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Vantage Planning Ltd www.vantageplanning.co.uk © Vantage Planning Ltd

Boeing Aircraft Hangar

Gatwick Airport North West Development Zone

Planning Statement

February 2017

http://www.vantageplanning.co.uk/

Gatwick Airport Planning Statement NWZ Hangar Development

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Table of Contents

1 Introduction ................................................................................ 2

2 Background ................................................................................. 4

3 The Proposed Development and its Operation ................................ 9

4 Landscape and Ecological Mitigation & Enhancement Strategy ...... 15

5 Planning Policy and Guidance ...................................................... 17

6 Planning Considerations ............................................................. 36

7 Conclusions ............................................................................... 52

8 Appendices ................................................................................ 54

Appendix 1: Matters for Planning Conditions .................................... 55

Appendix 2: Draft Section 106 Agreement ........................................ 56


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1 Introduction

1.1 This Planning Statement has been prepared in support of a full planning application, submitted on behalf of Gatwick Airport Ltd (GAL) and Boeing Commercial Aviation Services Europe Limited (BCASEL) - a subsidiary of the Boeing Corporation - for a proposed new aircraft hangar development at Gatwick Airport (‘the Airport’).

1.2 The planning application description is as follows:

“The construction of a new hangar and other associated works including aircraft apron, connection to taxiway ‘Uniform’, vehicle parking and external parts storage area, fire suppression plant, diversion of Larkins Road and realigned security fencing, drainage and lighting, together with associated landscaping and ecological mitigation and enhancement works”

1.3 The hangar will form a base for BCASEL’s European GoldCare services - a premium maintenance service that it offers to its worldwide airline customer base to manage the ongoing maintenance of its airline customers’ fleets.

1.4 A full description of the proposed development is provided in Section 3 of the Statement.

Planning Application Documents

1.5 The planning application is supported by the following documents:

Table 1.1: Application Documents

Documents Author

Planning Application Forms Vantage Planning

Application Drawings D5

Planning Statement Vantage Planning

Design and Access and Sustainability Statement D5

Local Economic Impact Assessment Oxford Economics

Ground Noise Assessment Hayes McKenzie

Flood Risk Assessment CH2M

Ecological Surveys and Appraisal Report CBA

Landscape and Visual Appraisal CBA

Landscape and Ecological Mitigation and Enhancement Strategy

CBA

Tree survey and Arboricultural Impact Assessment Martin Dobson Associates

Transport Statement ARUP

Air Quality Statement CH2M


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Documents Author

Archaeological Impact Assessment Oxford Archaeology

Drainage Strategy WSP Parson Brinkerhoff

Ground Conditions Geo Environmental Interpretative Report

Arcadis

Draft S.106 Agreement for off-site ecological works and additional off-site planting

GAL (Provided as Appendix 2 of this Planning Statement)

Structure of this Statement

1.6 This report is structured as follows:

Section 2 provides background information including the need and economic benefits of the development.

Section 3 describes the proposed development and how it would operate.

Section 4 provides details of the proposed Landscape and Ecological Mitigation and Enhancement Strategy.

Section 5 reviews the principal national and local planning policy context and other planning considerations.

Section 6 consider the detailed planning consideration and identifies and reviews how the proposed development is in accordance with the policies of the development plan, national policy and other considerations and is a sustainable development.

Section 7 draws conclusions.


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2 Background

2.1 Boeing is one of the world's leading aerospace companies and the largest manufacturer of commercial and military aircraft.

2.2 Headquartered in Chicago, Boeing employs more than 170,000 people in the United States and in 70 other countries, including 2,000 at a number of sites across the UK. Indeed with approximately half of Boeing’s European employees based in the UK, the UK is Boeing’s largest source of employment in Europe, and third globally after the US and Japan.

2.3 Over 80% of the company’s workforce are educated to the equivalent of degree level, and its activities also draw on the talents of hundreds of thousands more skilled people from its worldwide supplier base, which in the UK supports a further 13,000 jobs.

