The Erection of a Building to Accommodate the Headquarters and Air Ambulance Station for Magpas, Including

DEVELOPMENT MANAGEMENT COMMITTEE 21 SEPTEMBER 2020

Case No: 18/01217/FUL

Proposal: THE ERECTION OF A BUILDING TO ACCOMMODATE THE HEADQUARTERS AND AIR AMBULANCE STATION FOR MAGPAS, INCLUDING HANGAR AND GARAGING SPACE FOR A HELICOPTER AND EMERGENCY VEHICLES, WITH ASSOCIATED LANDSCAPING, CAR PARKING, AND BOUNDARY TREATMENT, WITH ACCESS FROM ERMINE STREET

Location: BUILDING 252, RAF ALCONBURY, ERMINE STREET, LITTLE STUKELEY, HUNTINGDON, PE28 4WX

Applicant: MAGPAS AIR AMBULANCE

Grid Ref: (E) 519313 (N) 276907

Date of Registration: 28/06/2018

Parish: THE STUKELEYS

RECOMMENDATION – APPROVE

This application is referred to the Development Management Committee (DMC) because the nature of the application is such that it warrants consideration by Members of DMC. The Officer recommendation of approval is also contrary to the recommendation of refusal from the Stukeleys Parish Council and the development is a Departure from the Development Plan.

1. DESCRIPTION OF SITE AND APPLICATION 1.1 The application site as amended comprises an area of approximately 2.04ha and formerly part of RAF Alconbury, now part of the wider Alconbury Airfield and Grange Farm allocation within the Local Plan to 2036, and the Alconbury Weald Enterprise Zone. To the west of the site, along the access serving the two adjacent residential properties to the north west runs a Public Right of Way (PROW), footpath 7/13. This joins footpath 8/13 approximately 650m to the north. The site is within Flood Zone 1 and does not include any areas identified at high risk of flooding from surface water, though there is an area adjacent to the site identified as being at risk from a 1 in 1000 year event.

1.2 There are two existing buildings on site that comprised part of the former RAF complex, with the smaller building measuring 18m in overall depth, 9.5m in width, 4.1m in height to the ridge and 2.5m in height to the eaves. The larger building measures 23.4m in overall depth, 16.7m in width, 5.4m in height to the ridge and 2.4m in height to the eaves. The buildings are linked by a covered walkway and historically appear to have been used as part of a kennels for a dog handling unit in connection with the Cambridgeshire Constabulary.

1.3 The application proposes the erection of a headquarters building, including a hangar and garaging space for aircraft and emergency vehicles together with engineering operations and provision of hardstanding to facilitate a take-off/landing area, landscaping, car parking, boundary treatments and alterations to the access arrangements. It is proposed the site is operational for 24 hours a day, but with limitations on flight times, discussed in detail below.

1.4 The proposed headquarters building measures approximately 51.5m in width, 33.2m in depth and 9.7m in height at the highest roof ridge point, with a flue projecting a further 3m above that, at 12.7m overall. Parking is proposed along the frontage, together with associated landscaping and hardstanding. The take-off/landing area would be to the rear of the site, comprising a large area of short grass, with low level perimeter planting.

2. NATIONAL GUIDANCE 2.1 The National Planning Policy Framework 2019 (NPPF) sets out the three economic, social and environmental objectives of the planning system to contribute to the achievement of sustainable development. The NPPF confirms that ‘So sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development. The NPPF sets out the Government's planning policies for: • delivering a sufficient supply of homes; • achieving well-designed places; • conserving and enhancing the natural environment; • conserving and enhancing the historic environment.

2.2 The NPPF refers decision makers to the Noise Planning Statement for England (NPSE), which is relevant guidance in the determination of noise impacts.

2.3 National Planning Practice Guidance (NPPG) and the National Design Guide 2019 (NDG) is also relevant and a material consideration.

2.4 For full details visit the government website National Guidance.

3. PLANNING POLICIES 3.1 Huntingdonshire's Local Plan to 2036 (Adopted 15th May 2019) • LP1 Amount of Development • LP2 Strategy for Development • LP3 Green Infrastructure • LP4 Contributing to Infrastructure Delivery • LP5 Flood risk • LP6 Waste Water Management • LP7 Spatial Planning Areas • LP11 Design Context • LP12 Design Implementation • LP13 Placemaking • LP14 Amenity • LP15 Surface Water • LP16 Sustainable Travel • LP17 Parking Provision and Vehicle Movement • LP18 Established Employment Areas • LP30 Biodiversity and Geodiversity • LP31 Trees, Woodland, Hedges and Hedgerows • LP34 Heritage Assets and their settings • LP36 Air Quality • LP37 Ground Contamination and Groundwater Pollution • SEL1.1 Former Alconbury Airfield and Grange Farm

3.2 Supplementary Planning Documents (SPD) • Huntingdonshire Design Guide – Adopted 2017 • Cambridgeshire Flood and Water SPD – Adopted 2017 • Developer Contributions – Adopted 2011 (Updated 2019) • Huntingdonshire Landscape and Townscape Assessment – Adopted 2007

3.3 For full details visit the government website Local policies

4. PLANNING HISTORY 4.1 0600278FUL – Continuation of use of building as independent dog handling unit. Approved 15/03/2006.

4.2 1102094FUL – Enabling works for the Alconbury Enterprise Zone comprising: demolition of existing buildings; new and improved highway accesses and roads; provision of three new gatehouses and security barriers; additional perimeter fencing; structural landscaping; ground works associated with new roads and landscaping; and ancillary drainage, utility works, lighting and removal of hardstanding. Approved. 28/02/2012.

4.3 1201158OUT – Up to 290,000 sqm of employment floor space, including data storage and a materials recovery demonstration centre and up to 5,000 dwellings, including sheltered/extra care accommodation; a mixed use hub and mixed use neighbourhood facilities, including retail, commercial, leisure, health, place of worship and community uses; non- residential institutions including primary schools, nurseries, a secondary school and land reserved for post 16 education provision; open spaces, woodlands and sports provision; retention of listed buildings; new vehicular access points from Ermine Street and the A141, with other new non-vehicular access points; associated infrastructure; reserve site for a railway station and ancillary uses; and associated demolition and groundworks. Approved 01/10/2014.

4.4 16/01445/REM – Submission of reserved matters (access, appearance, landscaping, layout and scale) in respect of the construction of a primary electrical substation, new landscaping, highways works and ancillary works. Approved. 09/12/2016.

4.5 19/01320/S73 – Variation of conditions 1, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 18, 20, 24, 26 and 28 for application 1201158OUT – Amended wording (see covering letter, appendix 1) and Key Phase Submission - KP2 - The Country Park (Hybrid Element). Pending Decision.

4.6 20/01573/REM - Reserved Matters Application for approval of access, appearance, landscaping, layout and scale for new highways, landscaping, suds infrastructure and ancillary works. Pending Decision.

5. CONSULTATIONS 5.1 HDC Environmental Health Officer (EHO) (copy attached) – No objections to the scheme as amended, subject to conditions regarding hours of operation and that the operation management plan is adhered to.

5.2 Stukeley Parish Council (copy attached) – Objection. Recommend refusal because of overlooking, loss of privacy and noise to the existing properties. Potential loss of business to the neighbouring properties.

5.3 Alconbury Parish Council (Neighbouring Parish) – Recommend Approval.

5.4 Huntingdon Town Council (Neighbouring Parish) – Recommend Approval. Members welcomed the amended noise impact assessment and the hours of operation. Members had no further comments and continue to recommend approval.

5.5 Houghton and Wyton Parish Council (Neighbouring Parish) – Support in principle the relocation of MAGPAS to Alconbury Weald. It is imperative for this vital service to continue without interruption.

5.6 Upton & Coppingford Parish Council (Neighbouring Parish) – No comment.

5.7 Abbots Ripton Parish Council (Neighbouring Parish) – No objections.

5.8 Cambridgeshire Constabulary – No objection. The amended application overcomes concerns relating to fencing and security gates. The applicant’s original response stated that CCTV and secure doors and windows would be installed so there will be no requirement for any conditions should permission be granted.

5.9 CCC Local Highway Authority (LHA) – No objection. The HCV access into Alconbury Weald is existing and suitable to cater for the types of road vehicles likely to be generated.

5.10 CCC Transport Assessment Team – No objections. The application is proposing low car parking relative to the standard which supports the sustainability objectives of the site. The development sits within Key Phase 1 of the Alconbury Weald Strategic Site, which was assessed and highway mitigation assigned based on a floorspace cap. The floorspace of this application will need to be subtracted from the Key Phase 1 floorspace cap.

