BOROUGH COUNCIL OF WELLINGBOROUGH REGULATORY COMMITTEE

REPORT OF THE DIRECTOR OF ENVIRONMENTAL SERVICES

APPLICATION REFERENCE: WP/2004/0426

PROPOSAL: THE CONSTRUCTION OF AN ALL WEATHER SURFACE TO THE EXISTING RUNWAY 03/21 WITH ASSOCIATED TAXI WAY APRON AREAS AND EARTH WORKS.

LOCATION: SYWELL AERODROME, WELLINGBOROUGH ROAD, SYWELL, NORTHAMPTON

APPLICANT: SYWELL AERODROME LIMITED

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1.0 Introduction

Purpose of Report

1.1 These proposals are the subject of an appeal on the grounds of non-

determination, which the Secretary of State has directed he should

determine because the proposals give rise to significant public

controversy.

1.2 The purpose of this meeting is to resolve what decision Committee

members would have taken in relation to the proposals had they retained

jurisdiction to determine the application. This is necessary to inform the

presentation of the Council’s case at the appeal in due course.

1.3 This report has been prepared by external planning consultants RPS

Planning and Environment, part of the RPS Group who have considered all

representations made in respect of the appealed application including

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those made in writing and orally (either by telephone or face to face

meetings). The report has considered and balanced the development plan

and all other material considerations in reaching the recommendation

contained in Section 9 herein.

1.4 RPS made themselves available to all persons who requested a meeting at

the Council’s Swanspool House offices. RPS were themselves advised by

TPS Consult in respect of technical aeronautical matters and Entec in

respect of environmental matters. This report has been prepared

independently from Council officers and members. Advice on legal

matters has been provided by Marrons Solicitors of Leicester.

1.5 The background reports from the Council’s consultants, TPS Consult and

Entec, were made available to the public on 10 February 2005 as soon as

they were finalised.

1.6 The recommendation set out in Section 9 of this report is that had the

Planning Committee retained jurisdiction to determine the application it

should have been refused for the following reasons:

1. The proposed development would result in an unacceptable

intensification of flying activity amounting to a material change in the

character of use which would adversely affect the amenities of nearby

residents by reason of noise and general disturbance, whilst causing

detrimental harm to the character of Old Sywell Conservation Area

and to the setting of the listed Grade II* Sywell Hall, contrary to

adopted Local Plan policies G1, G9, G13, E9 and L12 and adopted

Structure Plan policy RE3.

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2. The proposed development would result in an unjustified and

unacceptable impact on open countryside contrary to the provisions

of adopted Local Policy G6 and E6 and as such would not serve to

conserve or enhance the local landscape character contrary to

adopted Structure Plan policy AR2 and RE3.

3. The proposed development, when considered against the criteria set

out in adopted Structure Plan policy T12, is deemed to be

unacceptable, specifically for the following reasons:

I. the scale and nature of the proposed development is

inappropriate for the existing amount of activity on the site;

II. the economic and employment benefits are not justified;

III. adverse impact on residential property;

IV. adverse environmental impacts.

1.7 Members are advised to exercise their discretion in relation to the

proposals as if they were determining the application in the normal

manner by having regard to the provisions of the Development Plan and

all other material considerations.

The Planning Application

1.8 The (now appealed) planning application consists of;

• Planning Application dated 28 May 2004

• Covering Letter dated 28 May 2004

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• Drawing No. J98084/PA/101 – Proposed Layout

• Drawing No. J98084/PA/102 – Cross Sections of Runway and Taxiway

• Environmental Statement Prepared by Jacobs May 2004

• Environmental Statement – Non Technical Summary - Prepared by

Jacobs May 2004

• Letters and enclosures from applicant dated 17 November 2004 and

4 February 2005.

The Structure of this Report

1.9 The remainder of this report is set out in the following way. Section 2

contains a description of the proposal, section 3 sets out the planning

history as it relates to the current application, section 4 sets out the

consultation responses, section 5 sets out the relevant development plan

policy, section 6 sets out other material considerations and section 7

sets out the applicants stated need for the proposal. Following this,

section 8 contains an analysis of the key issues based on the proceeding

sections. Section 9 then contains a summary and section 10 puts

forward a recommendation. The Appendix to this report contains a

summary of the assessment of the Environmental Assessment.

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2.0 PROPOSAL

2.1 The proposal is for the construction of an all weather surface to the

existing runway 03/21 with associated taxiway, apron areas and earth

works at Sywell Aerodrome, Sywell.

2.2 The aerodrome abuts the settlement boundaries of Sywell Village and Old

Sywell Village. The application site, covering the extent of the physical

works, lies within the aerodrome boundary and abuts Holcot Lane. The

southern end of the proposed runway is around 320 metres from

residential properties on Holcot Lane and around 330m from Sywell Hall

within Sywell Old Village.

2.3 The applicant describes the key features of the aviation improvement

proposals as

• “An all weather runway of 30m width, providing take off / landing

distances of 1,000m in either direction. This is to be paved in either

asphalt or concrete. The all weather runway will be positioned within

the existing main runway strip (runway 03/21). For those aircraft that

prefer grass, a parallel grass runway 03/21 will be maintained,

directly to the east of the paved one.

• Displaced thresholds at either end of the all weather runway, to

provide clear glide slopes for aircraft as required by CAA Publication

Cap 168, Licensing of Aerodromes.

• All weather parallel taxi way and taxi way access routes of

approximately 2,550m in total length and 15m or 10.5m width as

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appropriate. The access route will lead from the general aviation (GA)

area at the eastern edge of the aerodrome to the new all weather

runway, and extend to the Wellington Hangers at the western edge of

the aerodrome.

• Paving of the existing aprons (approximately 10,000sq m), adjacent

to the Wellington Hanger and in front of the Northamptonshire

School of Flying (NSF) Hangers.

• In total a maximum area of 8.1ha of the aerodrome is expected to be

paved.

• A drainage system in connection with the new paved areas,

specifically the all weather runway, will have drainage incorporated

within its design. Surface water drainage will run via adequate

interceptors and vents partly to soakaways and partly to Ashby

Bottoms Brook. The apron areas opposite NSF will drain to soakaways

via an oil interceptor. The apron area by the Wellington Hanger has

existing drainage that will be improved and an interceptor added.

• Replacement of temporary airfield ground lighting currently used on

the grass runways with permanent airfield ground lighting for the all

weather runway. This will comprise 45 watt edge ground lights

positioned at approximately 60m intervals along both sides of the

runway with six threshold lights at each end of the runway.

• Earth works and regrading at the southern end of the runway to

ensure a consistently graded Runway End Safety Area, with gradients

compliant with CAA requirements. Earth works material will originate

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from the aerodrome complex, including material from the

excavations required to form the runway, taxiway and aprons. The

earth works will cover an area of 3.6ha, and reach a height above

existing ground level of 2m on the extended runway centre line,

rising to 4m along the Holcot Lane boundary.”

2.4 Significant works will be required for surface water drainage of the

impermeable surfaces. These do not form part of the current application

though details would be required prior to commencement of

construction.

2.5 It should be made clear that the all weather surface will provide an

additional hard runway within the existing main grass runway and that

the grass runway itself will be retained in parallel to the proposed new

runway. The new runway will be 91m (10%) longer than the existing and

retained grass runway.

2.6 The runway itself is 1,150m long which includes the starter strip / stop

way. Thus, the Accelerate Stop Distance Available (ASDA) can be declared

as 1,150m in both directions along the runway. In addition, the taxi ways

on to and off the runway add a further 140m of hard surfacing and the

Runway End Safety Areas (RESA’s) are an additional 160m and

approximately 105m along the centre line. The Runway End Safety Area’s

are grassed areas, at grade with the runway. Whilst the paved runway

itself is 30m wide the runway strip is a further 60m on each side of the

paved runway. This will be a grassed area and is a safety feature for

aircraft missing or leaving the runway on takeoff or landing. A grass

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runway will be retained within the grassed runway strip parallel to the

paved runway along its southern side.

2.7 A hard surfaced taxi way is proposed starting from in front of the

business park running to the southern end of the new runway, on to the

Wellington hanger and then to the northern end on the new runway. The

taxi way runs the full length of the runway along its western side. Aprons

or hard standings are proposed in front of the business park, adjacent to

existing hangers and alongside the Wellington Hanger.

2.8 Planning consent is needed for the proposal as the construction of the all

weather surface, taxi way, apron areas and earth works constitutes

engineering operations being defined as development by the Planning

Act and requiring planning permission.

2.9 However, as a consequence of providing the all weather surfaces, the

airfield will be able to accommodate additional Air Traffic Movements

(ATM) and a broader range of aircraft types, more evenly spread

throughout the year.

2.10 The applicants have proposed a range of conditions that ‘cap’ Air Traffic

Movements by number and weight. This proposed limit on Air Traffic

Movements formed the basis of the Environmental Statement. By letter

dated 04 February 2005, the applicant proposed the reduction of the

upper weight limit from 25,000kg to 16,500kg. These caps are described

later in this report.

2.11 The intensification of the use that will result from the proposal will itself

require planning permission, as the additional Air Traffic Movements will

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amount to a material change in the character of the use. It is not

therefore correct for the applicant to say that there can be no planning

control on activities. Whilst the present use may be proved to be lawful,

any intensification of use resulting in a material change in the character

of the use would require planning permission.

2.12 Any fall back position of achieving the same level of flight activity

without the hard runway must be reasonably capable of being achieved.

From information received by the applicant on the condition of the grass

runway it is not considered that such an intensification is reasonably

achievable without the hard runway.

2.13 The numerical increase in Air Traffic Movements is set out below. The

figures are from the applicants’ Environmental Statement (ES).

Existing Out of New Total Heli- Total Recorded Hours Corporate Fixed copters ATM Operators Wing EA Baseline March 2002 - Feb 2003 Recorded ATM 62,861 2,800 - 65,661 8,680 74,341 Proposed Increase 11,539 - 7,000 18,539 3,820 22,359 Increase as % of Recorded 18% 28% 44% 30%

EA 2003 Recorded ATM 53,608 2,800 56,408 10,714 67,122 Proposed Cap 74,400 2,800 7,000 84,200 12,500 96,700 % Increase 39% 49% 17% 44%

EA 2000 Recorded ATM 44,620 2,800 47,420 8,203 55,623 Proposed Cap 74,400 2,800 7,000 84,200 12,500 96,700 % Increase 67% 78% 52% 74%

2.14 The applicants have recently confirmed that fixed wing Air Traffic

Movements for the calendar year 2004 were 41,292 (including 2800 out

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of hour movements), the proposed cap representing a 104% increase in

fixed wing Air Traffic Movements.

2.15 The proposal will not include any de-icing facilities for the paved runway

or aircraft. This means that fixed wing Air Traffic Movements will be

restricted during freezing weather conditions. A condition would be

required preventing the use of de icing materials which would discharge

to watercourses or ground water.

