Planning Committee Agenda Item 9 5 June 2013 12/01377/F

TO: PLANNING COMMITTEE

DATE: 5 June 2013

REPORT OF: HEAD OF POLICY, DEVELOPMENT AND PROPERTY AUTHOR: Andrew Benson

TELEPHONE: 01737 276 2175

EMAIL: andrew.benson@-.gov.uk AGENDA ITEM: 9 WARD: and Whitebushes

APPLICATION NUMBER: 12/01377/F VALID: 8 August 2012 APPLICANT: Ltd. AGENT: Terence O'Rourke Ltd. LOCATION: REDHILL AERODROME, KINGS MILL LANE, REDHILL DESCRIPTION: Construction of hard runway to replace existing grass runways and ancillary infrastructure comprising realignment of existing taxiways, drainage improvements, replacement runway lighting and new approach lighting All plans in this report have been reproduced, are not to scale, and are for illustrative purposes only. The original plans should be viewed/referenced for detail.

SUMMARY

This is a full application for the replacement of the existing grass runways at Redhill Aerodrome with a new hard runway, of east-west alignment, together with associated infrastructure including new approach lighting, perimeter taxiway realignment, drainage improvements and habitat management.

The application follows a similar proposal, refused by the Planning Committee in 2011 on green belt and highway grounds. The current revised proposals have attempted to reduce the landscape and noise impacts of the development and the applicants have taken the opportunity to represent/reargue their case for development. The amount of hard-standing proposed has been reduced with the proposed runway width now narrower at 25 metres wide, rather than 30 metres as previously proposed. The runway would be longer than the previous application, at 1,349 metres long, although the take- off and landing distance available would remain 1,199 metres long, identical to the previous application. There has also been a reduction in the amount of cut and fill required to achieve the suitable runway gradient so reducing the topographical impact and the flight path has been adjusted to the east to move aircraft away from properties in South Nutfield and Henhaw Farm. The additional length of the runway would enable aircraft to reach a higher altitude, sooner than was previously proposed, so reducing the impact of overflying in nearby areas. It would also allow all approach lighting from the west to be located within the aerodrome boundary.

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Since the previous application was determined the planning policy framework has changed. Although the adopted Borough Local Plan is still the Development Plan for decision-making purposes, any policies within it must be considered alongside those within the National Planning Policy Framework (NPPF), published in March 2012. The NPPF does not mention airports or airfields with regards to determining planning applications but does state: “When planning for ports, airports and airfields that are not subject to a separate national policy statement, plans should take account of their growth and role in serving business, leisure, training and emergency service needs. Plans should take account of this Framework as well as the principles set out in the relevant national policy statements and the Government Framework for UK Aviation.”

The NPPF also reinforces a presumption in favour of sustainable development, stating that decision-makers should be: “approving development proposals that accord with the development plan without delay; and where the development plan is absent, silent or relevant policies are out‑of‑date, granting permission unless: –– any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or –– specific policies in this Framework indicate development should be restricted”

The site is located within the Green Belt where a presumption against inappropriate development remains, with the NPPF stating: “As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.”

Policy Co1 of the Borough Local Plan seeks to maintain the open character and functions of the Green Belt, commenting that inappropriate development will not be granted unless justified by very special circumstances. It is therefore compliant with the NPPF and can be given due weight. Policy Em12 of the Borough Local Plan states that the Borough Council will normally resist any development at Redhill Aerodrome which is likely to result in the intensification of its use for flying and related activities. The reason for this policy is to prevent inappropriate development within the Green Belt and the policy is therefore compliant with the NPPF but, really only serves to duplicate the objectives of Policy Co1. For this reason it is considered that as a specific policy it should be given less weight in light of the publication of the NPPF.

The Councils assessment is that the proposals would conflict with the purposes of including land in the green belt and would not preserve openness, and that accordingly the proposed development constitutes inappropriate development within the Metropolitan Green Belt which should be resisted unless very special circumstances

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The very special circumstances put forward by the applicant are as follows:  Increased employment associated with the aerodrome to a total of 590 jobs (currently 450);  Generation of a total of £27.5m added value to the economy, an increase of £8.2m;  Safeguarding of existing and future jobs because it is likely that the existing business is unsustainable;  Stimulation of economic growth in the local area and improving its attractiveness to businesses;  Assisting local businesses to grow and develop to the benefit of the local economy;  Making more efficient use of an important part of the national transport infrastructure, enabling existing aviation capacity in the south east of England to be utilised effectively;  Provision of biodiversity, drainage and operational safety improvements;  Realignment of runway approach over Gap;  Provision of strict limits and operational controls through planning conditions and/or Section 106 Agreement.

In order to give serious consideration to the economic and employment benefits, set out by the applicant as very special circumstances, the Councils (RBBC and Tandridge) jointly appointed an economic consultant from Portsmouth University to independently assess the case, information and figures advanced by the applicant.. It was not disputed that the proposed development had potential to create up to 140 new jobs and £8.2m GVA (Gross Value Added). This was broadly accepted at the time of the previous application and had not changed. That specific circumstance was given only limited weight since it was considered that such an argument could result in many instances and forms of unacceptable development which would be harmful to the Green Belt. Appeal case law has established that business expansion plans do not necessarily amount to very special circumstances.

The potential for the proposed development to secure the future of the 450 jobs associated with the Aerodrome has been carefully considered. The possibility of these jobs being lost, if planning permission were refused, is potentially a very special circumstance which could be judged to outweigh the harm caused. However there has been limited evidence put forward by the applicant to demonstrate that the Aerodrome would be forced to shut without a hard runway. It is claimed that existing businesses would vacate without a hard runway but those same businesses moved to the site in full knowledge of its limitations and nothing has changed in that regard. The applicants also assume a decline in aviation movements which would impact the Aerodrome but, when estimating the potential growth in jobs and GVA from the hard runway, assume a

M:\BDS\DM\Ctreports 2013-14\Meeting 1 - 05 June 13\Agreed Reports\12.01377.F - Redhill Aerodrome, Kings Mill Lane, Redhill.docx Planning Committee Agenda Item 9 5 June 2013 12/01377/F general increase in aircraft movements. None of the businesses operating at the site rely on a hard runway for their business, or they would not be located there. Whilst a hard runway may allow them to expand their operations, there has been little evidence to demonstrate why it would force them to close. Having regard to the type of businesses operating at the site: a number are non-aviation related and a number are related to rotary-aircraft, which would not be benefitted by a hard runway, it is considered that case of the potential for loss of existing jobs as a result of refusal is not made out and is considered to be unfounded.