5.11 CCC Lead Local Flood Authority (LLFA) – No objection. The additional information confirms the wider site can accept the 1 in 100 year discharge rate of 6.5l/s. The details submitted within the REM application (ref. 20/01573/REM) are sufficient that a condition is not required seeking further details.

5.12 Environment Agency (EA) – In the absence of a full Environmental Impact Assessment (EIA) and in view of the environmental sensitivity, full applications are required to meet the parameters of the outline strategies for Key Phase 1.

5.13 HDC Urban Design Officer – The application is supported in design terms though some further clarification is required, which can be dealt with by condition. Conditions are recommended requiring details of the materials to be used in the external construction, the flue, hard and soft landscaping and cycle parking.

5.14 Health and Safety Executive (HSE) – (Generated through HSE Land Use Planning Tool) No objection. The proposed development site does not currently lie within the consultation distance (CD) of a major hazard site or major accident hazard pipeline; therefore at present HSE does not need to be consulted on any developments on this site.

5.15 Natural England (NE) – No objection. NE is satisfied the proposed development is unlikely to have any adverse effects on statutorily designated sites, including Sites of Special Scientific Interest (SSSI). No objection subject to implementation of appropriate remediation and foul and surface water drainage strategies being secured through planning conditions.

5.16 Wildlife Trust – No objection. No specific comments to make with regards to ecological impacts.

5.17 Anglian Water (AW) – No objections. Anglian Water has no sewers within the vicinity of the development. The Alconbury Wastewater Treatment Plan has sufficient capacity to accommodate flows. Conditions requiring detailed foul and surface water drainage schemes are recommended.

5.18 Cambridgeshire Fire & Rescue – No objection. The Fire Authority would recommend adequate provision is made for fire hydrants, through Section 106 agreement or planning condition.

5.19 CCC Archaeological Officer – No objections.

5.20 HDC Landscape Officer – The amended details show an additional area for planting. Further detailed information is required in relation to hard and soft landscaping and a landscape management plan. This can be required through condition.

5.21 Internal Drainage Board (IDB) – No comments.

5.22 Highways England (HE) – No objection.

6. REPRESENTATIONS 6.1 15no. letters of objection received incorporating the following summarised material considerations; • Incorrect information has been shown in the noise assessment, with distances taken towards the garage of neighbouring property, not the habitable areas which are closer. • The rotor wash has the potential to circulate particulate matter adversely affecting the amenity and health of neighbouring residences and creating a hazard, particularly as there is an aggregate business run from an adjacent property. • There are electricity telegraph poles in close proximity to the site at risk from the helicopters taking off/landing in close proximity. • The proposed trees would lose leaves in autumn and lead to minimal overall screening from lighting, sound and vibration, which would impact neighbouring property. • No other mitigation has been put forward to mitigate the impact to neighbouring property except those to speed up the helicopter take off. • Potential crashes are most likely to happen during take-off/landing and may threaten the safety of people in the surroundings. • Sufficient noise mitigation cannot be achieved that would limit harm to neighbouring property to an acceptable level. • There are alternative sites available, or that will be available, that are more appropriate. • The proposal would lead to a loss of privacy from helicopters in use. • The development would result in a breach of Human Rights under the Human Rights Act 1998. • The proposal would result in unacceptable levels of noise to neighbouring property. • There are no other methods to address noise impacts if unacceptable impacts occur. • The noise assessment does not provide an accurate reflection of the impact and is limited in scope. • The aircraft will cause vibration that will disturb neighbouring residents, particularly during night flights. • The noise generated from the proposal will adversely impact health and wellbeing of neighbouring residents. • The noise from helicopter take off/landing is significant, and is impossible to ignore, sleep through or get back to sleep after. • Neighbouring residents are sensitive to noise impacts for health reasons, and the proposal would particularly impact their health. • Lighting from the proposal, particularly from any night flying, would be intrusive to neighbouring property. • If the application is approved, conditions should control hours of operation, flight paths to avoid neighbouring property and there should be an evaluation of fenestration of neighbouring property, which may need replacing. • The proposal does not accord with the office and industrial uses originally consented on Alconbury Weald. • There would be an adverse impact to road safety from increased emergency vehicles on the road using an already unsafe access. • Helicopters taking off and landing close to the motorway would be a distraction to drivers and reduce safety. • The proposal will threaten the viability of adjacent established businesses. • The proposal would result in the vacancy of space in Huntingdon town centre as MAGPAS would relocate its headquarters. • The helicopters will impact animals in neighbouring fields and harm biodiversity in the surrounding area. • The proposal will lead to increased emissions, adversely impacting air quality. • The demonstration did not overcome the concerns as there would be substantially different circumstances from the operation of the site.

6.2 4no. letters of support received incorporating the following summarised material considerations; • The site provides an opportunity for MAGPAS to improve their current operations so more time can be spent on serious cases that need their care. • In reality the site is the only viable site currently and foreseeably available. • MAGPAS provides essential critical care for the region. • The site provides better road and air access to support MAGPAS in providing care. • Improving infrastructure is essential in enabling patients to be given lifesaving care and improve changes of survival.

6.3 The following point have been raised that are not material planning considerations. Officer comments are italicised where appropriate; • Matters controlled by legislation outside planning legislation. • The results of informal polls. (Comments must be submitted to the application to be taken into account.) • Political matters. • The site is designated as an enterprise zone. (This is not a planning designation, and in itself has no weight, notwithstanding the site is also designated as an Established Employment Area which is considered further below.) • Damage caused to neighbouring property. (Damage caused not specifically arising to the use, would be a civil issue between the relevant parties. Matters that might arise as a result of the specific use are material and considered where relevant within the report.)

7. ASSESSMENT 7.1 The main issues to consider in the determination of this application are: • Principle of Development • Design and Character • Noise Impacts • Neighbouring Residential Amenity • Highway Safety and Parking • Ecology and Biodiversity • Contaminated Land and Air Quality • Drainage and Flood Risk • Other Matters

Principle of Development

7.2 The application site sits within a number of areas which broadly deal with matters relating to the principle of development; • The Alconbury Weald Strategic Expansion Location (SEL) • The Alconbury Enterprise Zone Established Employment Area (EEA) • Huntingdon Spatial Planning Area (SPA)

7.3 The application, however, proposes a sui generis use, including the storage, maintenance and flying of aircraft and associated office space. As such, it does not fall within the approved uses within the original Alconbury Weald outline application (ref 1201158OUT) and requires a full planning application. The proposal is also a Departure from the Local Plan.

7.4 Policy LP7 relates to Spatial Planning Areas (SPA) and confirms that the Huntingdon SPA includes the land covered by the strategic expansion location of Alconbury Weald, as such the site is within a SPA. Policy LP18 confirms the Alconbury Enterprise Zone is an EEA and sets out the circumstances in which a use not falling within Class B will be supported. In the supporting text for the built-up area, paragraph 4.85 of the Local Plan confirms that reference within the Local Plan to built-up areas is to shape where unallocated development proposals may or may not be considered appropriate; furthermore the supporting table for built- up area guidance confirms that “existing commitments” will be considered as part of the built-up area.

7.5 This application site falls within the area granted outline consent for Alconbury Weald (ref. 1201158OUT) which is allocated within the Local Plan for mixed-use development. This part of Alconbury Weald forms part of the first phase of development, Key Phase 1, and as such a Reserved Matters Application could be submitted within this part of the site. While the proposed use in this application does not fall within the consented uses it is considered that physical development in this location is supported in principle.

7.6 In terms of the use of the site as proposed, policy LP18 supports new development within an EEA, subject to a number of criteria. Part (a), relating to amenity and safety is considered in other areas of this report, but the remaining elements are relevant to the principle considerations of use, location and amount of development This area of the Enterprise Zone is located away from the main concentration to the east, and officers are not able to identify any particular reason this proposal would make the EZ less attractive for other employment uses. There also remains plentiful land within the site for further development. It is therefore considered that the alternative sui generis use proposed will not adversely affect the role and viability of the EEA or have a wider impact upon the SPA given the specific use proposed. As such the proposal complies with criterion b and c of LP18; part d is not relevant as the proposal does not relate to a town centre use.

7.7 As referred to previously, the site is within the strategic allocation SEL 1.1 which is proposed for a range of developments, including developments within B Use Classes. The outstanding outline consent on the site (ref. 1201158OUT) allows for developments within Use Classes B1 and B2. This proposal would not accord with those uses, and so would be contrary to the policy as written and constitutes a departure from the Development Plan.