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3.0 PLANNING HISTORY

3.1 An application (WP/2002/0030/F) for similar physical development of a

hard runway and taxiways was permitted by the Borough Council of

Wellingborough in March 2002. This decision was subsequently

challenged in the High Court and was quashed. Whilst having similar

physical characteristics, the current planning application differs

significantly from that previously supported by this Council in terms of

the change in Air Traffic Movements and the caps on movements

proposed to justify the extent of the physical works. The March 2002

permission allowed by condition a different combination of Air Traffic

Movements than are currently proposed. The difference between the Air

Traffic Movements is set out in the table below.

Condition March 2002 Permission Current Proposal

Total Annual Fixed Wing 75,000 84,200

Air Traffic Movements

Total Daily Fixed Wing Shall not exceed 400 on 550 on any day when

Air Traffic Movements more than 25 days per tower open

07.00-23.00 year

Air Traffic Movements 5 per week 5 per week below 5700kg

23.00-07.00

Air Traffic Movements Max 1000 Max 2000 up to

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over 5700kg 16,500kg

Air Traffic Movements Part of total Max 5000 between 2731-5700kg

Helicopters No limit 12,500 per annum

Helicopters 23.00- No limit 5 per week

07.00

Turbofan over 5700 No limit None

Out of hours Air Traffic 2800 per year

Movements (07.00-

09.00 and 18.00-23.00)

3.2 This is not a detailed description of the conditions proposed by the

applicant but seeks to highlight the changes between what is currently

proposed and what was previously supported. The physical works to the

runway also appear to be different, the southern RESA (close to Holcot

Lane) and subject to enforcement action is not shown on the earlier

application drawings.

3.3 Application was made to the High Court for permission to judicially

review the March 2002 decision of the Council on a number of grounds.

Permission was granted, and the March 2002 decision subsequently

quashed on the basis of only one of the grounds of challenge.

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3.4 In considering the current application, RPS have reviewed the original

grounds of challenge.

Ground 1 & 2

3.5 “There was an error of arithmetic which affected the decision making

process, that being, an increase from 9 to 12 months represented a 33%

increase and not a 25% increase.”

3.6 In accepting that the Council had considered the application on the basis

of a 25% increase rather than a 33% increase, the Judge found that the

Council had unwittingly found themselves determining the application on

the basis of information that did not take full account of the

environmental impact of the proposal. The Judge relied upon a quote

from one of the submissions that:

“The permission granted exceeded that which had been assessed.”

3.7 The Judge found that objectors had an arguable case in that had the

Committee been aware of the mistake and its consequences such matters

may have influenced their decision. The Judge also found that when

viewed objectively, the number of Air Traffic Movements was probably

the main controversial issue in the case, and one which would have

arguably had the most effect, potentially, on the environment and the

public, as well as the Regulatory Committee.

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Ground 3

3.8 “The absence in the Environment Statement or the process consequent

upon it, of any or adequate evaluation of the fauna likely to be

significantly affected by the development.”

3.9 As a matter of general comment the Judge quoted from a previous

decision which was quashed on the grounds that:

“On the limited information in that case available to the Planning

Authority, they could not rationally have found that there was no

significant adverse nature conservation effect flowing from the

development. The information was insufficient to evaluate the

risk, and until the extent of the risk had been established, it was

not properly in a position to evaluate the necessary measures to

meet the risk. It was insufficient to impose conditions, or by

condition to require further surveys as a means of mitigating an

un-quantified and un-quantifiable risk.”

3.10 The Judge noted, however, that in this case there were no badgers or

great crested newts on the site and that no bats were present either. He

concluded that the Council had not, therefore, erred in concluding they

had a sufficient description to identify the likely environment effects.

Ground 4 and 5

3.11 These grounds were in four parts, part one being that the report to

Planning Committee, known as the Green Paper, should have been

available more than the statutory minimum of three clear days. The

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Judge found that that submission was unarguable and that the nature of

the proposed development was such that the Council could reasonably

conclude that the normal statutory period was sufficient.

3.12 The second part was that the Green Paper was not available within the

statutory minimum of three clear days. The judge found there was an

argument to be made on this issue and gave permission for review on

that ground.

3.13 The third part of Grounds 4 and 5, was that a Background Report relied

upon by Council officers in preparing their advice to the Committee was

not made available. The Committee Report had summarised the

consultant’s report. The Judge found that generally the way in which the

Council dealt with the consultant’s report was adequate and not arguably

such as to render the decision unlawful.

3.14 The fourth point under Ground 4 and 5 was that objectors were given

insufficient time to address the Committee, but the Judge found that

there was not an arguable case on that point.

Ground 6

3.15 With regard to the failure of the Council to adjourn the Regulatory

Committee meeting to allow inspection of documents, the Judge found

that if the statutory requirements were complied with then there were no

arguable grounds for deferring the meeting.

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Ground 7 – Breach of Human Rights

3.16 The Judge found that these were covered in points made under other

individual grounds and had nothing to add to them.

Further Application

3.17 The applicants have appealed against the non-determination of this

application and have resubmitted a further application for the same

physical works though the applicants are proposing that conditions be

attached limiting Air Traffic Movements to their current levels in terms of

Air Traffic Movements, size of aircraft and hours of operation.

3.18 The physical works of the resubmission are designed to a level that

would be able to accommodate the number and type of aircraft proposed

in this (2004) application. The length and width of the proposed hard

runway would not be required for the current pattern of aircraft

movement. Indeed, a shorter hard runway than the current grass runway

would be sufficient. Also, the full length, parallel taxiway is only required

to accommodate the proposed future capacity.

3.19 A shorter hard runway would not need to encroach as close to Holcot

Lane as currently proposed and would not require the raising of ground

levels which are currently subject to enforcement action.

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4.0 CONSULTATION REPLIES

4.1 Sywell Parish Council – The Parish Council has held extensive

consultations with its constituents in respect of the application and has

received a large number of responses both written and verbal. The vast

majority of these responses were against the application for a hard

runway. At a meeting at Sywell Parish Council held on the 14 September

2004, it was agreed that Sywell Parish Council should oppose the

application for a hard runway on the grounds of the inaccurate

description of the length of the runway, inadequacy of ES in respect of

aircraft of between 16tons and 25tons, the use of appropriate base line

figures, an assessment of night time flights and proposed provision of

night time flights, assessment of noise, potential for additional

accidents, inadequate drainage, traffic generation, air pollution and lack

of economic benefits.

4.2 Overstone Parish Council – Objected on the grounds of loss of amenity

by way of noise and pollution, additional vehicular movement, intrusion

into the quality of rural life, and sufficient airports already to serve

Northamptonshire. The Parish Council also requested that the application

be considered by the Secretary of State.

4.3 Mears Ashby Parish Council – formerly object to the application. A poll of

residents found 190 voters were against the application, 33 voters were

for the application and 9 were undecided. The Parish Council’s objection

is in respect of noise, the effect on schools, additional local road traffic,

safety issues in respect to air and road traffic and inability to police the

“capping figures” (the conditions limiting the number of aircraft

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movements). The Parish Council also submitted a detailed note on noise

matters and the issues raised have been addressed in consideration of

the application and are addressed in this Report.

4.4 Hannington Parish Council – firmly against a direct enhancement of the

site as detailed in the planning application. This would have a serious

impact on both the social and environmental status of many of the

villages surrounding the airport.

4.5 Orlingbury Parish Council – The Parish Council has no objections to the

plans but would like to see steps taken to prevent any further extensions

being permitted.

4.6 Moulton Parish Council – The Parish Council held a meeting with the

representatives of the applicants’ and STARE. Melton Parish Council

vehemently oppose this application on the grounds of noise pollution,

increased traffic, light pollution, general environmental impact, the

potential for development of a commercial airport and lack of

information on the thickness of the runway.

4.7 Ecton Parish Council – The Parish Council resolved to reaffirm their

previous objections to the application from January 2000 and March

2002. In addition, the objections were made in respect of the increase in

the number of fixed wing Air Traffic Movements.

4.8 Pitsford Parish Council – The Parish Council supports the opposition to

this application and objects to the expansion of Sywell airport on the

grounds of loss of amenity by way of noise and pollution, additional

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vehicular movement, intrusion into the quality of rural life and sufficient

airports to serve Northamptonshire.

4.9 Boughton Parish Council – No objections were received from the Parish

Council although three letters of objection were forwarded by them.

4.10 Brixworth Parish Council – The Parish Council has no objection to the

planning application.

4.11 Holcot Parish Council – The Parish Council objects to the application on

the grounds of increased flights leading to stacking over Holcot village,

increase in road traffic movements and further urbanisation of

Northamptonshire.

4.12 Spratton Parish Council – The Parish Council requests very serious

consideration be given to the increased in air pollution, adverse effect on

surrounding minor roads and possibility of greater noise disturbance.

4.13 Great Goddington Parish Council – The Parish Council objects and raises

the following points - lack of information on increases in road traffic

which is inevitable and with no plans for off site road improvements,

increase in noise, night flights, over flying and fuel dumping. The Parish

Council considers that the application would be best dealt with by way of

a public inquiry.

4.14 Hardwick Parish Meeting – The overwhelming view of the residents of

Hardwick is that the application should be refused on the grounds of

adverse affect on the quality of life currently maintained by residents.

Concerns include the adverse effect of the potential major increase in

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flight activity, increased night flights, increased noise from larger

aircraft, potential for flooding and pollution and increased commercial

and private vehicular traffic.

4.15 Daventry District Council – It was resolved that the District Council raises

no objections in principle to the proposal, subject to the inclusion of

conditions and legal agreements limiting the number of flights, hours of

operation and size of aircraft and establishment of joint consultative

committee, on which the Council would wish to be included.

4.16 Northampton Borough Council – The Parish Council has no objection in

principle to the application. However, members made the following

comments – Wellingborough Borough Council should carefully compare

and contrast the existing and proposed number of flights to ensure the

increase in flights is not excessive, and that the planning obligations

proposed by the applicants be the minimum required. Furthermore

concern is expressed about proposed early morning flights between

0500 and 0700 hours.

4.17 County Councillor Judy Shepard (Moulton Division) –Councillor Shepard

highlights a number of her constituents’ concerns regarding site activity,

increased air flights, size of aircraft, increased traffic movements,

environmental detriment in air quality, noise, dust and loss of local

amenity, and loss of quality of life. A list of conditions are also requested

to be considered.

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4.18 Councillor Cyril Palmer suggests conditions in respect of the control

tower and raised concerns in respect of the noise assessment in respect

of Holot Lane.

4.19 Northamptonshire County Council - Built and Natural Environment in

respect of the archaeological impact, a condition is suggested in respect

of undertaking any necessary archaeological investigations.