There applicants also claim the hard runway would stimulate economic growth in the local area and improve its attractiveness to businesses; assist local businesses to grow and develop to the benefit of the local economy; and make more efficient use as part of the national transport infrastructure. However, only anecdotal evidence is provided in supported of its ability to boost attractiveness of the area to local business. The aerodrome is located close to Biggin Hill Airport which does have a hard runway and consent for 120,000 aircraft movements per annum. Biggin Hill currently has spare capacity, with only 44,264 aircraft movements last year and no more than 70,000 movements in any of the last 5 years. This is far below the 120,000 permissible and demonstrates that, at the current time, any local business or general aviation needs could be met by Biggin Hill rather than requiring a new hard runway at Redhill.

The remaining very special circumstances put forward by the applicant are not considered to outweigh the harm to the green belt. Whilst the biodiversity improvements would offer some ecological benefits, these are not considered to outweigh the increased hard-surfacing and intensification of use of the site. Similarly, the improved drainage and other safety measures would benefit the aerodrome and its users but the majority could be carried out without needing to be part of a scheme for a hard runway. The existing limitations exert a natural cap on the amount of aircraft movements able to take place, which in turn limits intensity of use. This in turns limits the extent to which the current site encroaches on the green belt and impacts on the function of the land as part of the green belt and its purposes, as well as the impact on openness. This also negates the need for the limitations offered in the draft Section 106 heads of terms and conditions. Although there are currently no controls, it is self- regulating in terms of the types of aircraft able to operate and their hours of use. Whilst the runway re-alignment over the Salfords Gap minimises the noise impacts of the development, this would still be greater than currently experienced and so offers no benefit from the existing.

In terms of the harm to the green belt that would be caused by the development, it is important to consider not only the visual impact of the hard-surfacing and associated infrastructure but also the intensity of use of the site and the activity generated. The aerodrome has operated since 1922, prior to planning controls. There are no planning restrictions relating to the number of flights but numbers have dropped steadily from 95,432 flights in 1998 to 41,065 flights in 2010. That higher figure from 1998 included a number of very short take-offs and landings associated with Bristow Helicopters training flights, who have since relocated abroad. The decline in flights is not due solely

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The applicant claims the proposal would facilitate a gradual change in the mix of aircraft using the aerodrome, providing opportunities for existing businesses and potential new businesses as well as increasing the certainty about when flights can occur being less weather-dependent. It is accepted that this would result in an increase in aircraft movements and the applicant considers the proposal would result in up to a total of 85,000 movements in 2030, comprising 65,000 general aviation movements and 20,000 business aviation movements including aircraft such as light jets and turboprops. A Section 106 planning obligation would be necessary to secure this restriction on flights.

Although there were around 95,000 aircraft movements per annum on the site in 1998 and the applicant would accept a restriction of 85,000 movements, this has to be considered against the much lower recent average of movements since 1997. It is also considered likely that a high proportion of the aircraft movements associated with the approximate 95,000 figure involved very short take-off and landing movements associated with helicopter training flights associated with Bristow Helicopters prior to the relocation of the majority of their business to the USA. In addition to this, it is likely that the proposal would result in a change in the aircraft types using the aerodrome, including the anticipated 20,000 business aviation movements. It is also likely that the proposal would result in proportionately more fixed-wing movements compared to helicopter movements.

Whilst the ability to impose planning controls to restrict flight movements could have some benefits, the previous figure of 95,000 is somewhat misleading due to the high number of helicopter training flights and it is likely that a hard runway with a restriction of 85,000 movements would result in an intensity of use far more than currently experienced at the site and also have a greater impact than the historical use. The current grass runways exert a natural limitation on flights, both in number and the type of aircraft. They cannot be used by jet aircraft, in the dark or in adverse weather/ground conditions.

The site, with its current grassed runways with limited small aircraft movements have a character consistent with a small, low-intensity rural aerodrome, used primarily for training and leisure flights. The change to a hard-surfaced runway would be less compatible with a rural area, changing the character and intensity of the use. Whilst some of the very special circumstances put forward by the applicant are compelling, especially with regard to the economic benefits of the proposal, they are still, on balance, not considered sufficient to outweigh the harm caused to the openness of the green belt.

The application is supported by a noise assessment that shows that there would be an increase in noise levels in the local area. The runway would be realigned to move the

M:\BDS\DM\Ctreports 2013-14\Meeting 1 - 05 June 13\Agreed Reports\12.01377.F - Redhill Aerodrome, Kings Mill Lane, Redhill.docx Planning Committee Agenda Item 9 5 June 2013 12/01377/F flight path away from the most built-up residential areas, the size of the noise contours associated with the flight path is enlarged as a result of the proposal such that it would have a net negative impact, rather than a positive one. The increase in noise is less than that previously identified and assessed against former PPG24 “Planning and Noise” as being significantly harmful, meaning planning permission should not be refused on this ground but the increase in noise would be part and parcel of the general intensification of activity, contrary to green belt policy. Whilst the noise contours show the levels of noise resulting from aviation at the site, they do not show the increased frequency of noise and activity that would result from the potential for greater numbers of flights operating from the site, and which would contribute to the sites impact on the green belt and character of the area.

The Highway Authority had objected to the previous application due to the intensification of the use in an unsustainable location, only being accessible by rural roads with restricted visibility in places and a history of accidents. However, having now been provided with further information about trip rates and traffic distribution, as well as further capacity modelling, the Highway Authority is satisfied with the development in principle. This is dependant on a significant package of highway safety improvements and provision of sustainable travel options which would need to be secured through Section 106 Agreement in any approval.

In summary, the application improves on the previous scheme in terms of reducing the amount of hard-surfacing and associated infrastructure. There is also greater policy support for economic development in the NPPF and Draft Aviation Policy Framework. The applicants have also sought to provide further economic justification for the development than previously, explaining that the Aerodrome may cease to function with associated loss of existing jobs without the proposed hard runway. However, the Councils’ independent economic consultant casts doubt over such fears and a number of businesses at the site do not rely on fixed-wing aviation. Whilst the economic benefits of the proposal, with additional jobs and GVA that it would bring are acknowledged as favouring the application, they are not, on balance, considered of very special circumstance to outweigh the harm to the green belt by way of the intensification of use and increase in built development.

RECOMMENDATION

Planning permission is REFUSED.

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Consultations:

Highway Authority: Following additional modelling of highway capacity plus additional information regarding traffic distribution and traffic generation, the Highway Authority no longer objects to the proposal subject to a package of measures towards:  Highway Capacity Improvements;  Safety enhancement measures along Kings Mill Lane;  Improved accessibility and visibility at site entrance;  Pedestrian and cycle improvements; and  Provision of a mini-bus service and travel plan.

National Air Traffic Services: no objection.