7.8 Section 38(6) requires that applications must be determined in accordance with the Development Plan unless material considerations indicate otherwise.

7.9 The application proposes to employ approximately 30 people across a floor space area of 1822m2, equivalent to an approximate employment ratio of 1:60. Comparatively, R&D floor space, according to the Homes & Community Agency Employment Density Matrix, would deliver a density of between 1:40 and 1:60, and would be considered a readily acceptable form of proposal in this location. As such, the employment generation from this proposal is similar to the levels that could be achieved from comparative floor space within Use Class B1 developments.

7.10 On the whole, the proposal is therefore considered comparative to more typical employment uses and accords with the requirements for non ‘B uses’ within policy LP18. The proposal therefore supports the EEA, and would accord with policies LP7 and LP18. However, the proposal does conflict with the range of uses supported within the allocation set out in policy SEL 1.1. As such, while comparative to other B uses, there is a technical conflict with adopted policy and this is considered further in Section 8 of this report, as part of the planning balance.

Design and Character

7.11 This area of Alconbury Weald is located away from the main area of the site to the east, connected by a narrow strip of land providing road access. The area is characterised by a range of larger buildings, both former RAF buildings and more recently modern employment buildings within the EZ, but the site adjoins agricultural land to the north and east. To the west is a pair of residential properties, although one also incorporates an onsite aggregate business.

7.12 The proposed development sites the main building towards the front of the site, with a reasonable depth of planting in front, and a parking area located to the south eastern corner. The north eastern area of the site is proposed as a large grassed area, to provide a take-off and landing area, and the latest amendments have incorporated an area of planting in the northern corner, between the site and the adjoining residential dwellings.

7.13 As a full application, this proposal is not bound by the requirements of the Alconbury Weald Outline Planning Permission (ref. 1201158OUT), including the Design Code for Key Phase 1. However, surrounding development that comes forward will predominantly stem from that permission, and so will be required to accord with the Design Code, which will inform and direct the character of the locality in the long term. As such, Officers have assessed the application against the Design Code, to ensure the proposal would reinforce the character that will form within this area, and as a benchmark of the high quality of design sought within Alconbury Weald.

7.14 The HDC Urban Design Officer has raised no objection on the whole subject to conditions regarding parapet walls, the position of the flue and details of hard and soft landscaping. The HDC Landscape Officer has raised no objection to the principle of the proposal, and while comments have noted the lack of detail, it has been noted this could be required by condition.

7.15 The Design Code places the site within the ‘Set in the Landscape’ typology, with the northern area specifically highlighted as an area of ‘boundary planting’. In general, the area is expected to provide lower density built form, set amongst generous landscape buffers that are prominent in the public realm.

7.16 The general form of the building reflects that envisaged within the Design Code, being well within the 12m maximum building height and incorporating a landscaped set back from the roadside. The area to the north of the site is intended to be fully planted, and a section of this would be lost, to be replaced with low level planting around the take-off/landing area. While this would be a departure from the design code, this would only be a section of the intended planting buffer, at the narrower end of the indicative buffer, with the remainder continuing to be fully planted.

7.17 However, the loss of some planting would impact the landscape strategy for Alconbury Weald as a whole, and views to the north of site, such as from the PROW, would remain more open, with the built form of the site appearing between planted areas.

7.18 This matter is returned to in the overall planning balance and conclusions in section 8 of this report.

Noise Impacts

Relevant Policy and Guidance

7.19 Adopted policy LP14 states that proposals will only be supported where the predicted adverse noise impacts, including internal and external levels, timing, duration and character have been made acceptable.

7.20 NPPF para. 180 requires that planning decisions should ensure that new development is appropriate for its location, and takes into account the likely effects of pollution on health, living conditions and the natural environment. Proposals should seek to mitigate and reduce the adverse effects to avoid giving rise to significant adverse impacts on health and quality of light and identify and protected tranquil areas that are relatively undisturbed by noise and prized for their value for that reason. The associated footnote to that paragraph refers to the Noise Policy Statement for England (NPSE), which provides more detailed guidance in assessing noise impacts. A copy of the NPSE is appended to this report, for ease of reference.

7.21 In summary, the NPSE sets out categories of noise impact, which can be summarised as follows; • No Observed Effect Level (NOEL) – The level below which noise can be detected. • Lowest Observed Adverse Effect Level (LOAEL) – The level above which adverse impacts to quality of light and amenity can be detected. • Significant Observed Adverse Effect Level (SOAEL) – The level above which significant adverse effects on health and quality of life occur.

7.22 The NPPG (Paragraph: 005 Reference ID: 30-005-20190722) clarifies that adverse noise impacts are considered to occur when noise levels result in a change in behaviour, for example turning up the volume to hear the television. It provides a table that subdivides the NPSE categories further, to act as a hierarchy of noise impacts, and indicates the actions that should be taken at those points. The table is shown on the next page.

7.23 In terms of specific noise levels, British Standard BS8233:2014, provides the guideline noise levels in table 4 below as desirable levels to achieve a suitable noise environment. The levels stem from guidance issued by the World Health Organisation (WHO) on noise levels. For clarity, a 10db change corresponds to the halving or doubling of loudness to a human ear.

7.24 Noise assessments submitted during the course of the application have made reference to the guidance identified above, as well as DEFRA research titled “Research into the Improvement of the Management of Helicopter Noise, 2008”. Among the conclusion of that paper, the following were identified; • “Helicopters can be up to 15dB more annoying than fixed-winged aircraft. However, helicopter noise levels alone do not account for annoyance trends in communities. • High aircraft (fixed wing) noise levels can awaken people, but the likelihood of the average person having their sleep noticeably disturbed due to an individual aircraft noise event is relatively low [4]. However, sleep disturbance from helicopter operations may differ considerably due to its unique modes of flight such as hovering and low flying. • Annoyance by helicopter noise is not well correlated with generally accepted acoustic parameters. The reasons for this are thought to be a related to three factors: 1) The unique subjective character of the helicopter noise not being fully addressed by the indices. 2) The use of long-time averaged (LAeq) parameters that do not correctly represent single events or operations that have a low rate of incidence. 3) The 'virtual noise' factor, which encompasses community attitudes and fears towards the operations”.

Representations and Noise Reports

7.25 Objections received incorporate a number of points, summarised above. In relation to noise, they have raised concerns in relation to health and amenity, disturbance and interruption of sleep. They have also challenged submitted noise assessments, and the submitted mitigation that has been put forward as being insufficient.

7.26 The application has been supported by noise assessments, and noise assessments have also been received from neighbouring residents. In chronological order, these are; 1. Applicant’s Noise Impact Assessment by Peter Brett Associates (PBA) dated March 2018 (subsequently superseded) 2. Objectors’ Noise Impact Assessment by MAS Environmental dated 2 November 2018. 3. Applicant’s revised Noise Impact Assessment by Peter Brett Associates (PBA) dated March 2019 and based on revised operating times of the Helicopter. 4. Objectors’ Addendum Report (dated 17 April 2019) to the Noise Impact Assessment by MAS Environmental.

7.27 These noise assessments were all carried out in advance of the latest amendments, which have been proposed to mitigate the impacts of the development on neighbouring property in noise terms. As such, they have not reflected the latest circumstances. To summarise, the amendments have introduced a restriction on the hours of outbound flights to between 7am and 7pm, and have increased the boundary of the site to incorporate an area of substantial planting. Such restrictions and further details would be controlled by condition, which officers consider accords with the six tests in NPPF para. 55, and hours of operation and planting schemes are common conditions imposed on applications.

7.28 The times in which flights may be outbound are intended to also include the predominance of return journeys, though a small number have been noted as likely occurring after that, at the discretion of the pilot in exceptional circumstances. Evidence submitted by the applicant indicates this would at maximum be 10 journeys per year, returning before 8pm. Outside these times, the applicant suggests it would be more likely to deploy road-based vehicles, as they are more cost effective and would be outside the rush hours, where traffic would not be obstructive to rapid response.

7.29 In light of these amendments and further clarification, elements of the submitted noise reports are no longer relevant, namely those sections that relate to night-time flights, since these would not take place. The following sections therefore seek to summarise the remaining relevant sections of the reports.