2.4 Boeing’s GoldCare is a premium maintenance service that it offers to its worldwide airline customer base to manage the ongoing maintenance of its airline customers’ fleets. It provides services and support to its global customer base of airlines and a flexible set of fleet engineering, materials and integrated maintenance services that are tailored to the individual needs and requirements of airlines. This covers supply of aircraft parts, engineering and information services, aircraft modifications, logistics, as well aircraft maintenance, repair and overhaul facilities.

2.5 The service is currently used by 60 of Boeing’s airline customers around the world including a number of Gatwick’s airlines.

2.6 At the 2016 Farnborough Air Show an agreement was announced between Boeing and Norwegian for Boeing to provide GoldCare services to Norwegian Airlines - an agreement that represents the largest commercial services order in Boeing’s history.

2.7 A European base is needed from which to provide these services, and last November BCASEL and GAL announced the plans to build the facility and base the GoldCare operation at Gatwick. Given that Norwegian are one of Gatwick’s most important airlines, with a significant operation based at Gatwick, the location of the facility at Gatwick is a logical and efficient choice.

2.8 Unlike the other three hangars at Gatwick which are airline specific (British Airways, Virgin Atlantic and easyJet) the proposed facility is also designed to support BCASEL’s other European GoldCare customers who fly their aircraft to Gatwick, but Boeing will not be maintaining aircraft that do not operate commercial flights into Gatwick.


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2.9 The investment will provide a new ‘state of the art’ maintenance hangar to facilitate line maintenance work that needs to be undertaken in a controlled hangar environment. The investment in the new facility is estimated at some £88 million.

2.10 The proposed investment at Gatwick also follows on from a joint commitment made by the UK Government and Boeing on a long-term partnering initiative for prosperity and growth that is expected to see the creation of a further 2,000 new Boeing jobs in the UK as part of Boeing’s long-term strategy for increasing investment in the UK.

2.11 The bringing forward this development at Gatwick will:

i) Offer significant employment, training and apprenticeship opportunities, including the creation of over 130 jobs at the site;

ii) Provide wider indirect and induced economic benefits from supply chain and support services;

iii) Provide a significant up-lift in Gatwick’s aircraft maintenance capability and capacity, as the airport continues its growth in both short and long haul services; and

iv) Bring a premium, prestigious Aviation brand to Gatwick Airport and the Gatwick Diamond Economic Area.

2.12 Section 6 of this statement comments further on the economic benefits of the development drawing on a Local Economic Assessment prepared by Oxford Economics.

The Application Site and its Surroundings

2.13 The application site is within the boundary of the Airport, within the North West Development Zone.

2.14 The development would take place on land that has for a number of years been allocated in the Gatwick’s Masterplans for aircraft maintenance development and is therefore consistent will the long term vision for the airport.

2.15 The site lies immediately to the west of the ‘Uniform’ taxiway and stands - which opened in 2011 (Planning Permission Reference CR/2008/0665), south of surface water control Pond ‘M’ (which formed part of the same planning permission) and north of the Airport’s concrete batching plant and construction logistics area (Planning Permission Reference CR/2001/0292).

2.16 The broad location for the development is shown in Figure 2.1 below.

2.17 The planning application site boundary extends to some 10.4 hectares.

http://www.boeing.co.uk/news-media-room/news-releases/2016/july/boeing-uk-government-announce-long-term-initiative.page?




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Figure 2.1: Location Plan

2.18 The southern part of the site has been previously used for storage of materials and spoils from previous airfield projects, which is then recycled and re-used as hard core in connection with airport projects.

2.19 The eastern part of the site contains a c. 50 metre wide strip of managed airfield grassland and the route of Larkins Road (which serves an airport construction logistics area and the airport’s concrete batching plant).

2.20 The northern and western parts of the site are undeveloped and comprise areas of grassland and the remnants of a former woodland and hedgerows which have been eroded by previous development in this part of the airport. A remnant channel of the Man’s Brook also traverses the site.

2.21 The Airport has for some years implemented a Biodiversity Action Plan, to cover Brockley Wood and the River Mole Corridor. The development site lies adjacent to but outside this corridor.