4.20 Northamptonshire County Council – Sywell CE Primary School – the Head

Teacher on behalf of children, staff and governors, objects to the

planning application in respect of noise impact and concerns over health

and detriment to education of pupils. Concerns were also raised in

respect of safety and pollution.

4.21 Northamptonshire County Council - Countryside Services (responsible

for Sywell Country Park) – concerns were raised regarding detriment to

visitor enjoyment of the country park as a result of any noticeable

increase in aircraft noise and potential impact on the reservoir from run

off.

4.22 Northamptonshire County Council, Sustainable Development (Highways)

– The Highway Authority initially reported that the information provided

in support of the application within the Road Traffic section of the ES

offers an assessment of trip generation based on a scenario which does

not take account of a possible future increase in traffic flows. It seems

unlikely that the LPA would, or indeed could, impose suitable conditions

that would provide sufficient controls on the number and type of Air

Traffic Movements likely to take place at Sywell Aerodrome.

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4.23 Therefore, without the necessary information to enable a more

comprehensive assessment of the impact, such proposals would have on

the local network, the Highway Authority has no option but to

recommend that the proposal be refused on highway grounds.

4.24 The Director of Sustainability requires that, if consent were to be

forthcoming, improvements to the highway at the narrow section of

Wellingborough Road be carried out and that consideration be given to

creating an amenity weight limit covering Mears Ashby Road

commencing at its junction with Wellingborough Road.

4.25 The applicants made further submissions in respect of the Highway

Authority’s consultation response, including the lowering of the upper

weight limit for fixed wing aircraft from 25,000kg to 16,500kg.

4.26 As a result, the Highway Authority have made a number of comments.

They note that everything hinges on the acceptability (or otherwise) of

the projected Air Traffic Movements and that if the Local Planning

Authority is satisfied that the application should be considered on the

numbers, as stated in the application, and that any permission could be

suitably conditioned, then mitigation measures should be introduced to

counter the effects of the development on the local highway

infrastructure.

4.27 The Highway Authority state,

“Although very little has been offered by the applicant in the way

of mitigation measures thus far, some issues have been raised

throughout the consultation period in respect of highway

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improvements. A scheme to bypass the narrow section of

Wellingborough Road, to the east of Mears Ashby Road, has been

a topic of discussion for some time. Although this does not form

part of the current application proposal, the problems associated

with this section of narrowed highway remain and are likely to

intensify as a result of the development. Local concerns in respect

of road capacity and general highway safety, remain principle

issues as far as local highway users are concerned. It has to be

stated that, given the fact that future traffic generation is based

on statistical projections and the self imposed caps on Air Traffic

Movements, which still has an element of flexibility within the

types and sizes listed, the Highway Authority is not in a position

to allay concerns.”

4.28 The Highway Authority refers to the applicants’ comment that “the owner

and operator of the Aerodrome recognises that there is genuine public

concern about the potential for expansion if the paved runway were to be

constructed” and has suggested conditions to address those concerns.

4.29 Northamptonshire County Council, Sustainable Development (Policy) -

The consultation reply refers to submissions on the previous application.

Those submissions required the application to be determined in

accordance with policy T12 referred to above.

4.30 Environment Agency – the EA originally had no objection to the

application subject to the imposition of conditions. However, the EA

subsequently wrote having considered representations submitted on the

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planning application by LST Construction Consultants on behalf of

STARE.

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The Agency’s revised response is,

“The agency has considered the report (by LST), and we are still of

the view that a detailed surface water drainage strategy is

required. However, given the local interest and the technical level

of this involvement, the Agency considers it advisable to consider

the drainage strategy through an open consultation process. An

obvious option here would be for the surface water drainage

strategy to be drawn up before a decision is made by the Council

regarding the planning application. The Agency would be pleased

to comment on any such strategy that is proposed for the Council

to consider.”

4.31 However, no further objection to the proposal was advanced and the

imposition of a Grampian condition requiring the submission and

approval of drainage details before development commenced was

considered to be reasonable. Therefore the surface water run off and

discharge issues presented by the degree of hardstanding proposed are

considered able to be remediated. The Agency also commented that a

surface water discharge consent would be required.

4.32 The Countryside Agency had no comment in respect of the application.

4.33 English Heritage originally did not consider that the application fell

within one of the relevant categories for consultation. English Heritage

were re-consulted after pointing out the Conservation Area status and

presence of listed buildings within Sywell close to the proposed new

runway. English Heritage replied,

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“The proposed development will not have any direct impact on the

setting of a Grade I or Grade II * listed buildings. However, if as a

result of the findings of the environmental impact assessment,

you are of the opinion that the indirect impacts identified are

sufficiently severe as to have an adverse impact on the amenity

and setting of the historic buildings and conservation area, then

you will need to consider refusal of the application on those

grounds.”

4.34 English Nature does not object to this proposal.

4.35 The Civil Aviation Authority has commented that their involvement

regarding the proposal is one of safety regulations and that the CAA

Aerodrome Inspector is in liaison with the Aerodrome Licensee

concerning the all weather runway.

4.36 Wellingborough Chamber of Commerce fully supports the application as

the proposals can only be of benefit to the Borough from an economic

and social point of view.

4.37 Invest Northampton – refer to the relocation of Northamptonshire School

of Flying to relocate to Deenethorpe and erect 5000sqft of hangar space

next to the existing 1600m hard runway. They point out that

Deenethorpe is used by microlights, a few PFA aircraft and a private

collection of executive type aeroplanes. They point out there is little

infrastructure and part of the investment is to upgrade the existing hard

runway and provide taxiways and offices. They point out that the

management of Rockingham speedway have expressed support for an

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

26

improved facility near Corby to complement their aspirations for

expanding business at the circuit. It is also considered this amenity may

be beneficial to other businesses in the Corby area. (It is pointed out this

letter was not solicited by RPS as suggested in the letter, which the

author of the letter has now acknowledged.)

4.38 Invest Northampton have also stated that good communications will play

an essential part in ensuring growth targets are met and one such

element will involve air transport links which will be a consideration for

investors. Lack of amenities for fast travel will inhibit progress. The

proposal for an all weather runway at Sywell Aerodrome demonstrates to

investors that Northamptonshire is responding to seriously to the

requirement of businesses and is to be commended and therefore the

application should be supported by the Planning Authority.

4.39 Sally Keeble MP has objected on behalf of a number of constituents due

to the increase in air traffic over the north eastern part of her

constituency with profound consequences for local amenity and local

road traffic. Constituents strongly object on the grounds of impact on

the environment, lack of amenities and impact on road traffic. Concern is

also expressed regarding the potential increase in activity and over the

lack of consultation around the wider area. Mrs Keeble strongly opposes

the development. The MP has also written to the Deputy Prime Minister

requesting the application be called in by the ODPM for determination.

4.40 Paul Stinchcombe MP has objected to the planning application due to

harm to residential amenity through noise disturbance and the potential

for more noise through additional Air Traffic Movements. There is also a

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

27

concern that the applicants’ proposed conditions may not be

appropriate. The Mr Stinchcombe also questions the financial imperatives

of funding the development which would lead to pressure for a lessening

of the conditions. The MP has also written further regarding concerns

over the viability of the runway and lack of economic need.

4.41 His further objections can be summarised as follows,

“If the proposed development is conceded to cause environmental harm

unless strict limits on movements are imposed, and the development

would not be viable at those suggested limits, then;

a. The limits may not – arguably – be lawfully imposed by condition

since they would remove the benefits of the condition;

b. In any event, there would be immediate pressure to remove the

limitations;

c. If the application to remove the limitation is refused, a significant

amount of tarmac will uselessly have been deposited in the

countryside and an alternative use of the development will

inevitably be sought, with obvious planning implications.

If the proposed development will cause environmental harm so that it

should be refused permission unless that harm is justified, and the

asserted justification is economic benefit to the region, then that

assertion has to be demonstrated by compelling evidence, otherwise the

planning case is not made out.”

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

28

4.42 Phil Sawford MP has forwarded letters from constituents who feel the

proposals will impact on them despite the fact that the site or Local

Authority fall within Paul Stinchcombe’s constituency. The MP further

wrote that he has received further representations with a few letters of

support but the majority of constituents have very serious and real

concerns about the noise disturbance. Phil Sawford also notes that there

would be potential for the intensification of flying all year round or the

introduction of more powerful engines, regardless of conditions that

would be imposed.

4.43 Stop The Aerodrome Runway Expansion (STARE) are a campaign group

who have organised objections to the application and presented

technical appraisals of the application. These appraisals were forwarded

to the applicants for them to respond to STARE and the Council as they

saw fit. The appraisals and responses were also forwarded to the

Council’s own consultants for consideration as part of their assessments.

4.44 In particular STARE commissioned and submitted five technical

appraisals covering

• Runway design,

• Noise,

• Planning matters,

• Surface water drainage, and

• Air quality.

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

29

4.45 The objections can be summarised as

• Validity of base year Air Traffic Movements figures for assessment

purposes

• Lack of inclusiveness of the ES for all permitted aircraft types

• Concern over proposed flight path in respect of noise, safety and air

pollution,

• Noise data is unreliable and ground noise and other activities are not

assessed

• Concern regarding night flights

• Scepticism of the effectiveness of the noise complaints procedure

• Concern at the over design of the runway

• Potential for increasing the runway length

• The drainage works requiring significant structures; the

environmental implications may be significant and should be

considered before the current application is determined.

• Safety benefits negated by increased risk from extra flights.

• Effect of air pollution and light.

• The ES underestimates the potential impact on road infrastructure.

• There is potential to increase flight activity.

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• The increase in activity is a material change of use requiring planning

consent.

• The proposals will serve more than a local need.

• Harm to the visual environment.

• There is a failure to properly address economic need which is mere

speculation.

• There is a lack of need.

• Lack of consideration of alternatives.

4.46 RPS have considered most of these points independently and all were

taken into account in preparation of this report.

4.47 Around 400 individual letters of objection have been received from local

residents affected by the proposals. Objections relate to issues including:

• Noise • Flood risk

• Traffic • Breach of policy

• Air pollution • Lack of Infrastructure

• Air Safety • Reliability of baseline figures

• General loss of • Future expansion plans

amenity

• Light Pollution • Lack of economic justification

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

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• Intensification • Night flights

4.48 Around 120 letters of support have been received raising issues of;

• Economic benefit

• Safety

• Reliability

• Noise reduction

• Aerodrome viability

4.50 The applicant has also submitted copies of letters written in support of

the planning application WP/99/0525 which proposed a similar form of

development. However, as pointed out above, the development then

proposed was different in respect of the number and type of aircraft

movements proposed. No decision was made on this application as it was

appealed for non-determination and then the appeal was subsequently

withdrawn. Therefore the letters of support are not considered applicable

to the application under consideration.