London Biggin Hill Airport (LBHA): raise concerns regarding: impact on business/investment at LBHA; impact on local airspace; prematurity of proposal in absence of a national policy on aviation including role of Gatwick Airport.

Surrey County Archaeological Officer: no objection subject to a scheme of archaeological investigation being secured by condition.

Campaign to Protect Rural England (CPRE): objects on grounds of: (i) noise; (ii) highway implications; (iii) emissions; (iv) light pollution; (v) the site being outside a growth hub; (vi) that the harm outweighs the need; (vii) inappropriate development within the green belt without very special circumstances to outweigh the harm; and (viii) the potential for further expansion.

Salfords and Parish Council: objects on the following grounds: (i) green belt; (ii) intensification of use; (iii) increased noise; (iv) future infrastructure being required; (v) the level of local objection; (vi) traffic; (vii) difficulty of enforcing the proposed restrictions; (viii) lack of demand; (ix) drainage issues; (x) light pollution; and (xi) viability claims are disputed and a business case has been proved. Further responses made querying the applicants’ technical reports submitted and highlighting shortfalls in economic/employment justification. An independent Noise Review was also undertaken by S&SPC which raises concerns with the noise assessment prepared by the applicant’s consultant with special regard to: what threshold level should be considered acceptable; impact of early-morning and late-evening flights and that residual effects can be anticipated.

Nutfield Parish Council: raise concerns about the economic and employment benefits claimed by the applicants in light of the Councils’ independent economic consultant report.

UK Power Networks: no objection.

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Surrey County Council Strategic Response: raises concerns over flooding impacts and airspace capacity.

Gatwick Airport Safeguarding: no objection subject to sustainable urban drainage provision.

RBBC Drainage Engineer: no objections subject to surface water drainage condition.

RBBC Environmental Health: no objection from land contamination or air quality perspectives but concerns raised regarding the noise and disturbance impacts of proposal.

Surrey Wildlife Trust: no objection subject to implementation of the monitoring and wildlife protection measures contained within the Environmental Statement.

Surrey County Council Rights of Way: request informative regarding impact on footpaths.

Horne Parish Council: objects on grounds of: increased noise and longer operating hours; impact on green belt; traffic; sustainability; pollution and airspace congestion.

The Reigate Society: objects on the grounds of: (i) intensification and increase in flights; (ii) the potential for a disproportionate increase in fixed-wing movements; (iii) the potential safety implications due to proximity to Gatwick; (iv) potential conflict with the Government Aviation Policy; (v) inappropriate development within the Green Belt; and (vi) the substandard local road network.

Buckland Parish Council: objects on the basis that the proposal represents inappropriate development in the green belt without very special circumstances to outweigh the harm and that the noise generated would cause nuisance to reidents. Recommends various S106 obligations if the Council is minded to approve the application.

Norwood Hill Residents’ Association: objects on the grounds of (i) inappropriate development in the green belt; (ii) increased noise and disturbance; (iii) difficulty in regulating the flight path; and (iv) increased road traffic.

Mole Valley District Council: objected to the proposal on the grounds that it would lead to an increase in the number of flights by fixed-wing aircraft over the Buckland area of the district during all months of the year and over a longer daily operating period to the extent that it would cause disturbance and diminish the residential amenity of the area.

Surrey Police: no objection.

Keep Redhill Aerodrome Green (KRAG): objects on the grounds that (i) the large area of hard standing would be out of keeping with the character of the area; (ii) the S106 Agreement is likely to be ineffective; (iii) high aircraft movements haven’t occurred for

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Nutfield Conservation Society: object on the basis of not meeting very special circumstances required in the green belt; operating hours increasing noise; impact of increased aircraft movements; issues regarding additional hard-surfacing; impact on biodiversity; traffic; prematurity regarding aviation policy and that spare capacity exists locally.

Forestry Commission: standing advice.

Business Responses:

Several businesses and organisations have expressed support for the proposal on economic development grounds including:

Gatwick Diamond: supportive on the basis that it would assist with economic development of the area, safeguarding 450 jobs; increasing direct and indirect employment; increasing GVA; supports wider economic growth and job creation; improved connectivity for business and improve attractiveness of local area for business.

Surrey Chambers of Commerce: supportive on the basis that it would assist with economic development of the area, safeguarding 450 jobs; increasing direct and indirect employment; increasing GVA; supports wider economic growth and job creation; improved connectivity for business and improve attractiveness of local area for business.

Representations:

Letters were sent to neighbouring properties on 09 August 2012 and 3 January 2013, site notices were posted on 20 August 2012, and an advertisement was placed in the local press on 23 August 2012. 146 responses have been received objecting to the proposal and raising the following issues:

Issue Number Response

Noise & disturbance 125 See paragraphs 6.20-6.25 Increase in traffic and congestion 104 See paragraphs 6.28-6.36 Harm to Green Belt/countryside 93 See paragraph 6.2-6.19

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No need for the development 64 See paragraphs 6.10-6.19 Health fears 61 See paragraph 6.26 Hazard to highway safety 33 See paragraphs 6.28-6.34 Overdevelopment 30 See paragraphs 6.2-6.9 Flooding 22 See paragraph 6.35 Drainage/sewage capacity 19 See paragraph 6.35 Property devaluation 16 Not a material planning consideration Inconvenience during construction 15 Could be mitigated by condition Harm to wildlife habitat 11 See paragraph 6.36 Out of character with surrounding area 7 See paragraphs 6.2-6.9 Inadequate parking 3 No Highway Authority objection to parking Alternative locations should be 3 See paragraphs 6.10-6.19 considered Crime fears 3 No objections from Surrey Police

1.0 Site and Character Appraisal

1.1 The Aerodrome lies between Kings Mill Lane, Masons Bridge Road, Crab Hill Lane and the Salfords Stream, with its entrance off Kings Mill Lane. Approximately two-thirds is within Tandridge District, with one third within , and all is within the Metropolitan Green Belt, with a small area of ancient woodland designated as a potential Site of Nature Conservation Importance. It has three grass runways, two running east-west and one running north-south. The aerodrome was established in 1922 and served as a military airfield in WWII. The site contains a number of hangars and, near the entrance of Kings Mill Lane, occupies a number of aviation-related businesses, the largest of which is Bristow Helicopters. The total commercial floor space on the aerodrome is around 26,000 square metres.

1.2 Trees and other vegetation bound the site which is at a lower level to Kings Mill Lane. The site is around 190 hectares in area with the existing runways being around 850-900 metres in length and 25-30 metres in width. The surrounding area is characterised by green belt uses with the closest residential settlements within this Borough being Salfords, South Earlswood and Whitebushes.