2.22 Brockley Wood lies to the west of the site. It has recently been designated as Ancient Woodland. In accordance with the airport Masterplan the proposed development has been designed to avoid impinging on Brockley Wood. Indeed the proposals provide for a new 20 metre wide buffer between the site and the woodland which would be planted to provide added long term protection to the woodland and its biodiversity interests.

2.23 In 2011, as part of the NWZ stands development, a 350m section of the landside bund which extends along the inside of the diverted River Mole corridor was extended and increased in height to an average of some 14


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metres. Tree and shrub planting on its upper sides will increase the visual screening to 26 metres.

Current Aircraft Maintenance and Controls at Gatwick

2.24 Gatwick Airport currently accommodates three aircraft maintenance hangars which support day to day maintenance of a number of the airport’s existing airlines. These maintenance facilities are a British Airways hangar on the south side of the airport and Virgin Atlantic and EasyJet hangars on the northside of the airport, both to the west of North Terminal.

2.25 Aircraft maintenance, such as minor repairs, also occurs on stands around the airport as part of day to day operations. This maintenance may require an aircraft engine to be started to check its oil pressure and the systems it supports, and then stopped shortly after. Such start-stop runs and other low powered testing are unlikely to be distinguishable from general taxiing and ramp noise at the airport.

2.26 A very small part of the aircraft maintenance activities currently undertaken at the Airport requires engine testing to be undertaken at high power (“high power” means any power setting above ground idle). This type of testing has to be controlled very carefully for noise and safety reasons.

2.27 As explained in Section 4 of this Statement, the type of aircraft maintenance to be carried out in the proposed new hangar is light maintenance, and the need for any high powered engine tests will be limited and infrequent.

2.28 In any event a Gatwick Airport Directive (GAD)1 on engine testing puts in place procedures and imposes strict controls on all engine testing to ensure any disturbance to surrounding communities from noise generated during testing is minimised.

2.29 Under this GAD the airport must give permission prior to any testing occurring and the approval process requires taking into account safety considerations and potential effects on the local community. This affects both the timing and the location of any planned tests.

2.30 The GAD requires that high powered testing is only permitted in designated locations around the airport and is effectively prohibited at night (between 22.00 and 07.00).

2.31 Gatwick’s 2015 Section 106 Agreement with Crawley Borough Council (CBC) and West Sussex County Council sets out a limit of 250 high powered ground run engine tests per 6 rolling month period before Gatwick is required to

1 GAD/F:45/15 - Procedure for Aircraft Engine Testing


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undertake prescribed further actions, such as assessing the impacts of such a level of testing on local communities and considering steps to mitigate any impacts arising2. Current engine testing operations average around 100 engine tests per 6 month rolling period (equating ordinarily to less than 15 high powered engine runs per month). Because the maintenance operations at the proposed development envisage very few engine tests the development will not trigger this obligation.

EIA Screening

2.32 In December 2016 GAL submitted a screening request to CBC seeking an opinion as to whether the proposed development would need a formal Environmental Impact Assessment.

2.33 In January CBC confirmed that the development did not need an EIA.

2.34 Notwithstanding that a formal EIA is not deemed to be required, the application is supported by a series of reports which contain the results of a number of environmental studies.

Pre Application Consultation

2.35 Pre-application discussions have been held with planning and other officers of CBC to agree the scope of the planning application and agree how impacts could best be mitigated.

2.36 Prior to submission of the application pre-application meetings and other engagement activities have also been held with a number of other statutory and non-statutory stakeholders including:

Environment Agency

Aerodrome Safeguarding consultees including GAL, ANS and NATS.

Mole Valley District Council

Charlwood Parish Council

Surrey County Council County Archaeologist

West Sussex County Council Highways

Members of Surrey Bat Group

2.37 The proposed development and the contents of the supporting application reports reflect and respond to matters raised in those discussions.

2 Section 106 Agreement between GAL, Crawley BC and West Sussex CC dated 10th December 2015 - Obligation 4.4.


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3 The Proposed Development and its Operation

3.1 This section summarises the proposed development and how it would operate. Further information is contained in the Design and Access and Sustainability Statement and the application is accompanied by visual and illustrative materials.