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5.0 DEVELOPMENT PLAN POLICY

5.1 The Development Plan policy has not changed since Committee

previously considered the application in March 2002, except for the

emergence of RPG8 as RSS published in March 2005.

Regional Spatial Strategy

5.2 The RSS8 covers the East Midlands and aims to focus major investment

toward growth towns, such as Wellingborough. There are few policies

that are directly relevant to the application submitted as aviation policy

directly refers to development at Nottingham East Midlands Airport.

Other airports are described as providing local business and aviation

needs, but are not considered regionally important.

5.3 The Regional Transport Strategy Core Strategy in line with Government

policy, is based on:

• reducing the need to travel, especially by car, and reducing traffic

growth and congestion;

• promoting a step change in the level of public transport;

• making better use of existing networks through better management;

and

• only developing additional highway capacity when all other measures

have been exhausted.

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5.4 The Southern Sub-area objectives are

S1 Developing the transport infrastructure and services needed to

accommodate major planned housing and employment growth

consistent with the Milton Keynes and South Midlands Sub-Regional

Spatial Strategy.

S2 Developing the transport infrastructure and services needed to

support Northampton’s role as one of the region’s five Principal

Urban Areas.

S3 Developing the transport infrastructure and services needed to

support the regeneration of Corby as a place to both live and work.

S4 Developing opportunities for modal switch away from road based

transport in the nationally important freight distribution sector.

S5 Improving access by all modes to the East Coast Ports of Felixstowe

and Harwich.

5.5 The RSS notes that there are also a number of smaller airports within the

region that meet local business and general aviation needs. In

commenting on expansion at Nottingham East Midlands Airport the RSS

goes on to say that expansion of passenger and freight operations at

NEMA is supported in principle, but the impact of development proposals

should be rigorously assessed. This should include consideration of

noise, air quality, water quality, human health, landscape, biodiversity,

natural resources and cultural assets, together with social and economic

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

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effects. The RSS does not consider any further expansion of aviation

facilities to meet any regionally strategic need.

5.6 Policy S3 Water Environment refers to the requirement of sustainable

drainage and that SuDS must be employed in all development proposals

to reduce surface water run-off. No such drainage proposal has been

submitted with this application although the land and intention to accept

a Grampian condition exists.

5.7 The RSS contains a Sub Regional Strategy for Milton Keynes and South

Midlands, which includes Northamptonshire. Strategic Policy 2: The

Spatial Framework — Strategic Transport Infrastructure, refers to

improvements in public transport and road and rail improvements.

5.8 In respect of a strategy for movement the sub regional strategy states

that the movement needs of the growth area will increase in future,

placing further demands on congested roads and inadequate

infrastructure. Consistent with the priorities in the Regional Transport

Strategies, the strategy for the growth area will involve:

• encouraging shift towards more sustainable modes of travel;

• taking advantage of major improvements to the capacity, quality and

accessibility of key public transport facilities;

• increasingly applying demand management approaches to influence

travel behaviour and protect the capacity of the strategic highway

network; and

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• investing in highway improvements to ensure that strategically

important movements are carried out efficiently.

Northamptonshire County Structure Plan (approved March 2001)

5.9 The following policies are considered relevant:

Policy GS1

Policy GS2

Policy GS3

Policy GS4

Policy GS6

Policy RT1

Policy T3

Policies T1

Policy T2

Policy T12

Policy AR2

Policy AR3

Policy AR5

Policy AR6

Policy AR8

Policy RE3

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

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General Strategy for Development

5.10 Policy GS1, refers to strategic growth within the County (CO1 and NPA1

refer to strategic growth within Northampton and Corby Policy Areas.)

5.11 Policy GS2 requires that the provision of land for development will be

guided by the need to conserve important environmental assets,

minimise the impact on natural resources, and make best use of

brownfield land, contaminated land, buildings and infrastructure within

the urban areas.

5.12 Policy GS3 Land Use and Transport refers to the location of development,

in order to reduce the need to travel, whilst improving sustainable

methods of transport and reducing dependency on public car.

5.13 Policy GS4 requires that provision will be made for development to be

primarily concentrated within the urban areas.

5.14 Policy GS6 Infrastructure advises that conditions should be used to

ensure the provision of the necessary infrastructure.

Recreation and Tourism Development

5.15 The aim of this policy is to concentrate major recreation facilities where

they are easily accessible by a choice of transport modes.

5.16 Policy RT1 Major Recreation and Tourism Development indicates that

major recreational facilities are considered suitable in the countryside

only in exceptional cases where the following criteria is applicable:

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

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• Countryside location is justified;

• Major benefit to countryside economy;

• Well related to primary road network and rail services;

• Easily accessible without a car;

• A high standard of design/materials;

• There would be no unacceptable impact on the environment,

local amenity or traffic.

Transport

5.17 Policy T3 Transport Requirement advises that development should only

be permitted where the Local Planning Authority is satisfied as to how

the transport requirements and access needs of development will be

allocated the policy states that:

“Developers will be expected to make financial or other contribution

towards any transport improvements required as a result of traffic

movements generated by the development.”

5.18 Policies T1 and T2 are concerned with integrated transport strategies in

the County and Northampton sub area.

Aviation

5.19 Policy T12 Aviation related Development is the principal policy in relation

to the proposed development and in consideration of its

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

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appropriateness. The policy identifies a criteria to assess the suitability

of such development:

• Scale and nature of development, especially in respect of

activity;

5.20 The proposed hard runway has the potential for constant activity at the

site in the majority of weather conditions, removing physical restrictions

represented by the existing grass runways. The proposed runway will

increase the capacity of the aerodrome and the potential to

accommodate heavier, larger aircraft. Therefore the activity on site could

be considered to materially intensify, resulting in affect on the scale and

nature of the aerodrome.

• Economic and employment benefits;

5.21 The aerodrome represents a link for local business, emergency

deliveries, a base for a number of flight schools as well as aviation

related industry and accommodation such as the hotel. The hard runway

offers increased potential of certainty of the operations for the

businesses based at the aerodrome and using its facilities, which offers

long-term viability for local business and employment.

• Impact on residential properties;

5.22 The aerodrome is located in close proximity to residential dwellings in

Sywell village and Old Sywell village. The dwellings face directly onto the

aerodrome facilities and are directly affected by views and noise of the

aircraft. An increase in activity at the aerodrome, even in the air including

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

39

fly-bys of the runway would cause direct, material harm to the amenity

of those dwellings surrounding the site.

• Traffic Generation;

5.23 As submitted the all hard runway is proposed to allow a greater range of

aircraft to use the runway and allow its continued use during wet periods

and the winter months. However, this in turn may increase the capacity

of the aerodrome and the attraction of its facilities. The County Council’s

Highway Officer has commented that works are required to improve the

access relationship and capacity of the local infrastructure, works which

are recommended to be conditioned to any consent. However, the

increased traffic generation is considered to be a contributory factor to

the harm that the proposal would represent to the character of the area,

nearby Sywell Conservation Area, the local environment and residential

amenity. Therefore the implications of these works are considered

prudent in the assessment of the proposal and are not considered

suitable to be conditioned.

• Environmental Impacts;

5.24 The proposed runway would also alter the varying relief of the existing

landscape, involving the import of substantial amounts of fill. The

development of a large area of impermeable material would have a direct

affect on the level of surface water run-off from the site and has the

scope of reducing the localised permeation to ground waters. No detailed

drainage proposals have been submitted with the proposal and are

intended to be dealt with under a Grampian Condition. However,

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

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guidance in PPG25, the Structure Plan and Local Plan all advise that

drainage should be discharged in a sustainable manner, the method of

which should be designed into any proposal at the initial stages to

ensure the most effective design. The implications of such a scheme,

such as the introduction of a large storage lake and reed beds, should

have been considered by the ES in relation to the implications of local

habitats and the introduction of alien species.

5.25 The proposed hard surface runway offers a storage area for

contaminants such as fuel, oil and brake fluid that would enter any water

run-off and has the possibility of discharging into the local watercourse

and reservoir. Although oil traps and filtration facilities could be

provided, they would not have the capacity during high rainfall to

accommodate the run-off from such a large area of hardstanding.

Therefore such chemical contaminants would be likely to enter the local

watercourse. An adequate Sustainable Drainage System (SuDs), could

prevent this from occurring but has not been provided for in the

proposal, financially, practically or by space allocation. Neither has such

a scheme been compared to the safety requirements of a working

aerodrome. Certain controls of pollutants have been adopted by the

applicant, such as the restriction of de-icing chemicals to prevent entry

into local water bodies and restricting use of the runway in icy

conditions.

5.26 Apart from this the proposed runway may allow for a greater size, variety

and scope of aviation at the aerodrome that could increase the level of

noise, smell, air and light pollution. Also, its development would allow

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

41

greater scope for use of the aerodrome during the night or periods of

poor light, increasing the working hours, level of pollutants and

disturbance.

• Safety;

5.27 The safety of the aerodrome could be considered to improve as a result

of the proposal through use of a man made level landing surface.

However implications from landscaping and drainage facilities have not

been part of the assessment.

• Integration with other transport modes;

• Accessibility.

5.28 This element of the policy requires the aerodrome’s location to fit into

the wider transport strategy, providing links with public transport

facilities and allowing access by cycle and footpaths.

5.29 The Structure Plan explanatory text recognises there are a number of

existing aviation facilities in Northamptonshire which, as well as

providing recreational flying can also help serve local business needs.

The plan notes the Civil Aviation Authority licenses two facilities at Sywell

Aerodrome and Silverstone. Sywell is recognised as being a long

established facility where the amount of activity is not subject to

planning control, and includes flying tuition, aircraft maintenance, high

value freight movements, corporate flights, business charter flights and

recreational flying. Aviation facilities are also recognised at Deanthorpe,

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

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Hinton-in-the-Hedges and Span Holme as well as other former facilities

currently used for a variety of non-aviation related purposes.

Environmental Assets

5.30 Policy AR2 is concerned with conserving and enhancing the landscape

quality of the whole County.

5.31 Policies AR3 and AR5 are concerned with harm to Northamptonshire’s

biodiversity.

5.32 Policy AR6 seeks to conserve and enhance the character, appearance and

setting of Conservation Areas.

5.33 Policies aim to conserve and manage water resources whilst also

incorporating SuDs to attenuate flooding and improve the biodiversity of

proposals. Policy AR8 refers to flood risk reduction, advising that all new

proposals must involve SuDs in order to control the amount of run-off

within a river catchment area.

The Rural Economy

5.34 Development in rural areas should improve job opportunities whilst

conserving the character of rural areas.

5.36 Policy RE3 is concerned with the rural economy and development

within the open countryside which will only be permitted where it is small

scale and essential for the purposes of agriculture, forestry, minerals

development, waste management, recreation or tourism where an open

countryside location is required or related to farming. In considering

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

43

such proposals, regard will be had to impact on the environment, local

amenity and traffic.