7.30 The 2019 PBA report has put forward the following as appropriate LOAEL and SOAEL levels to assess the impacts of the proposal. To clarify the terminology used; • “LAeq,16h” is a measure of fluctuating time of a period of 16 hours where the fluctuations are averaged out to give a value for a notionally steady sound. • “LAmax” is maximum sound level reached over a period of time and may only be reached for a short time.

7.31 The PBA report has modelled noise impacts, and the maximum indoor sound levels are shown the below table. It is noted the levels fall below the SOAEL. Receptor B is Top Farm, one of the closest residential properties.

7.32 Helicopter noise levels externally at Top Farm would be 80db at 1.5m above ground level and 81db at 4.5m above ground level. These are based on the helicopter being on the ground. The modelling of the MAS report correlates with these numbers.

7.33 The assessments differ in the likely impact, with the 2019 PBA report utilising a more standard assessment based on BS8233:2014, and the MAS report noting a number of characteristics of helicopter generated noise that make standard methodology inappropriate. The MAS report also considers that the 80-81db level should be taken as the maximum noise levels in all scenarios, since the helicopter is on the ground, and noise levels are therefore unaffected by changes in the flight paths.

7.34 The MAS report considers the 5db relaxation that the 2019 PBA report has carried out is not suitable, as it only applies to continuous noise sources. Based on the DEFRA guidance referred to above, the MAS report suggests 15db should be added to the noise levels, due to the unique characteristics of helicopter noise.

7.35 The EHO has carried out a noise monitoring exercise at a demonstration provided by the applicant of the take-off and landing of a helicopter; this demonstration took place on the 3 October 2019 with DMC Members (in place at that time) invited along with Planning and Environmental Health Officers, and neighbours. It is noted there were limitations in the ability to replicate the conditions that would be present at the application site. That said, the EHO has concluded the readings, set out in the following table, provide a reasonable approximation of likely noise levels.

Recording time dB Description (minutes:seconds) LAeq 0:00 40 No helicopter sound 1:18 43 Propellers start turning 2:04 55 Propeller speed increase 3:00 67 Take-off 3:05 70 Moving towards microphone some 10 metres at a height of some 5 metres 3:20 74 Landed at hangar – half distance closer ~ 70 metres 3:40 60 Propeller speed reducing 4:00 40 Stopped

7.36 The EHO has also considered the noise reports that have been submitted and advised that, due to the nature of the noise, typical noise measures are not appropriate, and the LAmax is more appropriate. They advise that the application should be assessed on the basis of the NPPG criteria. This classifies noise levels on the basis of the changes in behaviour they result in. For this reason, the EHO does not consider it necessary to impose a 15db increase in noise levels.

7.37 The EHO considers the noise levels would be above the LOAEL, but below the SOAEL, and it is likely behaviours would change during the time a helicopter was being deployed, such as closing windows. In accordance with the NPPG hierarchy, it is necessary to mitigate and reduce noise to a minimum.

Officer comments

7.38 It is noted that there have been comments received relating to sleep disturbance, predominantly at night, and including details provided by a neighbouring property in respect of the health of an occupant and the effect the proposal would have. In light of the amendment to limit the hours of operation, this is no longer considered to be affected by the development and so it is not necessary to consider in depth the personal circumstances put forward relating to impacts from night-time flying and potential sleep disturbance.

7.39 Based on the information and noise assessments provided, and the comments of the EHO, Officers consider the noise levels of the proposal would fall between the LOAEL and SOAEL. It is considered the noise generated from the operation of the aircraft would be noticeable, and it would be in place for a sufficient length of time that it is not considered to be ‘transient’ in a similar manner to, for instance, a passing vehicle. That said, the aircraft would not be operating in a constant manner, but would be intermittent with some two or three instances throughout the 12 to 13 hour period (based on historic call-out data). As such, while the noise would be loud, the short period of operation is such that there would only be very limited times throughout the day where behaviour would change. In addition, as the noise would be generated during daytime hours, and the A1, at approximately 250m distant, would be at its busiest, officers consider there is a reasonable prospect behaviours may have formed in response to that noise source, given the identified background levels within submitted noise reports.

7.40 Notwithstanding the likely impacts, as the proposal sits within the LOAEL, it is required to mitigate its impacts insofar as it is able to. Predominantly, mitigation would be achieved by limiting the hours of operation for the aircraft to between 7am and 7pm, planting to provide noise screening, and through a number of behaviours that limit noise generating activities, set out in the Operations Management Plan (OMP), which would be secured through condition. A copy of the OMP is attached appended to this report, but in particular mitigation measures include; • Limiting the hours the helicopter could make outbound flights to between 7am and 7pm • Diverting around residences where possible. • Use of Drive Time Analysis to prioritise road responses.

7.41 The mitigation measures provided are considered to go some way to mitigating the impacts of the development in noise terms. It is difficult to fully quantify the impact the mitigation would have, but Officers, including Environmental Health Officers consider it would result in a reasonable level of mitigation, both through noise reduction and reducing the perception of activity at the site. The OMP indicates measures that would also limit noise generation at the site, which would mean potential noise sources, such as sirens, are commenced when necessary and away from more built up residential areas.

7.42 Officers consider that, even with mitigation, there is likely to be some behavioural changes, such as closing windows, as screening could not cover every position the aircraft could generate noise from. However, the national guidance requires that reasonable mitigation is carried out, and the proposal has introduced a range of measures to seek to reduce noise impacts. Situations where noise might be generated at volumes that would result in behavioural changes are therefore minimised as much as reasonably possible, limited to daytime hours and likely to be very infrequent across any single day.

7.43 Officers note comments received regarding the potential breach of the Human Rights Act 1998. Of particular relevance to planning is Schedule 1 Article 8, relating to the right to respect for private and family life, and Schedule 2 Article 1, relating to the protection of property, and peaceful enjoyment of property. As noted above, the proposal is considered likely to result in a very limited alteration of behaviour. It is not considered that it would be at a level that would result in a breach of human rights.

7.44 With regards to noise, therefore, the proposal is considered likely to result in very minor changes in behaviour, but mitigation has been put forward that would limit the worst impacts of the development and will be secured by condition. In considering this element of the proposal, Officers consider the proposal would result in a neutral impact in terms of noise. While it is likely to be noticeable, the mitigation measures and the infrequent nature is not considered to be sufficient to amount to an unacceptable impact to neighbouring residential amenity. It is therefore considered to accord with policy LP14, the NPPF, NPPG and NPSE in this regard.

Other Matters of Residential Amenity

7.45 Comments have been received raising objections on the grounds of overlooking and impacts of light from flying during the dark, predominantly from the aircraft during operation.

7.46 The main building within the site is located at a significant distance from neighbouring property, such that there would be no adverse overlooking, overbearing or overshadowing impacts.

7.47 The aircraft is also located at a significant distance from neighbouring property, both when at ground level at the site and during flying. That distance is sufficient to mitigate impacts of overlooking and from light generated from the aircraft.

7.48 It is likely there would be lighting at the site, for safe functioning during darker times, particularly in winter, where days are shorter. External lighting may result in large areas of glare. However, in light of the approved industrial uses within the site, there is a reasonable potential that alternative development would include some form of security lighting that would result in a similar effect.

7.49 There are forms of lighting that could restrict light spill such that it would not materially impact the amenity of the surrounding area through light pollution, or adversely impact the amenity of neighbouring property, and this could be readily controlled through condition. It is noted that comments received have raised concern that the lack of detail on lighting, and that conditions would not be appropriate. However, Officers consider it is highly likely an acceptable form of lighting is achievable on the site such that it is reasonable to secure details by way of a planning condition. Subject to that condition, therefore, and notwithstanding the above section on noise impacts, officers consider the proposal would not result in adverse impacts to amenity of neighbouring property and would therefore accord with policy LP14.

Highway Safety and Parking

7.50 Comments received have raised objections on highway safety grounds from neighbouring property, including on the basis of distractions arising helicopters flying over nearby roads, particularly the A1. The County Council as both Local Highway Authority and Transport Assessment Team have raised no objections to the proposal. No objections have been raised by Highways England.

7.51 The application site is proposed to adjoin the existing access road into the employment area of Alconbury Weald, which discharges from the site onto the B1090 to the west. The proposal is on the outside of a bend, with good visibility the left-hand splay, and with visibility to the junction the right. Officers note this entrance to Alconbury Weald has approval and is in place to predominantly serve the businesses within the EEA, and provides access for HGVS, as opposed to a residential access where there would be predominance of vehicle movements.