3.2 In summary the development comprises a new airside Hangar building with apron frontage and taxiway access, adjoining buildings for administration, workshops and plant, and appropriate access for heavy goods vehicle deliveries.

3.3 The development will also require diversion around the site of Larkins Road (an internal airport access road), and provision of security fencing for a new airside/landside boundary.

The Hangar

3.4 The Hangar design concept is shown in the Figure 3.1 below.

Figure 3.1 Rendered Image of Proposed Hangar

3.5 The hangar and its apron would be orientated so as to align with the general airport grid layout. The long axis of the building would be parallel with taxiway Uniform, with the access to the facilities being at right angles to the taxiway.

3.6 The design aircraft are the B777-X, B787-10 Dreamline and 737-MAX. The dimensions of these aircraft are contained in Table 2.1 below.


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Table 2.1 Design Aircraft Dimensions

Aircraft Length Wingspan Tail fin height

B777-X 76.7m 71.8m 19.7

B787-10 Dreamliner 68.28m 60.12m 17.02m

737-MAX 42.2m 35.9m 12.3m

3.7 The external dimensions of the Hangar would be some 170m wide and 101m deep. The internal dimensions of the Hangar would be some 166m metres wide x 97 metres deep.

3.8 The interior of the building is sized to allow two of the largest design aircraft (the B777-X) to be parked nose-in, wingtip to wingtip with their tails facing the taxiway and with sufficient space within the hangar to manoeuvre around them to undertake maintenance activities.

3.9 Architecturally the buildings have the appearance of series of rectangular boxes placed together and stepping down in height with increasing distance from the taxiway.

3.10 The frontage facing the taxiway is higher so as to accommodate the tail fins of the largest design aircraft within the building. Additional height is required within the building above the tail fin to enable lifting gear to operate safely, for works and repairs to tail fins, and to accommodate the clear span roof construction members for the structural design. The front section of the hangar will therefore be 32m high (above finished floor level) over a distance of approximately 40m.

3.11 The rear section of the main building would then step down to 23.3m above ground level over a distance of approximately 61m. This would contain the aircraft fuselage and nose where a lower working height is required.

3.12 At the rear of the Hangar building and stepping down to 14.2m high, over 2 storeys, are administration offices and workshops, small parts and equipment storage, staff lockers and washrooms and other ancillary accommodation.

External Materials

3.13 Full details of the proposed external materials are provided on the application drawings.

3.14 The Hangar is substantially of steel construction and will be metal clad. Careful consideration has been given to the appearance of the Hangar to reduce its visual impact. The high bay element is expressed as a defined form with a light goosewing grey cladding. This reduces the visual impact of the form when viewed against all but the clearest skies. The lower bay hangar form is then created in a contrasting darker grey material. This contrast will create a layering effect when viewed from the West visually breaking up the form.


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3.15 The materials and profiles have also been design to avoid adverse effects on to navigational aids, radar systems and the instrument landing system.

Sustainable Design

3.16 Further details on the design of the development, including the measures such PV Cells, ground source heat pump, rainwater harvesting, and lighting that have been taken to ensure the building meets the BREEAM excellent standard for water and energy credits, is described in the Design and Access and Sustainability Statement.

Other Associated Works

3.17 Other aspects of the proposed hangar development include:

An aircraft parking apron in front of the hangar, approximately 163m wide by 94.5m deep. This is sized to accommodate two aircraft side by side.

A new taxiway bell mouth connecting the Hangar apron to taxiway Uniform.

Provision of parking bays and external storage yards to allow for the manoeuvring of heavy goods vehicles and lay down of large aircraft parts;

An internal airside road will be provided around the Hangar perimeter to allow for deliveries of parts and other equipment to the Hangar and its office buildings and to allow aircraft tugs to exit through the rear of the hangar. This road will extend northwards from the site to meet the existing airside road at the northern end of Uniform taxiway

Two foam storage tanks 10.3m high x 13.3m in diameter located to the west of the hangar building; these will feed the internal fire suppression system for the hangar.