The Borough of Wellingborough Local Plan (adopted April 1999)

5.37 Although the Adopted Local Plan pre-dates the Structure Plan it is

understood that the County Council issued a Certificate of General

Conformity in respect of those policies relevant to this application.

5.38 The following policies are considered relevant;

Policy G1

Policy G2

Policy G4

Policy G5

Policy G6

Policy G9

Policy G13

Policy G17

Policy G18

Policy G21

Policy G22

Policy E6

Policy E9

Policy A1

Policy L12

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Policy L14

Policy SY1

Policy G20

Policy G19

Policy L15

5.39 On the Proposals Map accompanying the adopted Local Plan, only those

parts of the Aerodrome, being the industrial estate and business park

together with the Aerodrome facilities are covered by specific policy. The

rest of the Aerodrome, particularly including the runways and taxi ways

are not included in the identified inset area and instead fall within the

general countryside area.

5.40 The northern boundary of the Aerodrome close to the northern end of

the proposed runway follows the boundary of Sywell Wood, which is a

designated Site Of Nature Conservation Value under Policy G18. The built

development area within the Aerodrome and indeed Sywell Old Village

and Sywell village are shown on the Proposals Map as being insets.

General Policy

5.41 Policy G1 includes a general presumption in favour of development

subject to a number of criteria to assess the acceptability of proposals:

• Design Quality - It is not considered prudent to require a ‘high

standard of design’ from the proposal due to its nature and

existing aerodrome character.

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

45

• Amenity - The proposal is considered to affect the amenities of

neighbouring dwellings by reason of noise, vibration, light and

disturbance, in direct contradiction of this policy.

• Access/Parking - The access to the site is considered satisfactory

and sufficient provisions are made for the disabled.

• Highways - The increased traffic movements expected as a result

of this proposal would require highway works that have not been

submitted in detail with this proposal and hence the impact on

highway safety cannot be adequately assessed.

• Drainage - No detailed drainage details have been submitted with

the application and therefore surface water discharge methods, or

the capacity of existing foul water drainage, cannot be adequately

assessed.

• Loss of Agricultural Land - The aerodrome is existing and would

not be extended beyond its existing limits, therefore there would

be no loss of arable land.

• Hazardous pollutants - The existing and proposed aviation

activities do not involve Hazardous substances as listed under the

Hazardous Materials Act.

• Minerals - There are no known mineral resources that would be

affected by the proposal or in the vicinity of the site.

• Sustainability – The site is located in a rural area away from main

public transport interchanges.

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

46

• Security – The proposed works would not encourage antisocial

behaviour or reduce the security of the site.

5.42 Policy G2 Flood Protection requires that new development consider the

implications of flood levels and surface water discharge. Noticeably, it

advises that planning permission should be refused where development

would result in problems due to additional surface water run-off. As

submitted the proposal has the potential for this. Insufficient information

has been submitted to prove that the surface water can be adequately

controlled without undue harm to the character of the area and operation

of the aerodrome.

5.43 Policy G4 identifies “limited development and restricted infill villages”,

which includes Sywell, excluding the old village. Sywell Old Village is

identified separately in Policy G5 as being a “restraint village”.

5.44 Policy G6 Open Countryside identifies criteria for development in the

countryside, namely that it is a use that can only be accommodated in

the countryside, it involves small-scale structures and its location relates

to urban areas but would not result in urban growth of Northampton.

Paragraph 2.15 to Policy G6 states that special consideration will be

given to the industrial areas at Finedon Sidings and Sywell Aerodrome

(policies LH1 and SY1 (sic)).

5.45 Policy G9 Setting of Listed Building refers to the character of the

surroundings of Listed Buildings. Sywell Hall, a Grade II* Listed Building,

directly overlooks the aerodrome. The proposed increase in flight activity

including night flights and expansion of existing capacity would be

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

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considered to have a direct and detrimental affect on the setting of the

Listed Building.

5.46 Policy G13 Conservation Areas refers to development adjacent to

designated areas. The village of Old Sywell is a designated Conservation

Area, close to the application site, the character and setting of which

would be directly affected by the proposal due to the envisaged level of

intensification and altered character of the aerodrome.

5.47 Policy G17 is concerned with development affecting the essential

characteristics of any Site of Special Scientific Interest or local nature

reserve. A SSSI is located on the north side of Sywell Wood adjacent to

Hardwick Lodge.

5.48 Policy G18 refers to Sites Of Nature Conservation Value which would

include Sywell Wood, adjacent to the application site. Policy G18 specifies

that planning permission will not be given for development which would

adversely affect a site designated as a Site of Nature Conservation Value

except where there is no suitable alternative site for the development

and the proposal includes satisfactory mitigating measures to reduce its

impact upon the special interest of the site.

5.49 Policy G21 resists development which would result in the unnecessary

loss or damage to woodland, trees covered by TPO or hedgerows.

5.50 Policy G22 is concerned with the landscaping of development sites.

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

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Economic Policy

5.51 Policy E6 Industry in Open Countryside advises that industrial

development should accord with the policies H1 and SY1 in order to be

considered appropriate in the countryside. Substantial further expansion

of existing industry in the countryside would be contrary to the principle

of restraint that has been adopted in Policy by the Local Plan. Policy

allows for a degree of expansion that meets the reasonable need of

existing firms. The proposal as submitted proposes a substantial

development of the existing facility that is not considered to be

‘reasonable expansion’ in relation to the existing and proposed levels of

activity associated with the aerodrome.

5.52 Policy E9 is concerned with potentially polluting development which will

not be permitted if it is likely to result in unacceptable levels of pollution

by reason of noise, vibration, smell, fumes, smoke, soot, ash, dust, grit,

effluvia, leachates or other emissions by land, water or air, or is

incompatible with nearby uses.

5.53 Policy A1 is concerned with the loss of agricultural land.

Leisure

5.54 Policy L12 Aerial Sports identifies criteria for assessing aviation sports

facilities, such as those provided by the Sywell Aerodrome. Such

proposals should not affect the amenities of nearby residents, offer

suitable measures to reduce noise and visual impact, should not affect

the enjoyment of any public open spaces, have no direct impact on the

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

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ecological environment and such facilities must be accessible by a range

of transport modes.

5.55 The proposed development at Sywell Aerodrome does not accord to

these elements of the criteria due to the impact on the residents of

Sywell village. Furthermore, insufficient landscaping proposals have been

submitted that would mediate the visual harm or help to reduce the

noise from the proposed runway; public vantage points would be

detrimentally affected by physical ground works and earth bunds, whilst

its rural location is only really accessible by private car.

5.56 Policy L14 seeks to protect public rights of way.

Sywell Aerodrome

5.57 Chapter 11 of the Local Plan deals specifically with Sywell Aerodrome.

Para 11.17 of Chapter 11 identifies Sywell Aerodrome in the local context

and states the planning position of the site as required by Structure Plan

policy T12. This is an informative section that establishes the time extent

of the aerodrome use and lists the activities and buildings on site. It

notes that the site is the County’s only significant airfield and is also the

base for 20 – 30 planes and a number of helicopters. It is recognised that

with expanding European markets, there may be increased demands for

these types of services.

5.58 Para 11.19 refers to Sywell Aerodrome as the County’s only significant

airfield and the importance of such an asset in providing services for

local businesses, especially in conjunction with an expanding European

market. The proposed hard runway would allow the aerodrome to meet

Sywell Aerodrome, Sywell May 2005 RPS Planning and Environment

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future demand whilst providing an improved service to clients. Owing to

the importance of the aerodrome it is treated as an exception site by the

adopted Structure Plan. Policies for the future of the site must reach a

balance between the opportunities afforded by an airfield and the

disadvantages of an industrial /commercial site in the open countryside.

5.59 The site constraints are recognised. In particular, additional traffic flows

onto the A43 prior to the ‘Molton to Broughton’ improvement scheme

being implemented, and the narrow approach roads to the complex,

which are inadequate to cope with any material increase in road traffic

movements particularly that of HGV’s. Surface water drainage is also

noted as being problematic and prone to periodic flooding. The

proximity of the aerodrome to Sywell is seen to increase concerns

relating to loss of amenity.

5.60 “The Site”, referred to in paragraph 11.22 is defined as being the

development limits defined on Inset Plan 18 of the Local Plan which

extends only as far as the built development around the business park

and industrial estate. The defined limits of development also relate to the

extent of industrial / commercial development referred to in Policy E6.

5.61 Policy SY1 relates to the limits of development at Sywell Aerodrome as

shown on the Proposals Map. As part of the current application only the

Wellington apron and a small section of taxi way extend into the limits of

development. The policy also states that in all cases, development which

would be likely to lead to an increase in road traffic movements will be

conditional upon any necessary improvements to the highway network.

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5.62 Inset Map 17 of the Local Plan identifies Sywell Hall as an historic hall to

which Policy G20 refers. The policy is concerned with development within

the grounds of such historic halls.

5.63 Also shown on Inset 17 is the Conservation Areas boundary around

Sywell Old Village as well as areas of environmentally important open

space covered by Policy G19 and important amenity areas covered by

Policy L15 within Sywell Old Village.

Conclusions In Respect of Development Plan Policy

5.64 The conclusions to be reached are generally consistent with those

previously put to Committee in March 2002, and whilst development

plan policy does not rule out development at the aerodrome per se

neither does it expressly provide for the development of a hard runway

or an increase in Air Traffic Movements in this location. Any decision

therefore will rest upon weighing the environmental impact against the

economic and employment benefits and whether there are sufficient

reasons for setting aside any significant adverse environmental or noise

implications, in light of policies to protect amenity and the environment,

and to justify the extent of development within the open countryside.

5.65 Policy SY1 is not considered applicable to the determination of this

application due to the location of the application site outside of the

identified inset area which development is restricted to. Therefore it is

considered necessary to determine the application against policies in

respect of development in the open countryside.

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5.66 Regional and Strategic policy does not advocate the provision of further

runway capacity or improvements to GA airfields other than at NEMA.

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6.0 OTHER MATERIAL CONSIDERATIONS.

6.1 Government guidance in the form of Planning Policy Statement 1 –

Delivering Sustainable Development and Planning Policy Statement 7 –

Sustainable Development in Rural Areas is relevant to this application.

6.2 Within PPS1, the Government sets out four aims for sustainable

development. These are:

• social progress which recognises the needs of everyone;

• effective protection of the environment;

• the prudent use of natural resources; and,

• the maintenance of high and stable levels of economic growth and

employment.