1.3 The aerodrome currently has no planning restrictions ofn its opening hours but its published hours reflect daylight hours (0700-1900 summer and 0900-1700

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winter). Of the total aircraft movements in 2010 (approx. 41,000), 42% were circuits (used to practice take-off and landing), with Aero Club/Training accounting for 27%, private flying 19%; business flights 6% (including filming trips and sightseeing trips); and 1% police/air ambulance. The companies that own and operate Redhill Aerodrome are owned by Redhill Aerodrome Ventures Ltd (RAVL). Redhill Aerodrome Ltd (RAL) is responsible for the day-to-day management and Redhill Aerodrome Trading Ltd (RATL) is responsible for the letting, management and maintenance of the commercial property on the site.

2.0 Added Value

2.1 Formal pre-application discussions were held only to discuss validation requirements required for application.

2.2 During the course of the application discussions were held between the applicant and the Highway Authority and Environment Agency to amend proposal and address concerns.

2.3 The applicant has suggested a legal agreement to restrict the number of aviation movements which would be required as part of any approval..

3.0 Relevant Planning and Enforcement History

3.1 93/07300/OUT New airport with hard runway, Objection taxiways, apron, terminal, 220 6 September 1993 bedroom conference hotel, associated car parking, access road and motorway junction

3.2 08/01009/F All-weather runway Withdrawn 8 October 2008

3.3 11/00421/SCOPE EIA scoping opinion for this EIA Required proposal 3 May 2011 3.4 11/01342/CONLA Consultation from Tandridge DC Objection on this proposal 3.5 11/01254/F Construction of hard runway to Refused replace existing grass runways and 24 November 2011 ancillary infrastructure comprising realignment of existing taxiways, a new taxiway link, drainage improvements, replacement runway lighting and new approach lighting 3.6 12/01504/CONLA Consultation from Tandridge DC Pending on this proposal

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4.0 Proposal and Design Approach

4.1 This is a full application for the construction of a hard runway to replace the three existing grass runways and ancillary infrastructure comprising realignment of existing taxiways, drainage improvements, replacement runway lighting and new approach lighting.

4.2 The proposal would involve replacing all three existing grass runways (defined as Code 2 runways by the Civil Aviation Authority) with one hard-surfaced runway (which would be a Code 2b runway as defined by the CAA). The paved area would be 1,349 metres long and 25 metres wide although the total useable take-off and landing area would be 1,199 metres long. There would be some cut and fill required to achieve a suitable gradient along its length but this would be no more than 2 metres and would be a neutral cut and fill solution (I.e. not require any material to be exported/imported to or from site). The proposed runway would be suitable for very light jets and turbo prop aircraft which currently rarely use the runway due to its grass surface, although Draft S106 Heads of Terms have been provided by the applicant which do set limits on this and other matters as follows:

 Total aircraft traffic movements would be capped at 85,000 (65,000 general aviation/20,000 business aviation);  A cap on the proportion of business jets and other similar-sized aircraft permitted to use the aerodrome during the course of the year;  A limit on hours of operation of 0700-2200 (year round), with an agreed extension beyond this for a limited number of movements;  Commitment to operating within an agreed noise contour;  A noise management plan to include monitoring and a commitment to noise abatement measures;  A Travel Plan to limit the use of the private car;  A habitat management plan;  Promotion of the public use of Greensand Way by improving wildlife corridors alongside it; and  Maintaining RAL’s reporting to the Redhill Aerodrome Consultative Committee.

4.3 There would also be a grassed runway strip extending 75 metres either side of the runway centreline and 60 metres beyond each end of the runway which would again require some cut and fill operations, as well as a runway end safety area of 90 metres long by 60 metres wide, which would be grassed and allow for any aircraft overrun.

4.4 A number of ancillary works are proposed including replacement approach lighting comprising a series of lights at 60 metre intervals out to 420 metres either end of the runway, which would be on columns of a height to be determined (but likely to be no greater than five metres in height). New drainage systems and an

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area of flood plain compensation would also be provided as part of the proposal and the applicant has also stated that they would provide a habitat management area.

4.5 The applicant states the proposal could increase aircraft movements to 85,000 per annum, comprising 65,000 general aviation movements (fixed wing and helicopters) and 20,000 business aviation movements using aircraft such as very light jets and turbo props. They have suggested the number of movements be restricted to 85,000 through condition or legal agreement. Whilst currently the aerodrome operates between 0900 and 1900 hours in summer and 0900 and 1700 hours in winter, it is proposed that operational hours would be extended to between 0700 and 2200 hours all year round.

4.6 Further details of the development are as follows:

Site area 190.3 hectares (ha) 120.9 ha within Tandridge District 69.4 ha within Reigate and Banstead Proposed aircraft movements 85,000 Total 2010 aircraft movements 41,065 Average movements since 1997 60,173 Average movements 2000-2010 52,548

4.7 The key differences between this application and the one previously refused in 2011 are:

 Runway length increased from 1199m to 1349 m (an increase of 150 m but no increase in operating length to increase height above surrounding land to east and west to reduce noise impact);  Reduction in runway width from 30m to 25m and introduction of trurnpads at either end;  A previously proposed taxiway link (approx. 590m) has been omitted;  These changes have resulted in a net reduction in hard surfacing of 11,488 sqm (approx.. 25%) compared to previous application;  Slight realignment of runway to take flights further away from South Nutfield;  A reduction in the amount of cut and fill required; and  The inclusion of approach lighting all within the Aerodrome boundary rather than extending outside the site.

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5.0 Policy Context

5.1 Designation

Metropolitan Green Belt Potential Site of Nature Conservation Interest

5.2 Reigate & Banstead Borough Local Plan 2005

Landscape & Nature Conservation Pc2C, Pc4 Countryside Co1 Employment Em1, Em2, Em3, Em12 Utilities Ut4 Movement Mo7

5.3 Other Material Considerations

National Planning Policy Framework Supplementary Planning Guidance A Parking Strategy for Surrey Parking Standards for Development

Other Human Rights Act 1998 Community Infrastructure Levy Regulations 2010 Draft Aviation Policy Framework 2012 The Future of Air Transport White Paper 2003

6.0 Assessment

6.1 The main issues to consider are as follows:

 Metropolitan Green Belt  Very special circumstances  Noise  Safety  Transportation issues  Flooding  Biodiversity  Archaeology

Metropolitan Green Belt

6.2 The site is wholly located within the Metropolitan Green Belt where there is a general presumption against development unless it is for one of the uses listed as appropriate within paragraph 83 of the NPPF. Aerodrome development,

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including hard runways are not listed as an appropriate form of development. Engineering operations are listed as appropriate in certain circumstances where they do not harm the openness of the green belt or the purposes of including land within. As this proposal is considered to be contrary to the purposes of including land within the green belt and harmful to the openness of the Green Belt it represents inappropriate development which is by definition harmful and unacceptable unless very special circumstances exist that outweigh the harm caused.