Re-alignment of Larkins Road (an internal landside airport access road) to run to the rear of the Hangar;

A replacement Sub Station.

Re-alignment of the airside landside security fence and provision of separate security fencing to enclose the Hangar site.

Exterior Lighting - including floodlights to the front of the hangar to light the apron, exterior safety lighting to the ancillary areas to the north, south and west and lighting to the realigned Larkins Road. All lighting will be full cut off directional lighting, designed in accordance with aerodrome safeguarding requirements and to minimise visual and ecological impact.

Drainage works connecting the surface water and foul sewage to the existing airport drainage networks.


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Landscape and Ecological Mitigation & Enhancement Strategy

3.18 A Landscape and Ecological Mitigation & Enhancement Strategy has been prepared and is summarised in Section 4 of this statement.

Access

3.19 Only persons, aircraft and equipment authorised by the Hangar Operator will be allowed to use the Hangar apron or enter the Hangar premises.

3.20 No alterations to public roads outside the perimeter of the airport are proposed or needed.

3.21 The development, apart from the diverted route of Larkins Road will be entirely airside.

3.22 No staff parking is provided on the site. Staff and visitor parking will be provided at GAL’s staff car park ‘L’ which is close to the Timberham House main control post. Staff and visitors will be access the site via airside shuttle bus services after security checks.

3.23 All deliveries to the site would also be via the Timberham House control post.

Aircraft Operations and Maintenance Activities

3.24 Aircraft using the Hangar facilities will access the area from Taxiway Uniform.

3.25 Under normal circumstances an aircraft would be towed to the Hangar prior to maintenance and towed back to a stand post maintenance. Aircraft may also access and depart the Hangar apron under their own power, with departing aircraft being pushed back onto taxiway Uniform before taxiing back.

3.26 Where an aircraft arrives under its own power its engines would be shut down as soon as the aircraft is parked on the apron. Where an aircraft departs under its own power its engines will only be started during the pushback onto the taxiway.

Maintenance Activities

3.27 The proposed hangar would be in use on a 24 hour basis.

3.28 It would be used for base and line maintenance for A, B and ‘light’ C checks which are summarised in Table 3.1 below.

3.29 These essentially comprise regular maintenance and servicing checks which are carried out after an aircraft has completed a prescribed number of flight hours. A large number of the aircraft’s parts, components and systems are inspected, checked, and some are removed, replaced and tested. Typically these activities take 8-12 hours to complete.


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3.30 Whilst some of these could be carried out on stand there are advantages in the works being carried out in the controlled environment provided by a hangar.

3.31 There will be occasions where maintenance is performed on engines including complete engine changes, which involve disconnecting and removing an engine from its casing and reconnection of a new engine.

3.32 Aircraft engines would not be run on the apron other than on arrival and immediately before push back and occasionally for a 10 - 15 minute period at idle setting following an engine wash, subject to compliance with and approval of GAL under the Procedures for Engine Testing Directive - GAD/F:45/15.

3.33 On rare occasions a high power engine run may be required. This would be performed in accordance with the restrictions and locations defined in the GAD procedures. BCASEL have estimated that this is unlikely to occur more than once a month and probably far less.

3.34 Given the expected rarity of the need to carry out of high powered tests, the overall number of tests carried out will remain well below the ‘trigger’ level in the S.106 agreement for when Gatwick is required to undertake certain further measures on ground noise.

Table 3.1: Types of Engine Checks

"A" Checks Performed every 7- 9 days (approximately 80 - 100 flight hours). It averages 10 - 20 man-hours. Some may still be carried out on stands

"B" Checks The "B" check is a more thorough maintenance check. Accomplished approximately every two months (roughly 500 - 600 flight hours). Besides specific service performed on the aircraft, a detailed series of systems and operational checks are performed. A "B" check requires approximately 100 man-hours on narrow body aircraft and approximately 200 - 300 man-hours on wide body aircraft.

"C" Checks The "C" check is the most thorough type of maintenance work performed. The airframe - virtually the entire aircraft - goes through an exhaustive series of checks, inspections and overhaul work.