6.3 In respect of the protection and enhancement of the environment, the

Government is committed to protecting and enhancing the quality of the

natural and historic environment, in both rural and urban areas. Planning

policies should seek to protect and enhance the quality, character and

amenity value of the countryside and urban areas as a whole. A high level

of protection should be given to most valued townscapes and

landscapes, wildlife habitats and natural resources. Those with national

and international designations should receive the highest level of

protection.

6.4 PPS1, states that the condition of our surroundings has a direct impact

on our quality of life and the conservation and improvement of the

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natural and built environment brings social and economic benefit for

local communities. Planning should seek to maintain and improve the

local environment and help to mitigate the effects of declining

environmental quality through positive policies on issues such as design,

conservation and the provision of public space. Plan policies and

planning decisions should be based on:

• up-to-date information on the environmental characteristics of

the area;

• the potential impacts, positive as well as negative, on the

environment of development proposals (whether direct, indirect,

cumulative, long-term or short-term); and,

• recognition of the limits of the environment to accept further

development without irreversible damage

6.5 In respect of sustainable economic development, PPS1 states the

Government is committed to promoting a strong, stable, and productive

economy that aims to bring jobs and prosperity for all. Planning

authorities should:

(i) Recognise that economic development can deliver environmental

and social benefits;

(ii) Recognise the wider sub-regional, regional or national benefits of

economic development and consider these alongside any adverse

local impacts;

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(iii) Ensure that suitable locations are available for industrial,

commercial, retail, public sector (e.g. health and education) tourism

and leisure developments, so that the economy can prosper;

(iv) Provide for improved productivity, choice and competition,

particularly when technological and other requirements of modern

business are changing rapidly;

(v) Recognise that all local economies are subject to change; planning

authorities should be sensitive to these changes and the

implications for development and growth;

(vi) Actively promote and facilitate good quality development, which is

sustainable and consistent with their plans;

(vii) Ensure the provision of sufficient, good quality, new homes

(including an appropriate mix of housing and adequate levels of

affordable housing) in suitable locations, whether through new

development or the conversion of existing buildings. The aim

should be to ensure that everyone has the opportunity of a decent

home, in locations that reduce the need to travel;

(viii) Ensure that infrastructure and services are provided to support new

and existing economic development and housing;

(ix) Ensure that development plans take account of the regional

economic strategies of Regional Development Agencies, regional

housing strategies, local authority community strategies and local

economic strategies; and,

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(x) Identify opportunities for future investment to deliver economic

objectives.

6.6 One of the key principles of PPS7 is that new building development in the

open countryside away from existing settlements, or outside areas

allocated for development in development plans, should be strictly

controlled; the Government's overall aim is to protect the countryside for

the sake of its intrinsic character and beauty, the diversity of its

landscape, heritage and wildlife, and the wealth of its natural resources

so it may be enjoyed by all.

6.7 The principles also include that priority should be given to the re-use of

previously-developed ('brownfield') sites in preference to the

development of greenfield sites, and that all development in rural areas

should be well designed and inclusive, in keeping and scale with its

location, and sensitive to the character of the countryside and local

distinctiveness.

6.8 In respect of economic, development and employment planning policies

in Regional Spatial Strategies (RSS) and Local Development Documents

(LDDs) should facilitate and promote sustainable patterns of

development and sustainable communities in rural areas. This should

include policies to sustain, enhance and, where appropriate, revitalise

country towns and villages and for strong, diverse, economic activity,

whilst maintaining local character and a high quality environment.

Planning authorities should support a wide range of economic activity in

rural areas. Away from larger urban areas, planning authorities should

focus most new development in or near to local service centres where

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employment, housing (including affordable housing), services and other

facilities can be provided close together.

6.9 Taking account of regional priorities expressed in RSS, and in line with

the policies above, local planning authorities should:

(i) identify in LDDs suitable sites for future economic development,

particularly in those rural areas where there is a need for employment

creation and economic regeneration;

(ii) set out in LDDs their criteria for permitting economic development in

different locations, including the future expansion of business premises,

to facilitate healthy and diverse economic activity in rural areas

6.10 These general principles need to be taken into consideration in assessing

the acceptability or otherwise of the application proposals.

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7.0 APPLICANTS STATED NEED FOR THE AVIATION IMPROVEMENTS

7.1 The ES sets out the applicants’ stated need for the aviation improvements

and these are reproduced below:

“The aerodrome currently suffers restricted use as a consequence

of the operational restrictions of the grass runways, particularly

during the winter months. Water logging can prevent certain fixed

wing flights and limit the movement of emergency service and

maintenance vehicles. Aviation improvement proposals have

therefore been developed by SAL to achieve the following

objectives.

• Provide safer landing and take off conditions for fixed wing

aircraft at the Aerodrome and enable all weather

manoeuvring by emergency service vehicles, further

improving safety at the aerodrome, Sywell village and the

local surrounding area;

• Provide for reliable operations during the winter months

thereby improving the viability of aviation at the Aerodrome

and the viability of resident operators (known as Fixed Base

Operators, or FBO’s);

• Alleviate the issue of peaks and troughs in operation

currently experienced by aviation based businesses at the

Aerodrome due to winter unreliability, thereby ensuring their

long term viability;

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• Provide reliable facilities for the corporate business aircraft,

enabling them to use the Aerodrome all year round;

• Improve the image of the aerodrome, which is likely to

improve rental levels being achieved in the adjacent business

park.”

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8.0 ANALYSIS

8.1 The key issues identified from the above background information are;

• Planning Policy

• Environmental Impact

• Technical

• Amenity

• Need

Planning Policy

The key policy considerations are

¾ Local Plan policies

• G1 – General Policy

• G6 – Development in the Open Countryside

• G9 – Setting of Listed Buildings

• G13 – Conservation Areas

• E6 – Industrial and Commercial Development in the Open

Countryside

• E9 – Potential Polluting Development

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• L12 – Aerial Sports

¾ Structure Plan Policies

• RE3 – Employment Uses in the Open Countryside

• AR2 – Landscape Character

• T12 - Aviation Related Development

8.2 It is not considered that the proposal will respect or enhance the

character of its surroundings and would adversely affect amenities of

neighbouring properties resulting in widespread impact by reason of

increased noise and activity. The findings in respect of impact on the

road network are not conclusive. The proposal is not considered to be

consistent with the principles of sustainability. The proposal is likely to

result in unacceptable levels of pollution by reason of noise and general

disturbance. It is incompatible with nearby residential and other noise

sensitive uses and would be detrimental to the general public’s

enjoyment of nearby recreational facilities. Neither is the site accessible

by a range of public transport modes.

8.3 The proposal is therefore considered to be contrary to adopted Local

Plan policies G1, E9, L12

8.4 The proposal represents commercial development in the open

countryside involving more than a limited, small-scale structure essential

for the purposes of agriculture, forestry, minerals or waste development.

It is not a modest extension and will result in a material intensification of

the use outside of the limits to development. The proposal will not

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conserve and enhance the landscape character and does not respect the

local character and distinctiveness of the landscape.

8.5 The proposal is therefore considered to be contrary to adopted Structure

Plan policies AR2 and RE3 and adopted Local Plan policies G6 and E6.

8.6 Neither the Structure Plan nor any other development plan document

makes special provision for the development of aviation facilities, (other

than NEMA). Structure Plan policy T12 sets out criteria, against which

aviation development proposals must be judged. Considered against

those criteria particularly in respect of scale and nature of the proposal

compared to existing activity, impact upon residential and other noise

sensitive properties and other environmental impacts, the proposal is not

considered acceptable. Other criteria in respect of economic and

employment benefits and safety do not outweigh these other

considerations.

Having considered the proposal against the criteria in Policy T12 it is not

considered acceptable.

Environmental Impact

8.7 The main issues in respect of the impact on the environment are the

visual impact of the physical works and the pollution effects; particularly

noise in consideration of its impact on amenity.

8.8 Construction of the runway requires earth works to raise ground levels to

provide the Runway End Safety Area’s particularly at the southern end of

the runway close to Holcot Lane. These earth works were commenced

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without planning approval. The Council instigated enforcement action in

respect of the unauthorised earth works. Effectively this application

includes a retrospective application for those earth works. In authorising

the enforcement action, the Council stated,

“ the current construction works are considered to have significant

adverse impact on the character and visual amenities of the local

area being in close proximity to a Conservation Area and two Sites of

Nature Conservation Value.”

8.9 The technical appraisal of the runway design has indicated the southern

Runway End Safety Area is excessive for the proposed use of the runway.

Whilst over design is not itself an issue, in this case the over design

raises environmental issues in respect of visual impact over which the

Council has taken enforcement action.

8.10 Other work is ongoing at the Aerodrome. Hedgerows along Holcot Road

have been removed and replaced with palisade fencing. Engineering

operations are also continuing to raise levels at the Wellingborough Road

end of grass runway 15/33. This is said by the applicant to allow the re-

orientation of the runway to prevent over flying of Mears Ashby village.

Other refurbishment of buildings within the aerodrome is also

proceeding. None of these additional works form part of this application

or were assessed as part of the ES.

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Technical

8.11 With regard to the ES, there are two fundamental issues. Firstly, there is

the issue of the baseline figures, used to express the impact arising from

the additional air traffic movements and secondly, whether the full range

of aircraft included within the proposed conditions have been assessed.

Both matters have been raised with the applicant and a response sought.

8.12 The concern in respect of the baseline figures, is that in general the ES

considers that any impact is derived from the change to the environment

from the baseline to the proposed capped level. The magnitude of the

change will therefore be defined by the baseline level and the capped

level which is fixed. There is concern that the baseline figures are

unreliable for two reasons. Firstly, the baseline figures used in the ES

have taken a continuous 12 month period spanning 2002-2003. This 12

month period is the highest 12 month period from January 1998 to

December 2003. It is higher than any single individual year and is also

higher than an annual total using the average of each month. Clearly the

effect of having an inflated baseline year is to minimise the change in

environmental effects. This is discussed further in TPS’s Technical

Appraisal.

8.13 The applicants have subsequently provided further analysis based on a

seven year average flight activity. That analysis showed a higher noise

level for the baseline using a seven year average. The effect of such

averaging is to reduce the baseline number and therefore noise of fixed

winged aircraft but to increase the baseline number and therefore noise

of helicopters. The combined effect being to increase the baseline noise

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such that the degree of change is less. However, that average increase in

noise was as a result of an increase in noise from helicopter movements.

Helicopter movements were considered to be constant throughout the

year. However, flight data previously provided by the applicants, indicate

that landings and take offs by helicopters during summer months can be

around three times the number compared to winter months. As such, the

analysis will have over estimated the baseline noise level in winter

months; with the proposal aiming to spread future flight activity evenly

over the year, the change during Winter months will be greater than

predicted.