7.52 With particular regard to emergency vehicles, Officers consider these would be less likely to be discharged onto the road during rush hour as the site, by its nature, would look for expedient ways to avoid traffic, such as through deploying aircraft. However, even if emergency vehicles were to use the road, they would have additional ways to make themselves known, such as through lights and sirens, which would alert others to their presence sufficient to ensure appropriate action could be taken to avoid collision. It is therefore not considered there would be any particular adverse impacts on terms of highway safety.

7.53 Comments have been received raising highway safety concerns across the A1 as the helicopter would be unexpected and might distract drivers. Officers have not identified any evidence that supports this point, and no objections have been raised by the technical consultees on that basis. It is difficult to quantify any potential impacts. While the emergence of the aircraft would be less expected, drivers should be reasonably prepared for potential unexpected occurrences. In any event, the potential for a clash to arise is considered to be limited, given the likely times the helicopter would pass, and it would be at some height by the time it crosses the A1. As such, Officers do not consider this would likely result in any severe harm to the safe functioning of the highway network, or nearby trunk roads.

7.54 The application proposes a total of 50no. parking spaces, including 2no. disabled bays, located towards the front of the site and utilising a one- way route. The level of parking is sufficient for all staff and also includes additional provision for visitors. The level of parking is considered sufficient to ensure parking would not be displaced onto the highway in potentially unsafe locations or that might impact the amenity of surrounding occupants.

7.55 On the whole, therefore, the proposal is considered to accord with policy LP17 and would not give rise to severe adverse impacts in terms of the functioning of the highway.

7.56 The application has been reviewed by the Transport Assessment Team, who note the proposal, as a full application, would not be covered by the transport elements of the S106 agreement for the wider Alconbury Weald development. As such, it would not draw from the overall quantum of development considered acceptable on the site and would not be covered by the requirements to carry out monitoring across the wider site. A S106 agreement would be required to also include this development within the wider monitor and manage strategy for Alconbury Weald, to prevent the development undermining the ability of that site to continue delivery. It would also be necessary to condition the submitted travel plan mitigation measures, to promote alternative modes of transport and seek to improve the sustainability of the site. Subject to such a condition and legal agreement, the proposal is considered to accord with policy LP16, in promoting a safe and sustainable transport network.

Ecology and Biodiversity

7.57 The site is a brownfield site, with an existing building that once accommodated a dog handling unit. There are no specific ecological designations in close proximity, though there are some records of protected species close to the site. Officers note there is an extant consent (ref. 1102094FUL) to demolish this building as part of the ongoing enabling works across the site as a whole. While it was identified that the building had a low likelihood to support bats, officers note the age of that permission such that circumstances may have changed. Notwithstanding, as an extant consent, and in light of the wider Alconbury Weald outline (ref. 1201158OUT), the fallback position is that development could otherwise be achieved within the site and the principle in ecological terms is therefore considered established.

7.58 The application has not been accompanied by an ecological report that sets out the existing situation on the site, or mitigation measures that would otherwise have accompanied a reserved matters application pursuant to the wider outline consent. No objections have been received from Wildlife Trust or Natural England, though the latter recommends a condition seeking drainage strategies. These suggested conditions are considered in the section relating to drainage and flood risk below.

7.59 While the proposal has not demonstrated the current status of the site, given the fallback position offered through the extant outline permission that would enable development at this site in any event, officers consider a refusal could not be supported on the basis of harm to habitat and protected species. The loss of habitat could occur through alternative routes, particularly in respect of any habitat that might be accommodated within the building, given the extant consent for demolition. Officers note there would be other legislation that any developer would also need to comply with, that would provide protection for species within the site.

7.60 Notwithstanding the above, Officers also consider there is an opportunity to provide ecological enhancements and wildlife features, in light of the large areas of landscaping and planting proposed within the application. While alternative consented and extant applications enable development to come forward, and for demolition works to occur on the site, this does not otherwise alter that it appears readily possible to provide biodiversity features within the site, in accordance with adopted policy. Officers consider that, as this appears to be readily capable of being achieved, it could be dealt with by condition. Subject to that condition, therefore, the proposal is considered to accord with the requirements of policy LP30.

Contaminated Land and Air Quality

7.61 The proposal is below the thresholds in policy LP36 where it would require an air quality impact assessment, and it is not sufficiently close to an existing Air Quality Management Area (AQMA) where it might give rise to impacts. Objections have been received from neighbouring property on the basis of impacts to human health through poor air quality, particularly on the basis of particulate matter being circulated as a result of the operation of the aircraft.

7.62 Outside that particular matter, Officers have not identified any aspects that would likely give rise to adverse impacts in terms of air quality. With regards to the cycling of particulate it is noted that the neighbouring site stores aggregates, and as such may be sensitive to strong winds. That said, the operation of those elements of the proposed development that might give rise to such impacts are limited throughout the day.

7.63 The application has been accompanied by a Remediation and Verification strategy, following investigation in 2014 that identified contaminants in the ground. Some remediation works have been previously carried out as part of the wider Alconbury Weald works and further works are proposed. The EHO has raised no objection to the works proposed and recommended a condition to ensure they are carried out and a verification report is submitted to the Local Planning Authority to confirm the site is safe. Subject to such a condition, the proposal would accord with policy LP37.

Drainage and Flood Risk

7.64 Officers note comments received from Anglian Water, the Internal Drainage Board and the Environment Agency raising no objections to the proposal and note the application has demonstrated that there is sufficient capacity within the network to accommodate foul flows. Officers note the condition requested by Anglian Water regarding conditioning a foul drainage strategy. However, the details provided indicate pipe details, locations and restrictions, and other legislation (Water Industry Act 1991) covers the detailed specifics of the design, to the satisfaction of Anglian Water. In this instance, therefore, it is not considered a condition is necessary, as the details provided otherwise cover sufficient detail to determine the development would not result in harm to the foul network, and further details would be covered by other legislation such that it is not necessary to replicate them.

7.65 Following an objection from the LLFA in respect of surface water drainage, further details have been submitted demonstrating a scheme that could accommodate the development. This relies on an increase in the size of the attenuation pond to the southwest of the site, and at the time of writing this report is being considered under application 20/01573/REM.

7.66 That application site is within the control of Urban and Civic, as opposed to control by Magpas. However, given the issue of drainage has arisen due to the development of this site, Officers consider it likely that there would be drainage issues in other forms of development, resulting in a limitation on the ability to develop in this location until an acceptable drainage arrangement could come forward. As such it is highly likely the changes would be carried out to the drainage infrastructure to enable development in this area of the site. However, since the drainage works are needed to accommodate this proposal it is necessary to ensure these are in place prior to the development commencing.

7.67 The LLFA have reviewed this application and the revised drainage arrangements and raise no objections. While they have suggested a condition in the first instance relating to drainage details, the LLFA have also confirmed that no condition is required if drainage works are carried out in accordance with application 20/01573/REM, and their comments on that application have raised no objection. Officers consider the comments are sufficient to give comfort the drainage arrangements proposed are achievable and securable without pre-determining the pending reserved matters application; furthermore, the Alconbury Weald site is considered to be of a size which could provide alternative drainage solutions if required. The proposed development is therefore considered to accord with policies LP5, LP15 and the Flood and Water SPD.

7.68 Members are advised that this application is reliant on offsite works to ensure an acceptable drainage arrangement. An application is pending decision for a larger attenuation pond which officers consider there is a reasonable prospect the application could be acceptable. Notwithstanding this, given the scale of Alconbury Weald, Officers consider a scheme could be readily accommodated within the site that would enable a suitable drainage arrangement for development on this site. This would be secured through Grampian condition.

Other Matters

7.69 Objections have been received regarding the impacts to surrounding businesses that would result in the loss of earnings. Comments received have identified a neighbouring aggregate business that may be more vulnerable to strong winds, such as those generated by the aircraft. Officers note there is intervening planting that would work to mitigate those effects, breaking up the downwash from the limited aircraft events. There do not appear to be any other nearby businesses that would be materially at risk of impacts from the development.

7.70 Officers note comments received regarding impacts to animal welfare from the noise of the aircraft. The EHO has commented that they consider humans to be more sensitive. As such, officers consider the low frequency and lack of night-time flying is considered to significantly mitigate potential impacts to animal welfare such that it is not considered significantly harmful.

8. Conclusions and Planning Balance 8.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires that applications are determined in accordance with the development plan unless material considerations indicate otherwise.

8.2 In considering the planning balance, it is necessary to conclude on whether the proposal accords with the Development Plan when read as a whole, factoring in that policies will add varying degrees of weight and may involve conflict with each other1.