6.3 Policy Co1 of the Borough Local Plan draws down to the local level the above Green Belt policy. Also within the Borough Local Plan, to protect the green belt and prevent noise and disturbance to neighbouring residents, is policy Em12 which is specific to Redhill Aerodrome and states:

The Borough Council will normally resist any development at Redhill Aerodrome, as shown on the Proposals Map, which is likely to result in the intensification of its use for flying and related activities. Other proposals will be assessed against the Green Belt and appropriate design and layout policies of this Local Plan.

The policy then goes on to state in Amplification (1):

The Future of Air Transport White Paper 2003 did not allocate Redhill Aerodrome for any business aviation role and the Borough Council does not consider it necessary to have a hard runway for its general aviation role.

6.4 Policy Co1 is considered to be fully compliant with the NPPF and can therefore be given full weight. Policy Em12, whilst not conflicting with the Green Belt principles of the NPPF, is negatively worded and serves to duplicate the requirements of policy Co1 and should therefore attract less weight, but is still of some relevance. Policy Em12 refers to the Future of Air Transport White Paper 2003 and whilst this is still current, it must be considered in the context of the emerging Draft Aviation policy Framework 2012 which encourages aviation development but does not specifically mention Redhill.

6.5 The proposed development would result in over 35,000 square metres of hard- surfacing which would urbanise the character of the site. Combined with this would be the associated infrastructure, including the approach lighting whose visual impact would extend beyond the objects themselves, given that there would be a degree of light spillage, even with the cowelling specified. The visual harm would also extend to the change in topography needed to provide the new runway on near-flat ground. Given the nature of the surrounding area which is generally undeveloped, rolling countryside, these impacts would be significant.

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6.6 In understanding the likely impact on the green belt it is important to understand not just the physical infrastructure that would affect its openness and the general landscape, but also the nature and intensity of the activities to be expected and how this would change the openness and character of it. The applicant claims that, due to a historic level of 95,432 aircraft movements that occurred in 1998, the proposal would not result in an intensification of the current use, as they would accept a restriction by way of a legal agreement, limiting movements to 85,000 per annum. However, the potential number of movements resulting from this proposal should not be considered solely against what occurred 13 years ago, but also the more recent situation. Since 1997 the average number of annual movements has been 60,173, whilst since 2000, the average has reduced further to 52,548. Compared to the current situation and in recent history, the proposal, with the potential to result in 85,000 movements, undoubtedly therefore constitutes an intensification of the aerodrome use.

6.7 The relatively high figures quoted from 1997 and 1998 are also likely to have included a proportionately high number of helicopter training movements than would result from the proposal. In 1997 and 1998 helicopter movements accounted for around 48% of total aircraft movements whereas in 2010, and on average since 2000, helicopter movements amounted for only 43% of total aircraft movements. Many of the helicopter training movements would have involved very limited flight to constitute a movement; this is because each take-off or touch-down is counted as a movement. A helicopter training flight lifting off the ground, hovering for a few seconds, or minutes, would therefore constitute two movements but its impact would be far less than a fixed-wing aeroplane taking off along the length of a runway. The high number of movements before 1998 could therefore be misleading as to what the actual activity at the aerodrome was. It is therefore considered that the recent situation, that has occurred since 2000 is more reflective of the intensity of activity that characterises the aerodrome. In any case, events that have occurred historically should only be given limited weight as it is the current use against which future proposals should be considered. In this regard the figure of 85,000 aircraft movements quoted by the applicant as likely to result from the proposal and at which level they are prepared to accept planning restrictions, would undoubtedly constitute a material intensification of the use which would be harmful to the character and openness of the green belt.

6.8 The nature of the aircraft that would be able to use the aerodrome as a result of the proposed hard runway would also change as a result of the proposal as it would allow its use by very light jets and turbo props. These aircraft are larger than the pleasure flight craft or training vehicles which generally characterise the aerodrome presently. The change to larger craft would also result in an intensification of use of the site and detract from the character and openness of the green belt.

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6.9 Presently the aerodrome is characterised predominantly by grass and the more leisurely take-off and landing of small fixed-wing aeroplanes or helicopters gives it a rural character consistent with a small rural aerodrome used mainly for training and recreational purposes. A hard runway and the associated infrastructure would change not only the physical appearance of the landscape but, together with the change in the number of flights and type of aircraft would dramatically change the character of the site and cause significant harm to the current green belt function and its openness, contrary to policies Co1 and Em12 of the Borough Local Plan and the advice contained within the NPPF. Due to this harm that would be caused, any very special circumstances would need to be significant to outweigh the negative impacts.

Very Special Circumstances

6.10 The applicant has put forward a number of very special circumstances which they consider outweigh the harm caused including: increasing employment; generating an increase of £8.2m GVA; safeguarding existing jobs; assisting in stimulating economic growth in the local area and improving its attractiveness to business; directly assisting local businesses to grow and develop; making more efficient use of the aerodrome to fulfil capacity within the South East; environmental enhancements; and providing strict limits and operational controls through S106 and planning conditions.

6.11 The application is supported by an economic assessment prepared by York Aviation which includes the original assessment prepared for the previous application plus an addendum to it to support this revised proposal. A key risk highlighted in the addendum is that the Aerodrome may close with associated loss of business and jobs without the proposed hard runway. The economic contribution of the aerodrome has been given very serious consideration in order that the potential benefits of the proposed development can be fully understood and appreciated. In order to provide expert, independent advice on this matter, Reigate and Banstead BC appointed, jointly with Tandridge DC, an economic consultant from Portsmouth University to review the findings which the applicants and their own consultants have provided comment on.

6.12 The aerodrome is an important local employer and currently provides 340 full- time equivalent jobs on site and a further 110 indirect jobs in the local area, generating a total Gross Value Added (GVA) of £19.3 million. The applicant considers the proposal would have the potential to create a further 140 jobs and an additional GVA of £8.2 million by 2030. This means that the value to the local economy as a result of the proposed developments could be as much as £27.5 million and 590 jobs. These figures were given in the previous application and were not contested. The Councils’ consultant also found general agreement with the total jobs and GVA that would result from the proposed hard runway. However, the Councils’ consultant did consider that the overall employment and GVA resulting from the aerodrome was exaggerated by York Aviation due to the

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counting of deadweight and displacement (I.e. those jobs that would exist regardless of the aerodrome operation at Redhill). Nonetheless it is not disputed that the proposal could boost employment and revenue. Ultimately however this position has not changed since the previous application where these potential benefits were not, on balance, considered to outweigh the harm to the Green Belt. The employment strategy for the Borough does not include any expansion of the aerodrome; but rather its intensification is specifically resisted by policy Em12 as well as the general presumption against inappropriate development set out in Policy Co1. The Council’s Corporate Plan states a key priority for economic growth and the proposal could assist in this regard. Nevertheless, such growth should be properly planned and located in appropriate areas. Unemployment in the Borough is higher than recent years but remains low on a national basis and it is unlikely that the proposed jobs would be realised until many years into the future when the economic climate is unknown. The creation of new jobs cannot be justification for new development within the Green Belt, alone, or many forms of development could take place that would otherwise be deemed unacceptable and the character of the Green Belt would be materially and permanently harmed. Rather, a balance must be exercised and, on balance, the benefits of the new jobs and GVA that could be created are not considered sufficient to outweigh the harm caused.