There are ‘light’ and ‘heavy’ "C" checks depending on the type of aircraft.

Narrow body "C" Checks - Typically two types of "C" checks on narrow body planes. The first is a "Light C" check, which occurs approximately every 15 - 18 months. It requires approximately 2,100 man-hours and three days to accomplish. Every fourth


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"Light C" check becomes a "Heavy C" check. This check requires 20,000 - 30,000 man-hours and takes from three to five weeks to accomplish.

Wide body "C" Checks - Because of the complexity of wide body aircraft, all "C" checks are "Heavy C" checks. The complete airframe inspection and service is done every 24 - 30 months. It takes approximately 10,000 man-hours and from two to four weeks to accomplish a wide body "C" check.

‘Heavy C checks are undertaken at either an MRO heavy maintenance or the regional Maintenance Facility not Gatwick.

Proposed Construction and Demolition Works

3.35 The development would not involve any major demolition works, but would involve diversion of Larkins Road, removal and reinstatement of security fencing, removal and replacement substation and clearance of that part of the side which has been used for storage of construction arisings in connection with the concrete batcher plant operation.

3.36 To construct the proposed development a contractor's compound would be established on the site, comprising site offices, welfare facilities, and where storage and management of construction materials will be located.

3.37 On completion of the development the compound would be removed and the site restored.

3.38 It is estimated that the construction period would last for 18 months.

3.39 Construction works would be expected to take place during normal daytime working hours (07.00 to 19.00 Monday to Friday, and 07.00 to 13.00 on Saturdays). Being an operational airport there may be a limited number of occasions when construction may need to take place outside of these hours.

3.40 A Construction Environmental Management Plan would be prepared setting out further details on how construction impacts will be controlled and minimised such as:

Working hours

Construction traffic access and management including restrictions on routes to be used for construction traffic

Construction worker travel plan

Waste management controls and procedures

Measures to supress dust and control noise

Community liaison


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4 Landscape and Ecological Mitigation & Enhancement Strategy

4.1 Gatwick’s specialist environmental consultants have undertaken habitat and species surveys, a tree survey and a landscape and visual assessment.

4.2 The development design has sought to avoid and minimise impacts on trees and habitat. A Landscape and Ecological Mitigation & Enhancement Strategy (LEMES) has been prepared setting out how unavoidable impacts will be mitigated and compensated and how the objective of achieving a ‘no net loss’ in biodiversity can be achieved.

4.3 The Hangar will require the removal of a small copse of trees which borders Larkins Road. Additionally some 220m of the former channel of the Man’s Brook between Brockley Wood and Larkins Road, and the mature trees which border it, will be removed. In total, 141 trees would be lost.

4.4 The development will also remove an area of improved grassland and some standing water in the form of ditches and water-logged ground.

4.5 Some of the trees provide roosting and foraging opportunities for bats. The habitat on the site also supports a small population of grass snakes, harvest mice and invertebrates.

4.6 A 20m buffer has been preserved between the edge of the development and Brockley Wood. This will be planted with 500 trees and other landscaping. This is the number of replacement trees required under Local Plan replacement tree planting Policy CH3.

4.7 The trees planted will meet a planting palette approved by Airport Safeguarding with a maximum of 5% berry bearing species. As far as possible, new planting will consist of native species, appropriate for the general landscape character for the West Sussex / Surrey border.

4.8 The mixture of species in the new planting, range from relatively quick growing species such as hazel and willow, to species that take longer to establish such as alder (the latter planted as individual specimens to prevent the creation of closed canopies as the plants mature). This means that a variety of niche habitats will begin to develop over time.

4.9 Whilst it is never possible to directly replace an area of woodland or a hedgerow, the provision of new planting helps to minimise the loss of the original habitats and will establish a new mosaic of habitat types and linkages within the area. In the longer term (10-20 years), the new planting will become better established and help to provide new dispersal corridors and foraging habitat for a range of species.