8.3 Officers note that a technical conflict has been identified with policy SEL 1.1, as the proposal is not a ‘B Class Use’ within that policy. This weight is tempered by the nature of the proposal, as a development that is akin to the uses that have been otherwise envisaged in this development and Officers consider it would generate similar levels of employment. As such, the level of conflict is considered to be ‘technical’ and Officers consider the weight afforded to the conflict is wholly minor.

8.4 It has also been identified that there would be a conflict with the approved Design Code for the wider Alconbury Weald site in that there would be a lesser level of planting than envisaged across the northern aspect of the site. This would increase the weight of conflict with policy SEL 1.1, as the proposal would not accord with criterion (d), (m) or (s) of that policy.

8.5 The proposal accords with the Design Code in the majority of matters, but the conflict with the wider landscape strategy is notable. It is also noted the application is a full application, and therefore not bound by the approved Alconbury Weald strategies that stem from the outline application (ref. 1201158OUT). It must be assessed on its own merits. This is a site-specific policy, however, that is relevant only to development at this site. On the whole, the conflict with this policy is considered minor and afforded minimal weight.

8.6 It has been identified that the proposal accords with policy LP18, which provides support for developments such as this that support economic growth within EEAs. As a proposal of this nature would bring forward a development envisaged by policy LP18, it is considered this carries a significant weight.

8.7 It is noted the proposal accords with other policies in the plan, but these are considered to be neutral matters, rather than providing support to the proposal. As such, in considering compliance as a whole, Officers note that, while the conflict with policy does carry some minor weight, the conflict is technical and there are other wider policies that provide full support for this development. Therefore, the proposal is considered to accord with the adopted local plan when read as a whole and in the first instance the indication is that it should be approved.

8.8 In terms of material considerations that might indicate otherwise, Officers note objections have been received that raise material considerations and should be factored into the assessment. However, the planning merits of those comments have been considered above and have been found acceptable. It is therefore not considered there are any material considerations that indicate the development should be refused contrary to the Development Plan.

8.9 For the sake of completeness, Officers also note the following material considerations are considered to weigh in support of the development; • The provision of a life-saving service is considered to carry significant social benefits.

1 Corbett V Cornwall Council & Anr [2020] EWCA Vic 508 • The development process, in terms of materials sourced, and jobs created through build works, are considered to carry a moderate weight.

8.10 Notwithstanding the above comments on compliance with the plan as a whole, in any event, Officers consider the significant benefits of the development would outweigh the minor conflict with the development plan.

9. RECOMMENDATION – delegated APPROVAL subject to completion of a Section 106 agreement and conditions to include the following;

• The development must be implemented within 3 years. • The development must be carried out in accordance with approved plans. • Outbound flights of aircraft may only occur between 7am and 7pm. • The measures in the Operations Management Plan will be implemented and maintained. • Hard and Soft Landscaping details must be submitted and approved. • Details and samples of external materials to be used in the construction of the building to be submitted and approved. • Details of the flue, louvered screens and location of PV panels to be submitted and approved. • Details of cycle parking to be provided and implemented. • Details of the off-site surface water drainage works to be submitted and completed prior to commencement of development, or in accordance with an agreed timescale. • Ecological enhancement measures to be submitted and provided within the site. • Contaminated land remediation shall be carried out in accordance with the submitted details and a verification report submitted. • Fire hydrants to be provided prior to occupation in accordance with details to be submitted and approved by the LPA. • Details of external lighting to be installed shall be submitted and approved.

OR REFUSE in the event that the obligation referred to above has not been completed and the applicant is unwilling to agree to an extended period for determination, or on the grounds that the applicant is unwilling to complete the obligation necessary to make the development acceptable.

If you would like a translation of this document, a large text version or an audio version, please contact us on 01480 388388 and we will try to accommodate you.

CONTACT OFFICER: Enquiries about this report to Aaron Sands, [email protected] Sands, Aaron (Planning)

From: Ramune Mimiene Sent: 08 September 2020 11:53 To: DMAdmin Subject: The Stukeleys PC Planning Recommendations to Building 252 RAF Alconbury Ermine Street (ref 18/01217/FUL)

Dear Planners, The Stukeleys Parish Council would like to refer back to our previous comments made to HDC on 6 May 2020:

The Stukeleys Parish Council Recommend Approval to the above planning application but wish to express our concerns regarding the potential future planning on that particular site.

Thanks Ramune

Ramune Mimiene Clerk to The Stukeleys Parish Council 14 Low Road Little Stukeley Huntingdon Cambs PE28 4BA 07596 891618 [email protected] https://www.thestukeleys-pc.gov.uk/ Please note I work part time and so there may be a delay in my responding to both email and telephone calls. This email or any attachment is confidential, intended for the addressee only. If the email has been mis-directed please delete it and inform the sender. The email does not contain any personal data as defined under the General Data Protection Regulation 2018 (GDPR) however correspondence with the Council may be viewed by other authorised persons or organisations under the Freedom of Information Act 2000 (FOIA). If you believe that you cannot process this correspondence without the personal data you must contact the Council to arrange a sharing agreement under the terms of the GDPR.

On 17/08/2020 11:35 [email protected] wrote:

Dear Parish Clerk,

Please find correspondence from Development Management at Huntingdonshire District Council attached to this email in relation to the following application for planning permission.

Proposal: The erection of a building to accommodate the Headquarters and Air Ambulance Station for Magpas, including hangar and garaging space for a helicopter and emergency vehicles, with associated landscaping, car parking, and boundary treatment, with access from Ermine Street

Site Address: Building 252 RAF Alconbury Ermine Street

Reference: 18/01217/FUL

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Ms Ramune Mimiene Clerk to The Stukeleys Parish Council 14 Low Road Little Stukeley Huntingdon Cambs PE28 4BA 07596 891618 [email protected] https://www.thestukeleys-pc.gov.uk/

Please note I work part time and so there may be a delay in my responding to both email and telephone calls.

This email or any attachment is confidential, intended for the addressee only. If the email has been mis-directed please delete it and inform the sender. The email does not contain any personal data as defined under the General Data Protection Regulation 2018 (GDPR) however correspondence with the Council may be viewed by other authorised persons or organisations under the Freedom of Information Act 2000 (FOIA). If you believe that you

2 cannot process this correspondence without the personal data you must contact the Council to arrange a sharing agreement under the terms of the GDPR.

3 Sands, Aaron (Planning)

From: DMAdmin Sent: 04 May 2020 13:27 To: Control, Development (Planning) Subject: FW: Planning Permission Consultation - Building 252 RAF Alconbury Ermine Street (ref 18/01217/FUL)

From: [email protected] Sent: 04 May 2020 12:50 To: DMAdmin Subject: RE: Planning Permission Consultation - Building 252 RAF Alconbury Ermine Street (ref 18/01217/FUL)

Good Morning

I can confirm there are no objections from the Councillors

Many Thanks

Best regards, Angela Papworth Clerk of Abbots Ripton Parish Council Tel: 07850 749647

From: [email protected] Sent: 20 April 2020 16:23 To: [email protected] Subject: RE: Planning Permission Consultation - Building 252 RAF Alconbury Ermine Street (ref 18/01217/FUL)

Dear Parish Clerk,

Please find correspondence from Development Management at Huntingdonshire District Council attached to this email in relation to the following application for planning permission.

Site Address: Building 252 RAF Alconbury Ermine Street

Reference: 18/01217/FUL

Opting out of email correspondence ------We are continually striving to improve the service we deliver to our customers. As part of this we are now contacting our customers by email where possible in an effort to provide a faster, more efficient service.

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1 out please contact us at the address provided below so that we can remove your email details from our records.

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2 Sands, Aaron (Planning)

From: [email protected] Sent: 05 May 2020 12:09 To: DevelopmentControl Subject: Comments for Planning Application 18/01217/FUL

Planning Application comments have been made. A summary of the comments is provided below.

Comments were submitted at 12:08 PM on 05 May 2020 from Ms Charlotte Copley.