6.13 An important assertion made in this application by the applicant’s economic consultant, that was not made previously, was that the Aerodrome would be forced to close and existing businesses and jobs would be lost without a hard runway. This was an important issue that the Councils’ consultant from Portsmouth University was asked to consider. The majority of businesses on the Aerodrome site are not reliant on fixed-wing aviation. The proposed hard runway would therefore have limited positive impact on them as it would simply be irrelevant to their business operations.

6.14 The applicants economic consultants, York Aviation, cite three reasons as to why the aerodrome may close without a hard runway, these being: (1) traffic trends; (2) the structure of the aerodrome business and (3) limitations with alternative business strategies. In terms of traffic trends, York Aviation argue that the reduction in flight movements over time is primarily due to the inability of the grass runway to cope with weather conditions and that due to this unpredictability of operations further investment is deterred which could affect the future viability of the aerodrome. Whilst this is a ‘valid point’, it does not explain the decline in aircraft movements at other airports locally, which do benefit from a hard runway, such as Biggin Hill. Also, the existing businesses on site will have been aware of the limitations on the airfield which existed prior to them locating there. If they had relied on a hard runway to operate then they would not have located to the site and most have remained at a time when the economic conditions could allow them to negotiate ‘better rates’ elsewhere. The Councils’ consultant also considers that the there is an inconsistency in the level of optimism (‘optimism bias’) which makes the assumption that general aviation

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flight numbers will increase significantly when the economy comes out of recession, but that a far more pessimistic view of the market is applied to the aerodrome’s future without a hard runway.

6.15 The aerodrome business is geared towards aviation-related activity, hence the conclusion that – when combined with falling traffic levels and an absence of alternative business strategies – the business may not survive. However, the Councils’ Consultant concludes that the structure of the aerodrome business has ‘little bearing’ on its sustainability and is not in itself a reason for closure. Furthermore, it considers that although a ‘reasonable argument’ is presented in relation to alternative strategies for the site, including moving into greater Class B8 use, the ‘difficulties’ cited ‘are only really as strong as the assumption about the potential success of attracting business aviation’. The very special circumstance put forward in this application, that the existing business at the site would close and jobs would be lost without the hard runway is therefore not considered credible and little weight should be given to this as a justification to allow this inappropriate form of development in the green belt.

6.16 The applicants also refer to current aviation policy to form a very special circumstance in support of the proposal. The 2003 White Paper ‘Future of Air Transport’ is the most recent statement of government policy relevant to airports, and the applicants refers to its consistent emphasis on the importance of making best use of existing aviation infrastructure. They also refer to the mention of the role of small airports and aerodromes in providing capacity and supporting economic development and paragraph 33 of the NPPF which deals with the role of airfields in the planning system and states that ‘plans should take account of their growth and role in serving business, leisure, training and emergency service needs’. Reference is also made to the Strategic Review of General Aviation (GA) in the UK produced by the CAA in July 2006 which considered the wider benefits of general aviation and the significant role that airfields can play in local economic development. This concluded that smaller airfields were likely to have a more localised economic footprint, whilst medium sized airfields can act as a magnet for other businesses and become strong contributors to the local economy. It is suggested that Redhill Aerodrome ‘could be regarded as being between these two types of airfield’ and as such would have the potential to act as a ‘more powerful economic catalyst in the local area if the business aviation market could be developed’. The emerging Government policy on aviation is also referred to, the Draft Aviation Policy Framework which was published in July 2012 and therefore since the previous refusal for a hard runway. This states the Government’s primary objective of achieving long-term economic growth, and in paragraph 1.1 that ‘the aviation sector is a major contributor to the economy and we support its growth within a framework which maintains a balance between the benefits of aviation and its costs, particularly climate change and noise’. Furthermore, it highlights the important role of general aviation in connecting UK and international cities.

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6.17 The applicant claims that the proposal would result in environmental improvements through (i) biodiversity enhancements resulting from the creation of a habitat management area; (ii) improved surface water control; (iii) the realignment of the runway approach over the Salfords Gap; and (iv) improved operational safety performance as the existing grassed runways are often closed in wet conditions. It is not considered that the biodiversity enhancements following the creation of a habitat management plan would be so significant as to outweigh the harm caused by the new runway and could, in any case, be provided without being dependent on this proposal. Similarly, the improved surface water control and improved safety performance at the aerodrome would improve its operation but would not extend benefits outside the site. The existing runway is dangerous in wet conditions but at such times it is closed and therefore the safety benefits are less convincing than the economic benefits that would result for the applicant as a result of being able to operate during wet weather. The runway realignment over the Salfords Gap is also not considered to be a very special circumstance as overall the proposal would result in higher noise exposure to a greater number of properties.

6.18 Apart from the above mentioned reports, only anecdotal evidence has been provided to demonstrate how a hard runway may boost the attractiveness of the local area to business. Whilst some businesses would certainly prefer locations that are well served by either commercial or business aviation airports, the site is located close to both Gatwick Airport (5 miles) and Biggin Hill Airport (14 miles). York Aviation do not detail how Redhill would be able to compete with Biggin Hill, given the limited infrastructure available, except to suggest that Redhill would provide a cheaper offer and would be able to operate earlier than the 0730 flight restriction imposed at Biggin Hill. Whilst it is likely that local competition for Business Aviation would be attractive for some companies, as it may drive down the costs associated with this, it is unlikely to be a serious consideration for many companies wishing to locate to the area. Redhill’s proximity to Biggin Hill would therefore dilute any potential attraction to business given they would already be relatively well-served. In this regard, the applicant’s suggestion that the proposal would help make more efficient use of airport capacity in the South East is considered somewhat flawed, given the spare capacity at Biggin Hill locally. If Biggin Hill Airport were to reach capacity then it is likely that the economic and strategic benefits of providing a hard runway at Redhill would increase, but there is no suggestion that this scenario will be reached in the near future.