8.14 Secondly, the ES states in Section 2.3 that air traffic movement at Sywell

Aerodrome over the last six years (1998 – 2003), as recorded in the

Aerodrome Control Tower Log, is presented in Table 2A. The Council

requested the control tower log referred to in the ES as the source of

baseline Air Traffic Movements. The applicant provided this and

confirmed it as being a record of every movement of an aircraft, take off,

landing and “touch and go” movement. “Touch and go” movements are

practice/training laps where pilots land and take off without stopping.

However, examination of the control tower log provided by the applicant

showed that in individual months the number of Air Traffic Movements

recorded by the control tower are around 50% lower than the figures

used in the baseline figures.

8.15 The importance of this discrepancy is emphasised when the ES states

that baseline aircraft noise levels are close to the onset of significant

community annoyance, according to the PPG24 criterion. However, these

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noise levels are modelled based on the input data used in the ES rather

than from noise monitoring at the Aerodrome itself.

8.16 The applicants have subsequently clarified that the Aerodrome control

tower log originally supplied does not contain all Aircraft Traffic

Movements, specifically it does not include “touch and go” movements.

The applicants supplied an example of the complete Air Traffic

Movement log for one day that shows that of 321 total movements, 194

were “touch and go” movements. On an annual basis, “touch and go”

movements represent around 50% of all Air Traffic Movements at the

Aerodrome. This is significant, as the ES has assumed all “touch and go”

movements to be in the aircraft category with a relative noise level of

0dB. As such the analysis is based on a favourable assumption in respect

of half of all Air Traffic Movements.

8.17 The Air Traffic Movements in the control tower log which excludes “touch

and go”, include helicopter as well as microlight movements. Analysis of

that data revealed that microlights contributed around 25-30% of fixed

wing Air Traffic Movements and that helicopters make up around 20% of

all Air Traffic Movements annually. This proportion rises in the winter

months when fixed wing movements are reduced.

8.18 It is certainly local perception that Air Traffic Movements are significantly

lower than that reported in the ES for the baseline year, which, for

August 2003, represented around one movement every 2 minutes for a

ten hour daytime period.

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8.19 The applicant has stated that four flying schools were operating at the

aerodrome in November 2004. These were Northamptonshire School of

Flying, Sloane Helicopters, Pulse Helicopters and UK and American

Helicopters. Northamptonshire School of Flying which operates 10 fixed

wing aircraft is to relocate in March 2005 and SAL intend to establish a

replacement flying school. The applicants have also stated a fourth

helicopter flying school will be established in the near future.

8.20 Concern has been expressed that the baseline pattern of Air Traffic

Movements, including fixed wing and microlight “touch and go”

movements, upon which the ES is based, could alter dramatically as a

result of the hard runway with microlight flights etc being replaced in the

number quota by more intrusive Air Traffic Movements which could also

alter road traffic movements.

8.21 Single seater microlights and Cessna 206 Stationairs are in the same

weight category of below 2,731kg for which the applicant is seeking

permission for 77,200 Air Traffic Movements per year. The Cessna can

carry up to 6 people and has a relative noise level of +8dB; microlights

have a relative noise level of 0dB. The applicants quote an example of a

microlight flight which included 7 “touch and go” movements which

equals 16 Air Traffic Movements. These 16 Air Traffic Movements could

be replaced in the number quota by 8 separate departures and arrivals

by the Cessna. This could generate 48 people arriving and departing the

aerodrome in separate cars compared the single trip for the microlight

pilot. This would also cause 16 noise events of +8dB compared to 0dB.

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8.22 In respect of the range of aircraft being assessed, the applicants were

originally seeking consent for the hard runway limited in use by

condition to fixed wing aircraft up to 25,000kg. The ES, however, only

assesses fixed wing aircraft up to 15,649 kg. This point was raised

specifically with the applicants whose response refers to the use of the

aerodrome by Chinook Helicopters. However the condition is specific to

fixed wing aircraft, and helicopters of any weight will not use the runway.

The applicants also claim enhanced versions of present aircraft will be

quieter than the present fleet. However, none of the enhanced versions

mentioned by the applicant exceed 19,505 kg.

8.23 The applicants have subsequently requested that the application be

amended to refer to an upper weight limit of 16,500kg (excluding

military and security service aircraft). In that respect, therefore, the ES

more closely assesses aircraft in the weight limit proposed by the

applicant.

8.24 The use of the runway by the Dakota DC3, which the ES acknowledges is

the noisiest of the aircraft assessed and which has historically used the

aerodrome, is not assessed because they are “not expected” to visit the

Aerodrome. These would be permitted, however, under the weight

condition.

8.25 There is concern expressed by residents and local MP Paul Stinchcombe

that the current application represents only an initial stage of a larger

project. This is on the basis of the over design of the runway and taxi

ways for the level of Air Traffic Movements currently proposed, the

financial viability of the current proposed Air Traffic Movements not

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supporting the cost of the works and other operations being undertaken

or previously proposed at the aerodrome. Reference is made to the High

Court decision in respect of R v Rochdale Metropolitan Borough Council

ex parte (1) Tew, (2) Milne, (3) Garner whereby it was held that an EIA

must consider the whole of a project. There is, however, no firm evidence

that Air Traffic Movements will increase beyond those currently

proposed. Furthermore, the Council’s solicitors have pointed out that in

another case the High Court has held that there “…is no requirement to

carry out an environmental assessment of future aspirations or

ambitions” (R (Portland Port Ltd) v Weymouth and Portland BC [2002]

J.P.L. 1099)

8.26 Concerns raised by the County Council’s, Sustainable Development

Department in respect of highway improvements raise issues that have

not been addressed in the planning application in respect of works to

overcome these highways problems. Relatively significant road works

have been previously proposed involving the realignment and partial

closure of some roads around the southern perimeter of the aerodrome.

These, or any other proposal required to overcome highway difficulties,

do not however form part of this application.

Amenity

8.27 The issue is the loss of amenity suffered by residents and other noise

sensitive users from the intensification of aircraft movements; the scale

of that intensification has been described in this report. Such

intensification and loss of amenity is more manifest in respect of noise

disturbance caused by the increase in aircraft movements above

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residential properties around the aerodrome. Due to the proximity of the

application site to Old Sywell Conservation Area and the listed Sywell

Hall, the proposed intensification of activity and subsequent material

change in use is considered to cause harm to the character of the

conservation area contrary to Policy G13 and would be detrimental to the

overall setting of the listed building in conflict with the aim of Policy

G12.

8.28 The ES states that, “baseline aircraft noise levels are close to the onset of

significant community annoyance, according to the PPG24 criterion. If

the greater sensitivity to general and business aviation noise is taken

into account, as found by the 1988 Department of Transport study,

summer average noise levels would be regarded as clearly above the

onset of significant community annoyance.” (ES page 46).

8.29 In the covering letter to the application for the works to grass runway

15/33, the applicants state,

“The existing grass runway 15/33 alignment is constrained by the

local gradients at its eastern end. The present alignment requires

aircraft using that runway to pass overhead Mears Ashby at low

altitude, which can be of nuisance to residents of Mears Ashby,

particularly in the summer weekends when they are out in their

gardens. Additionally, aircraft taking off in an easterly direction

climb out over this village at full power, as the village is only

1,500 metres from the end of the runway…

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If the area was filled and graded, this would enable us to rotate

the runway anti-clockwise thereby taking the aircraft away from

the village…which would have benefits in terms of a reduction in

noise and an improvement in safety for the residents of Mears

Ashby.”

8.30 It is felt therefore that an increase in aircraft numbers, size, and

frequency would exacerbate this current position.

Need

8.31 In respect of the applicant’s stated issues of need, it is felt that the

application goes beyond that necessary to provide for safer landings in

the extent of physical works and the increase in Air Traffic Movements.

The runway continues to be licensed by the CAA.

8.32 Users of the aerodrome have said that water logging of the existing

grass runways only results in closure of the runways for around 10/12

days per year at times when demand is low in any case. They also point

out that cross winds on certain days would mean the hard runway would

be unsuitable for all but fully trained pilots in appropriate aircraft. In

addition with the runway being closed when frozen, the hard runway will

not guarantee year round availability.

8.33 Despite claims that the hard runway will allow smaller planes to take off

on shorter distances, the hard runway is still around 150m closer to

Holcot Lane than the grass runway and the full length of hard runway will

be used for take off and landings.

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8.34 Peaks and troughs relate to general weather conditions unrelated to

water logging i.e. poor visibility and wind directions. Peaks and troughs

also reflect the leisure use of the aerodrome and the propensity of users

to fly in winter months. The same pattern of peaks and troughs are

apparent in helicopter movements that are not affected by runway

conditions.

8.35 Corporate facilities could be provided at alternative locations with less

potential for environmental harm. Any need for regional corporate

facilities should be addressed in the Regional Planning Guidance or

Regional Spatial Strategy. A strategic review should be undertaken to

identify a suitable location for such facilities if a need is justified.

8.36 Invest Northamptonshire have indicated that Deenethorpe may be an

alternative and already has a 1600 meter hard runway, used by

microlights, private fixed wing aircraft and a private collection of

executive type aeroplanes. Whilst there is little infrastructure there is

planned investment to upgrade the hard runway, provide taxiways/roads

and offices. The East Northamptonshire Local Plan notes that permission

has been granted for the use and development of the former

Deenethorpe Airfield for passenger and freight handling.

8.37 An increase in rental levels for adjacent business occupiers would not

provide any community benefit and which may be detrimental to those

businesses.

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9.0 SUMMARY

9.1 The risk of, or potential for, harm from this proposal - resulting from the intensification of the lawful use - to the environment, amenity and the

Conservation Area is high.

9.2 The application proposes permitting an increase in Air Traffic Movements

to 96,7000 per year from a claimed level of 52,442 in 2004, 67,122 in

2003 and 55,623 in 2000. Such an increase represents an intensification

in use of 84%, 44% and 74% respectively.

9.3 The extent of the physical works, 1,000 metre runway, parallel taxi way

and raising of ground levels amounting to 8 hectares of hard surfacing,

is not justified within the open countryside.

9.4 Notwithstanding the Council’s consultants view on the methodology of

the noise assessment it is not considered that the conclusion - that noise

impact will be negligible - are reliable for the reasons set out below.

9.5 The ES states “baseline aircraft noise levels are close to the onset of

significant community annoyance according to PPG24 criteria” (page 46).

In the application for works to grass runway15/33 the applicants state

that aircraft using that runway pass overhead Mears Ashby at low

altitude, which can be of nuisance to residents of Mears Ashby, which is

only 1,500 metres from the end of the runway. Given the relative

proximity of Mears Ashby and Sywell to the runways, it must be expected

that the impact of overflights of Sywell would be worse and such impact

would increase with additional flights.

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9.6 The Council has already indicated that the unauthorised earth works have

a significant adverse impact on the character and visual amenities of the

local area. There is no justification for the extent of these works, even

were it accepted that the hard runway was justified. The adverse impact

from these engineering operations needs to be weighed against any

benefits the hard runway may bring.