Application Summary Building 252 RAF Alconbury Ermine Street Little Stukeley Address: Huntingdon PE28 4WX The erection of a building to accommodate the Headquarters and Air Ambulance Station for Magpas, including hangar and garaging space for a helicopter and Proposal: emergency vehicles, with associated landscaping, car parking, and boundary treatment, with access from Ermine Street Case Officer: Aaron Sands

Click for further information

Customer Details Name: Ms Charlotte Copley Email: [email protected] Address: 37 Station Road, Ramsey, Huntingdon PE26 1JB

Comments Details Commenter Town or Parish Council Type: Customer made comments neither objecting to or Stance: supporting the Planning Application Reasons for comment: Comments: The Parish Council voted unanimously to neither support or oppose the revision plans and documents received 20th April 2020 amending the site plan and operations plan

1 PAP/M22 HUNTINGDON TOWN COUNCIL

PLANNING COMMENTS : April 2020

18/01217/FUL Magpas Air Ambulance c/o Ms Olivia St Amour, Rapleys, 33 Jermyn Street, London, SW1Y 6DN

The erection of a building to accommodate the Headquarters and Air Ambulance Station for Magpas, including hangar and garaging space for a helicopter and emergency vehicles, with associated landscaping, car parking and boundary treatment, with access frmo Ermine Street. Building 252 RAF Alconbury, Ermine Street, Little Stukeley, Huntingdon, PE28 4WX

Recommend APPROVAL. Please see attached letter.

03/04/2019 The application is revised to propose to operate the Air Ambulance Helicopter from the site between the hours of 0700 and 2300 only (i.e. the Air Ambulance Helicopter would not be operated from the site between 2301 and 0659 hours). The revised proposal is accomanied by a revised Noise Impact Assessment, ref: 40011/3002 REv:03 Date: March 2019 20/04/2020 Revised plans and documents received amending the site plan and operations plan.

Members welcomed the amended noise impact assessment and the hours of operation. Members had no further comments and continue to recommend APPROVAL. 28/04/2020 Huntingdon Town Council continues to support this application and MAGPAS. Huntingdon Town Council recommend APPROVAL. 20/00422/FUL

Demolition of existing dwelling and erection of two dwellings. 6 Mill Common, Huntingdon, PE29 3AU

Recommend REFUSE. The application shows that there is risk to local wildlife habitats specifically bats and nesting birds with minimal mitigation offered. Furthermore the residence is in close proximity to a water source which could suggest more wildlife that would be impacted from development (LP30 and LP 31). The proximity to sites of interests (Alconbury Brook and Portholme Meadow) , and within existing conservation area the proposed development is not sympathetic to the surrounding area or properties. The proposed properties do not appear inkeepng with neighbouring properties in height and design (Huntingdon Neighbourhood Plan NE3)

PAP/M22 HUNTINGDON TOWN COUNCIL

PLANNING COMMENTS : April 2020

20/00603/LBC

Roof repairs following storm damage. Hartford House, 43 Main Street, Hartford, Huntingdon, PE29 1XZ

Recommend APPROVE. Roof tiles to be re-used where possible and any new tiles to be of similar suitable format and appearance (as recommended by HDC conservation officer advice)

20/00622/HHFUL

Two storey side extension with car port. 96 Thames Road, Huntingdon, PE29 1QW

Recommend APPROVE. There does not appear to be notable impact on neighbouring properties, however the design may not be inkeeping with other property frontages on Thames Road.

Huntingdon Town Council

Town Hall, Market Hill, Huntingdon, PE29 3PJ Tel: 01480 410383 email: [email protected] website: www.huntingdontown.gov.uk

Town Clerk: Philip Peacock

Ref: Magpas Planning Application 18/01217/FUL

To whom it may concern,

Thank you for your letter inviting Huntingdon Town Council to comment on the above application.

Whilst Huntingdon Town Council would be disappointed to see the Magpas office leave Huntingdon Town Centre, the relocation and new offices would continue to support the local community providing rapid response medical support to those in need. With the relocation the site would have more direct links to the A14/A1 and house the air ambulance services, giving a more unified set up for the organisation, which can also benefit those in need.

As a Council we actively support local businesses and charities within Huntingdon, as they support our town, communities and residents. The relocation of Magpas may create employment opportunities within the area for construction and ongoing project/site management. The existing site on St Mary’s Street, could also be redeveloped providing opportunities for a business, housing or community facilities which would only benefit the town.

The proposed site is distanced from residential sites within the Alconbury development, this minimising any noise of visual impact on residents. There would direct access to the site from the B1043 providing swift responses from rapid response vehicles but also means that the vehicles would not have to access key roadways through residential areas.

The building design has incorporated eco friendly measures to ensure that it is sustainable and minimising impact on the environment – design features such as solar shading and louvres to regulate air flow and temperature.

In conclusion Huntingdon Town Council recommend APPROVAL of this application and fully support this proposed development.

Twinned with: Salon de Provence, France Wertheim am Main, Germany A Charter Town since 1205 Szentendre, Hungary Gu bbio, Italy

Development Management Committee

Scale =1 :2,500 Application Ref: 18/01217/FUL

Key Conservation Area Listed Building The Site proposed planting, details to be agreed by condition

area of future development

ø 110m110000 m m

pond

KEY

1 - substation 2 - dispersal area 3 - fuel storage tank 4 - proposed building 5 - 8no. visitor carpark 6 - 42no. staff carpark 7 - external bin storage 8 - vehicle barriers 9 - drop down bollards 10 - coach drop off 11 - cycle parking under entrance canopy 12 - location of additional vistor cycle spaces (should need arise) site tree pond low level grass low to medium level planting low level perimeter planting pedestrian access access road staff + visitor vehicle one -way deliveries, refuge + coach drop off one -way system

Notes HEALTH, SAFETY AND ENVIRONMENTAL INFORMATION Client Revision Status Description Date MCW architects MAGPAS Oast House, Malting Lane Cambridge CB3 9HF 1. Do not scale from this drawing. Notes: P1 S2 First Issue for information 09/03/2020 Project Title 2. All dimensions are in millimetres unless otherwise stated. - It is assumed that the work is undertaken by a competent Contractor, 3. This drawing to be read in conjunction with all relevant who is therefore aware of all generic risks associated with these works. MAGPAS www. mcw architects.com architectural, civil/structural, and services engineer's drawings - It is assumed that any maintenance work referred to on this drawing is Wyton and specifications. undertaken by competent, appropriately trained operatives in line with the Access & Maintenance Strategy. Drawing Title Purpose of issue Status - These notes are to be read in conjunction with all relevant Residual Hazard Schedules and in particular Designer Residual Hazard Schedule Site Plan - Boundary Option 1 For Information S2

- Listed below are 'site specific' risk relevant to this drawing: Scale at A1 Date Drawn by Checked by Drawing No. Rev 1 : 500 09/03/2020 LVP CM 0281 -MCW -00 -ZZ -DR -A-01010 P1 area of future development

fuel tank

magpas hq

cycle spaces

location of additional visitor cycle spaces - should need arise in future

pond

Notes HEALTH, SAFETY AND ENVIRONMENTAL INFORMATION Client Revision Status Description Date MAGPAS MCW architects Oast House, Malting Lane Cambridge CB3 9HF 1. Do not scale from this drawing. Notes: P1 S2 Planning Information Issue 16/02/2018 Project Title 2. All dimensions are in millimetres unless otherwise stated. - It is assumed that the work is undertaken by a competent Contractor, P2 S2 Boundary line updated - Planing Information Issue 19/02/2018 3. This drawing to be read in conjunction with all relevant who is therefore aware of all generic risks associated with these works. MAGPAS www.mcwarchitects.com architectural, civil/structural, and services engineer's drawings - It is assumed that any maintenance work referred to on this drawing is P3 S2 Additional Cycle parking provision added - Planning 18/05/2018 Wyton and specifications. undertaken by competent, appropriately trained operatives in line with Information Issue the Access & Maintenance Strategy. P4 S2 Fuel storage tank enclosure updated - Planning 31/05/2018 Drawing Title Purpose of issue Status - These notes are to be read in conjunction with all relevant Residual Information Hazard Schedules and in particular Designer Residual Hazard Schedule P5 S2 Dimensions added - Planning Information 27/06/2018 Proposed Block Plan Planning S2

0 2 4 10 m - Listed below are 'site specific' risk relevant to this drawing: Scale at A1 Date Drawn by Checked by Drawing No. Rev 1 : 200 27/06/2018 LVP CM 0281-MCW-00-00-DR-A-01003 P5

Sands, Aaron (Planning)

From: Morley, Aaron (Env. Health) Sent: 05 May 2020 09:47 To: DevelopmentControl; Fox, Charlotte (Planning) Cc: Sands, Aaron (Planning); Flett, Finlay (Community) Subject: LittleStukeley_ErmineSt_RAFAlconbury_Building252_1801217FUL_121315d

Hi Charlotte

Planning Ref: 18/01217/FUL Env Health Ref: 121315

Building 252, RAF Alconbury, Ermine Street, Little Stukeley, Huntingdon PE28 4WX The erection of a building to accommodate the Headquarters and Air Ambulance Station for Magpas, including hangar and garaging space for a helicopter and emergency vehicles, with associated landscaping, car parking, and boundary treatment, with access from Ermine Street

I write further to the recent submission of the updated Operations Management Plan (V6) and amended site boundary plan with associated additional landscaping.