6.19 The other factor to consider when balancing the benefits of the proposal against the harm is the potential for bringing the use under planning control. The aerodrome has operated since before planning controls were introduced in 1948. It is therefore able to operate unrestrained, and the proposal would introduce a restriction of 85,000 aircraft movements per annum. As discussed previously, the 85,000 figure is greater than the recent number of movements and the previous high of 95,000 was 13 years ago and unlikely to be repeated. However, the future

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potential of the aerodrome must be considered. In this regard, the natural limitations of the aerodrome exert a control on the number of flights and the intensity of operations that could occur. The current grass runways exert a natural limitation on flights, both in number and the type of aircraft. They cannot be used by private jets, in the dark or in adverse weather or ground conditions. I consider it is therefore unlikely, unless this development went ahead, that the number of flight movements would expand to anything near the 85,000 proposed. If there were any significant increase in use of the grass runways then the type of aircraft would still be limited to smaller craft with less impact and therefore there is no need for planning controls on flight movements for so long as the aerodrome has grass rather than hard runways. For this reason, significant weight is not given to this factor as a very special circumstance.

Noise

6.20 The application is accompanied by a noise assessment which estimates the current noise conditions against those predicted as a result of the proposed development that would occur by 2030. Although the proposal would result in the realignment of the runway, to direct flights over the Salfords Gap, there would still be an overall negative noise impact, with more properties exposed to greater levels of noise than currently. It is also likely that the hours of exposure would be increased, given the potential for the hard runway to be used throughout the year and in nigh-time hours.

6.21 Noise contours have been provided within the noise assessment for the impacts of helicopters and fixed-wing aircraft respectively. The noise contours for the helicopter movements are more circular and locally concentrated around the aerodrome. These contours show a small overall enlargement in the noise contours as a result meaning there would likely be only a minor, overall negative impact.

6.22 The noise contours provided for the fixed-wing aircraft show a significantly enlarged area being affected by the proposal by 2030 compared to the current situation. Presently the noise contours above 57 dB (A) Leq (which I will refer to as “decibels” for ease of reference) resulting from fixed wing aircraft are located within a relatively small area not extending far beyond the aerodrome site itself. The proposal would result in noise contours at the same 57 decibel level extending beyond the site, towards the A23 to the west and over the M23 to the east. With regard to this 57 decibel level, Former PPG24 advised that this relates to the onset of annoyance as established by noise measurements and social surveys and only a handful of properties would to be affected at this level by the proposals. Whilst this does represent an increase in the numbers of people affected, it must be considered whether overall this would result in such significant harm as to warrant refusal on this ground. For similar proposals at other aerodrome sites it has generally been concluded that a relatively small increase in noise can be acceptable when balanced against other issues.

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6.23 PPG24 has now been cancelled, and the NPPF does not include any noise limits or thresholds meaning any assessments must be made by way of individual judgement. PPG24 did consider the 57 decibel noise level to represent the onset of annoyance, but the World Health Organisation cites 55 decibels as the level at which serious disturbance is caused and it states that noise disturbance can occur at levels as low as 51 decibels. A far greater number of properties would be exposed to increased noise exposure at these lower levels than the few properties affected by the 57 decibel level cited previously by PPG24. The Draft Aviation Policy Framework does not set noise limits but does acknowledge that people were now more sensitive to aircraft noise and that the 57 decibel threshold was too high and that many complaints about aircraft noise come from outside the 57 dB contour, The proposal would therefore result in some increased annoyance to a number of properties and the Council’s environmental health officer has therefore understandably objected to the proposal for this reason, especially as those affected would be existing occupiers and there would be limited options for controlling impacts by condition or other means of planning control.

6.24 Whilst the proposal would undoubtedly result in additional noise and disturbance for local people, this has to be considered against the advice contained within the limited current planning policy guidance on the matter. On this basis and, given the relatively small increase in people exposed to the 57 decibel level, it is concluded that the proposal would not result in significant harm to neighbour amenities such that it should be refused on this ground alone. However, given the general increase in noise, and frequency of noise, in this rural area, and the presumption against intensification of activities at the aerodrome, this factor does contribute to the general unacceptability of the proposal within the Green Belt.

6.25 Other than the noise and disturbance issue, it is not considered that the proposal would result in any other adverse neighbour impacts.

Safety

6.26 The benefits to pilots and crew as a result of safer landings were discussed above and, as stated, the grassed runways are closed in wet or dangerous conditions, meaning this is not considered to be a significant issue. Some concerns were raised by local residents regarding the potential for the proposed hard runway to result in greater aircraft movements and larger aircraft, so posing a safety risk as a result. The concerns related both to the potential for increased incidence of aircraft crashing due simply to the higher numbers of flights and also because of the close proximity to Gatwick Airport and the potential for conflicts between aircraft landing or taking off from there, with those from this aerodrome. Both National Air Traffic Services (NATS) and Gatwick Airport Safeguarding were consulted on the application and neither raised any objections. Whilst it is not specifically stated, it is assumed that the advice of NATS and Gatwick Airport

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takes into consideration any potential conflicts that may arise due to expansion and/or intensification of Gatwick Airport. It must therefore be concluded that there would not be any significant safety implications as a result of the proposed development.

Transportation

6.27 The site is accessed off Kings Mill Lane, a narrow, country road away from the main road network, with a history of accidents. The Highway Authority had objected to the previous scheme on the basis that it was unsustainably located and would pose a potential highway safety risk.

6.28 As set out in paragraph 12.31 of the Applicant’s Environmental Statement, it is estimated that a return to 85,000 aircraft movements by 2030 would generate 253 vehicle movements a day, an increase of 142 on 2010 levels. In addition to this, it has been estimated that the development could result in the creation of 120 additional jobs at the aerodrome, and it is estimated that this would increase AM weekday peak hour vehicle movements by 108 movements and PM peak hour movements by 162. The impact of the employment growth, therefore, is likely to be more significant in terms of vehicle movements than the increase in aircraft movements though it is noted that in both cases the growth figures are ‘aspirational’ over the period to 2030 and represent the ‘worst case scenario’. The ES concludes that even if these figures were achieved – and factoring in future ‘baseline’ conditions that could occur to the highway network without the development and as a consequence of natural growth - the impact on the highway network would be ‘negligible’.

6.29 The highway authority objected to the previous application on the basis that the site is unsustainably located, in a rural area, away from main settlements, town centres and the public transport network. As such it was considered that that development would encourage the use of the private car, contrary to the aims of then PPG13 ‘Transport’. Concern was also raised on the basis of the rural nature of the highway network, with its variable widths, limited visibility in places and a history of accidents, and the highway authority considered at the time that whilst there was insufficient justification for refusing the scheme specifically on these grounds the increased intensity of the use of these roads could result in highway safety concerns.