9.7 In the absence of any over riding considerations to outweigh this potential harm, including any tangible economic benefits, which could not be met elsewhere, there is no reason to risk such environmental harm and permit development in the open countryside.

9.8 In the event members are minded not to accept this recommendation, it

is considered necessary that additional information would be required as

set out in Appendix A before positive support can be given to the

proposal.

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10.0 RECOMMENDATION

10.1 It is recommended that planning permission be refused for the following reasons:

1. The proposed development would result in an unacceptable

intensification of flying activity amounting to a material change in the

character of use which would adversely affect the amenities of nearby

residents by reason of noise and general disturbance, whilst causing

detrimental harm to the character of Old Sywell Conservation Area

and to the setting of the listed Grade II* Sywell Hall, contrary to

adopted Local Plan policies G1, G9, G13, E9 and L12 and adopted

Structure Plan policy RE3.

2. The proposed development would result in an unjustified and

unacceptable impact on open countryside contrary to the provisions

of adopted Local Policy G6 and E6 and as such would not serve to

conserve or enhance the local landscape character contrary to

adopted Structure Plan policy AR2 and RE3.

3. The proposed development when considered against the criteria set

out in adopted Structure Plan policy T12 is deemed to be

unacceptable, specifically for the following reasons:

V. the scale and nature of the proposed development is

inappropriate for the existing amount of activity on the site

VI. the economic and employment benefits are not justified

VII. the impact on residential property is unacceptable

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VIII. environmental impacts are unacceptable.

10.2 As part of the Council’s Statement of Case, the First Secretary of State, to

whom this application has now been recovered for decision, should be

advised that the Council’s decision would have been in accordance with

the above recommendation had an appeal not been lodged.

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APPENDIX A

11.0 ENVIRONMENTAL IMPACT ASSESSMENT

11.1 The environmental effects of the proposal are considered in turn as they

appear in the ES submitted by the applicant. Those comments shown in

italics have been taken directly from the Executive Summary to Sywell

Airport ES Review Entec February 2005 and Planning Application for a

Hard Surface Runway at Sywell Aerodrome – technical appraisal TPS

Consult January 2005.

Planning Considerations (including the Development Plan)

11.2 Issues in respect of the Development Plan have been addressed above.

However, in respect of an assessment of the impact on policies in the

Development Plan, the ES has not addressed all relevant environmental

policies or in considering the impact on the Development Plan in total. As

such it is not a fully balanced assessment of the impact on the

development plan. This has not however prevented a full consideration of

Development Plan policy in considering the application.

Noise

11.3 The initial review of the ES found that the assessment of noise effects

was not sufficient to enable the noise impact of the proposed

development to be assessed as there were major inaccuracies in the

report. However, the issues raised have been satisfactorily addressed in

the ‘Response to RPS questions on noise’ compiled by Peter Moore

(received from Kember Loudon Williams (letter dated 17/11/04) via RPS)

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although details of how the increase in noise levels, relating to the hard

surface of the runway, have been calculated have not been provided.

11.4 Other omissions include potentially inaccurate baseline data relating to

aircraft movement. This may have given higher numbers of aircraft than

exist in reality, which in turn may have led to inaccuracies in the noise

assessment. The methodology for assessment is unclear and difficult for

a non-specialist to understand. The impact of noise levels on the ground

has only partially been assessed. Finally there has been no verification of

the baseline noise modelling.

11.5 Some of these issues have subsequently been addressed by the applicant

and are referred to elsewhere in this report. These comments relate to

the process of reaching the conclusions on noise and not to the

conclusions themselves. This report comments elsewhere on the

conclusions themselves. Despite these potential shortcomings in the

noise assessment it was felt there was sufficient information within the

ES to come to a view on noise.

Road Traffic

11.6 Impact from road traffic has been assessed by the County Council’s

Sustainable Development Department whose comments have been

reported. No required traffic works have been environmentally assessed.

Surface Water Quality and Drainage

11.7 The comments of the Environment Agency in respect of surface water

drainage are set out above.

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11.8 It is considered that the water quality section of the ES should be given

an IEMA ES review grade D, “Parts well attempted, but must as a whole be

considered unsatisfactory because of omissions and/or inadequacies.”

11.9 The comments of the EA were passed to the applicant who responded by

stating a negative condition would be acceptable to control drainage

works. Given the concern over the principle of development it was not

considered reasonable to request drainage details that would not alter

this position.

Socio- Economic Effects

11.10 The ES states that there are currently no plans to increase the number of

full time or part time employees on completion of aviation improvement

works. However, with the increased air traffic movements, additional

staff may be required in the future.

11.11 Overall the socio-economic effects appear to be somewhat optimistic in

respect of the wider impact of the all weather surface and do not appear

to be supported by any firm evidence.

11.12 Economic benefits can be divided between those which benefit Sywell

Aerodrome and those which benefit the rest of the local economy. No

consideration has been given as to whether the wider economic benefits

could be delivered from alternative locations with less environmental

impact. EIA guidance requires an assessment of alternatives, the ES has

only considered alternatives to the hard runway at Sywell and not to

meeting any need for corporate business aircraft from alternative

locations.

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Air Quality

11.13 Although there were some omissions in the Air Quality chapter, these

were minor and the additional information sent by Kember Loudon

Williams provided further information in relation to the identified

omissions. The Air Quality chapter is considered to reach the correct

conclusions and allows the impact of the proposed development on air

quality to be assessed.

Ecology and Nature Conservation

11.14 While the ecology and nature conservation section is considered to be

sufficient to allow an informed decision to be made as to the effects of

the proposal, it is considered that there are minor omissions within the

section. Many of these omissions have been addressed through the

provision of additional information from Kember Loudon Williams.

11.15 Omissions in the Ecology chapter included a lack of information in

relation to Great Crested Newts and whether there were any records of

this species at the site. There was also no reason provided as to why the

balancing pond at the site was considered unsuitable for amphibians.

11.16 The comments of Judge Gibbs in respect of the judicial review hearing

are relevant where he stated that as a matter of fact there are no great

crested newts anywhere near the site.

Community and Public Safety

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11.17 Community issues are addressed in respect of noise and air pollution. In

respect of public safety the use of the aerodrome at present and in the

future is strictly controlled by the CAA to ensure safety measures are

commensurate with the use of the aerodrome.

Landscape and Visual Amenity

11.18 The assessment is considered flawed in the fact that it does not provide

an “audit trail” from the conclusions about the significance of effects to

assertions about the sensitivity of a receptor and the magnitude of

predicted change. The methodology as provided in the information from

Kember Loudon Williams usefully provides the author’s definition of

magnitude of change and sensitivity to change. It does not state how the

two have been combined to suggest significance.

11.19 There are weaknesses in the description of baseline situation. The

baseline description of the creation of earthworks at the southern end of

the runway as presented is inadequate to enable an objective assessment

of the landscape and visual effects of such a change. Additional

information from Kember Loudon Williams elaborates slightly upon the

chosen baseline in the landscape and visual assessment. However, a

clear baseline description of the area supporting the new landform or a

description of views of that area before construction started has still not

been provided and this must remain an omission.

11.20 The assessment lacks clarity. This is partly due to the lack of a clear

structure differentiating between predicted effects upon landscape

features and elements, effects upon landscape character and effects

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upon the visual environment (i.e. changes in views). The assessment

appears to confuse effects upon landscape character with visual effects.

11.21 There is insufficient justification of mitigation proposals and there is

little description of why the proposed mitigation would be effective.

11.22 The inclusion of the earth bunds along Holcot Lane have been considered

as part of the general assessment of the proposal in this report, it is not

felt that the other shortcomings referred to prevent a consideration of

the proposal.

Cultural Heritage and Archaeological Resources

11.23 The baseline information provided in the ES and subsequent

archaeological field evaluation and geophysical reports (sent from RPS via

Kember Loudon Williams’ letter dated 27/10/04) is comprehensive and

provides an appropriate basis for the assessment. The principal issues

have been addressed in the assessment and the proposed mitigation is

appropriate. It is also stated that this has been agreed with the relevant

consultee. However, the effectiveness of the mitigation will be

dependant upon the details of how this will be implemented, and very

little information on this is provided. It is stated that the details of the

mitigation will be agreed with the local authority. The success of the

mitigation will be wholly dependant on it being implemented in

accordance with a scheme agreed by the local authority, presumably tied

to a condition on any planning permission.

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Geology and Soils

11.24 No adverse impacts are anticipated in respect of geology and soils.

Land Use and Waste Management

11.25 It is considered that with regards to geology, the Geology and Soils

chapter should be given an IEMA ES review grade C “Satisfactory, despite

omissions and inadequacies” but that with regards to land quality issues,

this chapter should be given an IEMA review grade D “Parts well

attempted, but must as a whole be considered unsatisfactory because of

omissions and/or inadequacies”.

Alternatives Considered

11.26 Part of the ES process is the consideration of alternatives to the proposal.

The alternatives considered by the applicant were;

• Continued Operation of the Existing Runway. (The “do nothing”

alternative)

• Use of geotextile mesh – a geotextile earth reinforcement mesh was

installed along the northern half of the runway in the 1970’s. It is said

this mesh is no longer performing.

• Improvement works to the Existing Runway – this would involve

removal of the grass surface and topsoil followed by levelling the

subsoil and re-seeding. SAL say this would take up to three years and

would not prevent water logging

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• Stabilisation of Existing Runway using cement/lime – this would not

prevent water logging and would inhibit grass growth.

11.27 The ES only need to consider alternatives studied by the applicant.

Overall Conclusions

11.28 The conclusion reached, taking into account the High Court’s comments

on the previous decision, on an overall assessment of the evidence

presented, and judging whether it satisfactorily demonstrates that there

will be no significant harm, is that no convincing argument has been put

forward to demonstrate a lack of harm.

11.29 Given that there was an objection in principle to the development in

terms of the intensification of use and material change in use it was not

considered reasonable to request further information from the

application, which would not address these fundamental points.

11.30 Given the existence of sound and clear cut reasons for refusal based on

the adverse impact on amenity and countryside character in terms of the

intensification of use, material change in use and unjustified

development within the open countryside, it has not been considered

necessary to request further information from the applicant which would

not address these fundamental points.

11.31 If members were minded to approve the application subject to conditions

and the satisfactory completion of a S106 Agreement in respect of off

site works and obligations, the following information should be

requested from the applicant for consideration by the council.

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• A full analysis of all Development Plan Policies and analysis of the

impact on the development plan as a whole.

• A full analysis of all those aircraft types which could use the proposed

runway.

• Proposals for off site highway works to the satisfaction of the County

Council

• Full details of surface water drainage proposals

• Full landscape and visual assessment

• Full consideration of alternatives including use of or development of

hard runways in alternative locations

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