The Operations Management Plan now limits the aircraft operations to between the hours of 7am to 7pm. This brings a major change with regard to potential noise disturbance in that the aircraft movement would no longer be considered to cause sleep disturbance. In accordance with the noise exposure hierarchy table in the Planning Practice Guidance, the noise level would be at the lower end of the “Lowest Observed Adverse Effect Level” because the noise may be heard and cause small changes in behaviour such as turning up the television, speaking more loudly and closing windows during the 5 minutes of aircraft movement for example, but it would not cause sleep disturbance during the normal evening and night-time hours and would not affect the character of the area with it already being in an industrial setting.

Where this is the case, the Noise Policy Statement for England (para 2.24) requires that all reasonable steps should be taken to mitigate and minimise adverse effects of noise (although this does not mean that such adverse effects cannot occur). To that end, the applicant has extended the application boundary to include soft ground and landscaping to act as a natural buffer between the proposed operational area and the nearest noise sensitive dwellings which would enhance the natural background sound and absorb some of the aircraft noise.

These new proposals change my original recommendations for noise contained within my e-mail of 18 November 2019. I now consider the combination of the Operations Management Plan together with the landscaping proposal to be the most reasonable noise mitigation measures and should be adhered to should this application be granted.

My comments relating to land contamination remain the same.

Best regards,

Aaron Morley BSc(Hons) MSc(EngGeol) MSc(EnvHealth) PGDip(Acous) FGS MCIEH CEnvH Environmental Protection Officer - Community Chartered Environmental Health Practitioner Huntingdonshire District Council Pathfinder House St. Mary's Street Huntingdon PE29 3TN Tel: 01480 388360

OPERATIONS MANAGEMENT PLAN (V6)

Introduction

Following the Noise Impact Assessment undertaken by Peter Brett Associates, an Operations Management Plan was recommended.

This document details the procedures in place with regards to noise management of our emergency medical service. For ease, these control measures have also been summarised at the end of the document.

The service

Magpas operate a 24/7 emergency medical service that is deployed by two ambulance services; East of England Ambulance Service and East Midlands Ambulance Service. It is activated to attend the most seriously injured patients in the region.

The clinical team comprises of a Doctor and Critical Care Paramedic and deploys using either an air ambulance helicopter or rapid response vehicle. In addition to the clinical team, the aircraft is crewed by a Pilot and a Technical Crewmember.

Hours of Operation

The service operates over two shifts – Day shift which is 07:00 – 19:30 and a Night shift 19:00 – 07:30.

The aircraft is currently available to the Day shift with no aircraft operations occurring between the hours of 19:00 and 07:00*.

Activation and Call-out

The clinical service is governed by a senior management team and operates under detailed policies and procedures. One of which provides clear guidance on activation of the team (see Appendix 1)

A summary of this guidance is below:

• Both ambulance services have a dedicated desk that activates specialist resources (air ambulance being one). The staff on these desks are trained to specifically ensure that any activation requests received are appropriate for the team to attend.

• Only certain categories of incidents will trigger the activation of a specialist Doctor/Paramedic team or on a specific request from an ambulance crew who need extra help. We are not activated like a standard ambulance resource.

• We use drive time maps to support air versus road deployment. If an incident location is within a 15-minute emergency drive (during the day) and 30 minutes’ emergency drive during the hours of darkness (up until 7pm) the team will respond by road vehicle. This means that over 50% of activations are by car, not helicopter.

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• The management team reviews all activations and has regular meetings with the ambulance service to monitor that the service is being activated appropriately. This ensures no unnecessary or inappropriate activations are taking place.

Based on 2017 activation figures, the average total call out per Day shift is 3 and per Night shift is 2. 45% of activations are by air and between the hours of 07:00 – 19:30 the average air deployment is 2 per shift.

Aircraft deployment

The aircraft is used to reach all areas outside of the drive-time area and/or if there are access difficulties. This ensure we can reach the 12 counties operate in.

The aircraft operates under Helicopter Emergency Medical Services (HEMS) approval and is able to claim aviation exemptions outside the normal operation of aircraft where immediate and rapid transportation is essential by carrying medical personnel, medical supplies, sick or injured persons to or from the scene.

The aircraft always takes off and lands into the prevailing wind. The wind in England is predominately southwesterly so this will be the direction the aircraft will routinely leave and return to the site.

The routine departure and arrival route from the proposed new location is as below –

• The aircraft is not allowed to fly within 500’ (height of a 50 storey building) of a person, vessel or structure unless taking off or landing. It will not fly low for any other period.

• Start up for the aircraft is 3-4 minutes. The aircraft will reach 250’ in 1 minute, then 500’ in approx. 7 seconds. We anticipate a maximum of 5 minutes overall from start up to 500’.

• We anticipate that the aircraft will reach 500’ above the A1.

• The aircraft will ascend to an altitude of 1,000 ft (or greater) before reaching the nearest built- up residential areas.

• Pilots will divert around local villages and residential areas as much as possible.

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• The aircraft can only be used for lifesaving, air ambulance purposes. The aircraft is not allowed to undertake any commercial flights.

• There would be no outward flights after 7pm unless in exceptional circumstances. Exceptional circumstances in this instance would be if there was a Major Incident in the region that required additional air support to deploy additional medical teams.

• * Between the hours of 7-8pm there could be up to 10 returning flights taking place per year. These flights would only take place using the pilot’s discretion and would only occur for an unplanned, mission critical, daylight hours return after a late finish at an incident. All other times, the aircraft would return before 7pm with the team travelling by car back to base.

Vehicle deployment

The vehicle does utilise audio and visual equipment (sirens and emergency lights) but these will only be required once the vehicle approaches traffic. The team may activate the emergency lights upon leaving the base but the sirens will only be used once traffic is reached.

During a night shift, only a maximum of 4 people will be on shift. The headquarters will be closed leaving just the operational area active. All activities and equipment checks will take place inside the building and only activations of the car will take place outside.

Summary of management controls

The proposed aviation facilities will only be used by the Magpas helicopter. 1

The Magpas helicopter will only be used for and in support of emergency 2 services.

There is a dedicated ambulance control desk that activates the team (and other 3 specialist resources). They are trained to specifically ensure that any activation requests received are appropriate.

The service operates under robust policies and procedures and has clear 4 Activation and Callout guidance.

Only activate to certain categories of incidents or a specific request from an 5 ambulance crew. We are not activated like a standard ambulance resource.

Drive time analysis maps are used. Whilst the aircraft is operational, if an incident location is within a 15-minute emergency drive (during the day) and 30 6 minutes emergency drive during the hours of darkness (up until 7pm) the team will respond by road vehicle. This reduces the number of aircraft activations.

The aircraft is currently available to the Day shift only with no aircraft 7 operations occurring between the hours of 19:00 and 07:00*.

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Over 50% of activations are by response car. 8

Regular meetings take place between Magpas and the ambulance services to 9 monitor that the service is being activated appropriately. This ensures no unnecessary or inappropriate activations are taking place.

The average total callout (by air and land) per 24 hours is 5. The Day shift 10 being activated 3 times and the Night shift 2. The average air deployment is 2 per shift.

The aircraft is not allowed to fly within 500’ (height of a 50 storey building) of a 11 person, vessel or structure unless taking off or landing. It will not fly low for any other period.

Start up for the aircraft is 3-4 minutes. The aircraft will reach 250’ in 1 minute, 12 then 500’ in approx. 7 seconds. We anticipate a maximum of 5 minutes overall from start up to 500’.

The aircraft will ascend to an altitude of 1,000 ft (or greater) before reaching the 13 nearest built-up residential areas.

The pilots will always consider how to minimise noise pollution when being tasked i.e. consideration to wind direction, routing etc. Pilots will divert around 14 local villages and residential areas as much as possible and this will be a local rule.

The response vehicle will only utilise a siren when it approaches traffic. 15

There will be limited operational staff on site during the night. The headquarters 16 will be closed. All activities and equipment checks will take place inside the building.

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Appendix 1 – Magpas Standard Operating Procedure (SOP) 1.6 Activation and Call Out

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