastructure is welcome. This policy could be strengthened by requiring development to retain and bolster existing hedgerows and trees wherever possible.

Policy A16 Goodwood Motor Circuit and Airfield and Policy A17 Development within the vicinity of Goodwood Motor Circuit and Airfield
This policy could be improved by recognising the significant amount of ancient woodland and non-ancient woodland to North of the area. We would encourage any development in the area to protect, enhance and expand the woodland in the area as part of delivering net gains.

Policy A21 Land east of Rolls Royce
This area contains areas of existing trees, hedgerow and woodland which are not currently mentioned by the policy. We would encourage any development to be sensitive to this and provide additional planting where possible.

Overarching comments
We would welcome the consideration of incorporating large and small pockets of multi-functional woodland as part of green infrastructure provision for development, particularly given the relatively low proportion of woodland found throughout the District, and the benefits this can have as ‘stepping stones’ between habitats as part of the Local Plan’s welcome vision of strategic wildlife corridors.

We also encourage the Council to appraise the plan against the following advice to maximise the benefits from protection, enhancement and expansion of woodlands, trees and connectivity throughout the District:

Additional improvements to consider

• Tree/hedgerow removal is considered as a last resort but where it is justified, we advise that developments can aim to deliver no net deforestation to help encourage development that provides an overall environmental gain. Ie where trees are required to be removed, additional tree planting will be made to compensate for this loss and we would advise that additional planting should be made to help compensate for the loss of habitat in the time it takes for new trees to mature.
• Long term management and maintenance of planted trees and woodland creation to give them every chance to becoming established and where trees do fail, they are replaced
• A minimum standard for tree canopy cover for new developments (e.g. for large-scale developments) as it provides a targetable level of green infrastructure in relation to trees for the numerous ecosystem services they provide.
• Precautions should be incorporated into any woodland design and tree planting to ensure that habitat creation is established successfully and that potential impacts from deer are managed on site and in the surrounding area as appropriate. See here for further guidance that should be followed for managing impacts from deer as part of woodland creation and tree planting: https://www.gov.uk/government/publications/woodland-creation-and-mitigating-the-impacts-of-deer/woodland-creation-and-mitigating-the-impacts-of-deer Some good practice advice is also provided in Appendix 1 of this letter.
• We advise that any tree planting should meet the following:
o Trees should be healthy and good practice biosecurity should be followed to prevent the risk of spreading pests and disease, in line with Government advice: https://www.gov.uk/government/collections/tree-pests-and-diseases. More information on the plant healthy can be found at: Welcome to Plant Healthy - Plant Healthy
o Created or restored habitat should be managed in perpetuity in line with a robust management plan that follows good practice to ensure assumed benefits of created habitats are delivered in practice (see Standing Advice referred to on page 1). We recommend meeting the UK Forestry Standard to demonstrate this.
• To help mitigate climate and support local economy would urge council to develop local plan policy that makes use of locally sourced timber. This has multiple benefits as it can help store carbon within development, reduce impact from transportation, reduce embodied carbon from alternative materials and support local economies and communities.
• Where developments incorporate District Heating, consider locally and sustainably sourced wood-fuels for the benefits this can have for renewable energy and towards a local, circular economy
• Use tree planting as part of nature based solutions for managing flood risk as well as other multi-functional benefits from green infrastructure as part of any development (e.g. Trees and woodlands provide £400 million of value in flood protection)
• We encourage the Council to refine their strategy to trees and woodlands using the recently launched ‘Trees and Woodland Strategy Toolkit’ available here: https://treecouncil.org.uk/what-we-do/science-and-research/tree-strategies/ to design and deliver a local tree strategy to harness the long-term benefits that trees can bring to local communities. The local plan should be developed with tree/woodlands in mind as an integral part, alongside other supplementary strategies for the environment including biodiversity, green infrastructure, nature recovery and climate change.

Key guidance regarding trees, woodland and development

Ancient woodlands, ancient trees and veteran trees are irreplaceable habitats. Paragraph 180(c) of the NPPF sets out that development resulting in the loss or deterioration of irreplaceable habitats should be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists. In considering the impacts of the development on Ancient Woodland, Ancient and Veteran trees, the planning authority should consider direct and indirect impacts resulting from both construction and operational phases.

Please refer to Natural England and Forestry Commission joint Standing Advice for Ancient Woodland and Ancient and Veteran Trees, updated in January 2022. The Standing Advice can be a material consideration for planning decisions, and contains advice and guidance on assessing the effects of development, and how to avoid and mitigate impacts. It also includes an Assessment Guide which can help planners assess the impact of the proposed development on ancient woodland or ancient and veteran trees in line with the NPPF.

Existing trees should be retained wherever possible, and opportunities should be taken to incorporate trees into development. Trees and woodlands provide multiple benefits to society such as storing carbon, regulating temperatures, strengthening flood resilience and reducing noise and air pollution.[1] Paragraph 131 of the NPPF seeks to ensure new streets are tree lined, that opportunities should be taken to incorporate trees elsewhere in developments, and that existing trees are retained wherever possible. Appropriate measures should be in place to secure the long-term maintenance of newly planted trees. The Forestry Commission may be able to give further support in developing appropriate conditions in relation to woodland creation, management or mitigation.

Biodiversity Net Gain (BNG): Paragraph 174(d) of the NPPF sets out that planning (policies and) decisions should minimise impacts on and provide net gains for biodiversity. Paragraph 180(d) encourages development design to integrate opportunities to improve biodiversity, especially where this can secure net gains for biodiversity. A requirement for most development to deliver a minimum of 10% BNG is expected to become mandatory from November 2023. The planning authority should consider the wide range of benefits trees, hedgerows and woodlands provide as part of delivering good practice biodiversity net gain requirements. Losses of irreplaceable or very high distinctiveness habitat cannot adequately be accounted for through BNG.