6.30 As part of this current application, the applicant has provided information which has enabled the highway authority to assess more fully the impact of the proposed development on the highway network. This information was provided as part of the Transport Assessment Addendum (December 2012), and set out the anticipated numbers of passengers per flight, number of passengers per vehicle and how these would be spread over the week. It also extended the assessment of the impact of the development to 2030, when ‘full operation’ of the development is anticipated.

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6.31 The addendum report sets out the likely distribution of this traffic across the highway network, and its consequent impact on three junctions; the access with Kings Mill Lane; the A25 junction with Mid Street, Nutfield; and the Three Arch Road junction with the A23 south of Redhill. A review of the accident record for Kings Mill Lane was also carried out, as the highway authority was concerned that the additional traffic generated by the proposed development would increase the potential for accidents to take place on Kings Mill Lane which already has a history of accidents. This concluded that during the 5 year period being studied, a ‘significant number’ of accidents had occurred at four bends on the stretch of Kings Mill Lane between Masons Bridge Road and the aerodrome access, and that the three main contributory factors were ‘loss of control’, ‘slippery road’ and ‘travelling too fast for the conditions’.

6.32 On the basis of the above, the highway authority has advised that without appropriate mitigation the development would be unacceptable in highway capacity and safety terms. In the event that planning permission was granted, a package of mitigation measures would be sought for the following through a S106 Agreement:

 A contribution towards the cost of highway capacity improvements at the Mid Street/A25 junction and Three Arch Road/A23 junction.  Provision of signage (to draw attention to draw attention to hazards/reduce speed); high friction/anti-skid surfacing at the bends and enhanced use of cats eyes/road studs along Kings Mill Lane  Provision of anti skid surfacing and improved signage at the Picketts Lane/Axes Lane/Honeycrock Lane/Masons Bridge Road junction, the Kings Mill Lane/Clay Lane/Bower Hill Lane/Kings Cross Lane junction and the Bower Hill Lane/Sandy Lane junction.  Improvements to visibility the aerodrome access.

6.33 In addition to these measures, the highway authority would seek the following measures to help mitigate the impact of the development by reducing the number of trips made to and from the site by the private car, and to assist employees and visitors who are able to commute by train:

 Improvements to the rights of way network in the area, particularly in relation to cyclists.  Provision of a minibus shuttle service between the aerodrome, Redhill town centre and Salfords and Nutfield stations and executive shuttle bus service for business aircraft operators (all to be promoted through site wide travel plan to be implemented by the applicants, and include the employment of a travel plan co- ordinator).

6.34 As concluded previously, the site is not well located, as it is in a rural area away from main settlements and towns, and public transport links. The roads

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surrounding the site are rural in nature, and are not suitable for pedestrians as there are no highways or lighting. The main means of accessing the site is currently by the private car. However, the highway authority is satisfied that subject to the introduction of a range of highway safety measures to the local road network to control speed and improve driver safety, the provision of junction improvements (to be part funded by the applicant) and measures to increase access to the site by means other than the private car, its objections in relation to safety, capacity and sustainability will have been overcome. However, as there is currently no mechanism for these measures to be achieved i.e. through a legal agreement, a reason for refusal is recommended on these grounds.

Flooding

6.35 The site is within the Environment Agency’s flood zones 2 and 3, and the airfield is low lying, and subject to flooding. This is addressed in Chapter 13 of the Applicant’s Environmental Statement. As part of the proposal, measures for dealing with surface water drainage and for compensating for the loss of flood plain resulting from the introduction of non permeable surfaces are proposed. In terms of surface water drainage, a runway-edge drainage system would be introduced which would capture surface water flowing transversely across the runway from the north. The drains have been designed for a 1 in 5 year event, but have the capacity to store run-off from a 1 in 100 year flood event plus 20% for climate change, as required by the Environment Agency. Stored surface water would be directed via a new outfall to the Salfords Stream. In terms of flood risk, flood storage areas would be formed within the aerodrome site, these being designed to accommodate the volume of flood water that would be displaced as a result of the loss of the functional flood plain. The proposals also involve works to a section of the Redhill Brook which runs to the eastern side of the site. These works would involve the de-culvertisation and diversion of the existing channel, which would result also in environmental benefits in terms of biodiversity due to the ‘naturalisation’ of the channel. Subject to the imposition of conditions, the Environment Agency raises no objection to the proposal. It is therefore considered that as adequate mitigation would be put in place no significant harm is identified in this regard. Similarly, no objection is raised in relation to ground conditions, any impact on which would also be managed by way of conditions.

Biodiversity

6.36 The application is accompanied by various ecological reports which recommend monitoring for protected species and measures for their protection. The site contains no statutorily protected ecological designations and provided such measures are required of any approval, there is no objection in principle to the proposal and its ecological impacts could be mitigated. A proposed habitat management area would help mitigate any negative ecological impacts resulting from the proposed development. Whilst this would be of benefit and would

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ensure no significant harm to wildlife, it was not, in itself, considered to outweigh the green belt harm identified above.

Archaeology

6.37 There is no known archaeological potential of the site but given the scale of the earthworks involved, the proposed development could be a source of impact on any cultural heritage value or significance of the site, and it is therefore recommended that this impact could be mitigated through the implementation of an archaeological watching brief during the construction phase of the proposed development, which would be required by condition if permission were to be granted.

REASONS FOR REFUSAL

1. The proposals would constitute inappropriate development by reason of conflict with the purposes of including land within the Green Belt and the extent of hard- surfacing and related infrastructure detracting from the character and openness of the Metropolitan Green Belt, contrary to policies Co1 and Em12 of the Reigate and Banstead Borough Local Plan 2005 and the National Planning Policy Framework. The arguments presented by the applicants in support of the application are not considered such to constitute very special circumstances overriding the harm caused and justifying the grant of permission.

2. The proposals would constitute inappropriate development by reason of conflict with the purposes of including land within the Green Belt and the increased intensity of use, with greater number of aircraft movements and potential for larger aircraft types, over longer hours, that would result in increased activity, including general levels of noise and disturbance, detracting from the character and openness of the Metropolitan Green Belt contrary to policies Co1 and Em12 of the Reigate and Banstead Borough Local Plan 2005 and the National Planning Policy Framework. The arguments presented by the applicants in support of the application are not considered such to constitute very special circumstances overriding the harm caused and justifying the grant of permission.

3. In the absence of a legal agreement to secure improvements to the transport network and sustainable travel measures, the proposed development would lack sustainable travel options and cause increased highway safety risk contrary to policies Em12, Mo3, Mo4, Mo5 and Mo7 of the Reigate and Banstead Borough Local Plan 2005 and the National Planning Policy Framework.

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