Chichester Local Plan 2021 - 2039: Proposed Submission

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.

The 400m buffer should be reconsidered and replaced with a more robust policy that offers a true reflection and response to noise and safety concerns.

Land likely to be used in cases of aircraft emergency should be kept open and free from development.

Reference to the 400m buffer zone, and its inclusion in policy A17 is understood and welcomed, but we question if, as part of this local plan, a more robust area of control can be created. The 400m distance was a useful ‘rule of thumb’ generated in the absence of any other policy restricting sensitive or particularly harmful development in close proximity to the circuit and airfield, but it is appropriate to replace it with a more considered and robust policy parameter.

It is unfortunate that in drawing a limit on a plan, developers are interpreting the constraint as supporting development at any point beyond 400m from the site boundary. This is too simplistic and gave rise to the problems encountered with the proposed development north of Madgwick Lane, with development proposed up to the 400m limit because it was interpreted as being acceptable in policy terms. On the ground this was not the case with issues of noise and disturbance from overflying aircraft, and aircraft safety issues rendering development beyond the 400m in this location equally unacceptable.

The Estate would welcome the opportunity to discuss and agree with the planning authority a more robust buffer zone around the airfield and motor circuit, that responds more appropriately to facts on the ground, and to the existing safeguarding NPRs which exist.

Development, of a form other than housing, and not sensitive to noise from the circuit and aircraft movements could be developed closer to the site than 400m in some locations, while in others the 400m limit should be extended (following NPRs for example). Land immediately to the south of the airfield between it and the river should however remain as open land, both for aircraft safety considerations and for community amenity and landscape benefits.

Open land around the airfield that is most likely to be used in the case of aircraft emergency, should be included in the development exclusion zone and identified as open space and or land of landscape importance (the area identified as “Land removed from existing site allocation” on Map A9a fits such a category).

It is important to recognise the operation of Goodwood Motor Circuit and Aerodrome is reliant upon the land around it. Use of that land for other purposes presents a potential constraint to operations. The Estate is keen to ensure the land remains open where required (e.g. to provide open land for aircraft emergency or for parking and other uses associated with events) and for new landscape works - including extension of wildlife corridors. The 400m buffer, as extended as we suggest through other representations, comprises the remaining open area between Chichester City and the National Park, which should be conserved.

The paragraph should emphasise, as raised in other representations, the true value of the Goodwood Estate to the local and National Economy.

Goodwood Estate generates an estimated economic contribution of £435m into the national economy and £125m in tax contributions, of which £314m and £100m respectively benefit the local economy (2019 Study by London School of Economics). Consequently, one of the area's most significant providers of employment, homes and economic benefit, is under threat from inappropriate adjacent development. The Plan should ensure the benefits provided by Goodwood and its operations are sustained by appropriate policy protection and opportunity.

The paragraph should emphasise, as raised in other representations, the true value of the Goodwood Estate to the local and National Economy.

Goodwood Estate generates an estimated economic contribution of £435m into the national economy and £125m in tax contributions, of which £314m and £100m respectively benefit the local economy (2019 Study by London School of Economics). Consequently, one of the area's most significant providers of employment, homes and economic benefit, is under threat from inappropriate adjacent development. The Plan should ensure the benefits provided by Goodwood and its operations are sustained by appropriate policy protection and opportunity.

The particular importance of the economic and employment contribution of Goodwood Estate and Rolls-Royce should be acknowledged.

The particular importance of the economic and employment contribution of Goodwood Estate and Rolls-Royce should be acknowledged.

The Goodwood Estate generates an estimated economic contribution of £435m into the national economy and £125m in tax contributions, of which £314m and £100m respectively benefit the local economy (2019 Study by London School of Economics).

It is understood Rolls-Royce is to publish details of its economic contribution imminently, which should be addressed through the Plan

The Estate will work with the local planning authority to expand upon the proposed wildlife corridors, particularly in respect of land around the circuit and aerodrome. The existing bridleway adjacent, and recent planting, is one opportunity to provide additional corridor provision linking with the Tunnels SAC across Estate Land.

The Estate will work with the local planning authority to expand upon the proposed wildlife corridors, particularly in respect of land around the circuit and aerodrome. The existing bridleway adjacent, and recent planting, is one opportunity to provide additional corridor provision linking with the Tunnels SAC across Estate Land.

Leisures uses can generate noise and disturbance and should be added to the list of potential sources

Leisures uses can generate noise and disturbance and should be added to the list of potential sources, for which none assessments should be a critical element of development proposals on land adjacent. The Goodwood motor Circuit and aerodrome represent a major leisure (as well as commercial and economic) use that generates noise. Any development proposed adjacent should require a full and representative noise assessment

It is important the Plan makes appropriate provision for the protection of local character and distinctiveness and this applies equally to open areas (countryside and urban fringe) as it does to the built environment. This can be achieved through the identification of character areas to which overarching and specific development management policies apply.

It is important the Plan makes appropriate provision for the protection of local character and distinctiveness and this applies equally to open areas (countryside and urban fringe) as it does to the built environment. The Goodwood Estate, its conservation and operations provide land between the City edge and National Park to the north with a distinctive character, which is both recognised and should be sustained. Development proposed within the area should assess and demonstrate through evidence, how that character is to be protected and enhanced. Developments which will detract or result in significant change should be resisted.

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