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4.10 The LEMES provides for harvest mice and grass snakes to be relocated to the surrounding habitat managed by Gatwick for its biodiversity potential, for bat boxes to be installed on land to the west of the airport and for future monitoring programmes of bats, snake and birds in each of the first three years, following completion of the development to assess the population status.

4.11 Additionally, a low screen bund (circa 1m high) will be provided to follow the west side of Larkin’s road as it curves around the development. This will be sown with wildflower grasses and managed in accordance with Aerodrome Safeguarding requirements. It will provide habitat principally for burrowing invertebrates local to Gatwick

4.12 The LEMES also provides for some additional planting on the landscaped bund to assist further in screening the airport and views of the development from countryside to the north. The lighting strategy for the Hangar and the diverted Larkin’s Road will be designed to minimise light spillage into Brockley Wood.

4.13 The hangar building itself will help to shield light spill from the aircraft aprons on the east side of Uniform taxiway. Nevertheless, lighting will be associated with the exterior of the hangar and its apron and along Larkins Road. Final details of the lighting design will be submitted for the approval of the Local Authority and will be informed by the Bat Conservation Trust’s best practice guidance on lighting design.

4.14 The development leads to the loss of a remnant section of the Man’s Brook. It had originally been proposed to divert this, but due to the sensitivity of creating new open water bodies in the vicinity of the airport’s flight path which risk attracting birds, it has instead been agreed with the EA and Crawley that an appropriate mitigation would be to enhance a number of other ponds on the east side of the airport in one of Crawley’s designated Biodiversity Opportunity Area. A separate Land Drainage Consent application will be made to CBC, accompanied by a Water Framework Directive assessment.

4.15 Further invertebrate enhancement works and additional bird nesting boxes are also proposed in Biodiversity Opportunity Area.

4.16 Because the proposals for the additional planting on the landside bund and the habitat enhancement works in the Biodiversity Opportunity Area are outside the application site it is proposed that a S.106 agreement is made to secure these improvements. A draft agreement is provided in Appendix 2.


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5 Planning Policy and Guidance

5.1 This section summarises key national and local planning policies relevant to the proposed development.

5.2 The policies identified are those regarded as the most relevant. This covers National Planning Policy and the policies of Crawley Borough Council.

Legal Context

5.3 Section 38(6) of the Planning and Compulsory Purchase Act 2004 and Section 70(2) of the Town and Country Planning Act 1990 require that applications for planning permission must be determined in accordance with the development plan, unless material considerations indicate otherwise.

5.4 The Statutory Development Plan comprises the following documents:

Crawley Borough Local Plan (2015) (‘CLP’)

5.5 Other relevant policy documents include Crawley Borough Council Supplementary Planning Documents and the Gatwick Airport Masterplan (2012)

National Policy

National Planning Policy Framework (2012)

5.6 The National Planning Policy Framework (NPPF) sets out the Government’s planning policies for England and how these are expected to be applied. The NPPF sets out a presumption on favour of sustainable development.

5.7 These policies articulate the Government’s vision of sustainable development, which should be interpreted and applied locally to meet local aspirations.

5.8 The document encourages positive, balanced decisions, emphasises the primacy of the development plan and local decision making.

5.9 Paragraph 7 provides the three dimensions to sustainable development in the planning system. These dimensions define the economic, social and environmental roles of the planning system:

an economic role – contributing to building a strong, responsive, and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure;


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a social role – supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of the present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being; and

an environmental role – contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy.

5.10 Paragraph 9 states:

Pursuing sustainable development involves seeking positive improvements in the quality of the built, natural and historic environment, as well as in people’s quality of life, including (but not limited to):

making it easier for jobs to be created in cities, towns and villages;

moving from a net loss of bio-diversity to achieving net gains for nature;6

replacing poor design with better design;

improving the conditions in which people live, work, travel and take leisure; and

widening the choice of high quality homes.

Core Planning Principles

5.11 Twelve core land-use planning principles are set out in paragraph 17 of the NPPF. Those most relevant to the proposed development are:

proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities;

always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings;

support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change, and encourage the reuse of existing resources, including conversion of existing buildings, and


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encourage the use of renewable resources (for example, by the development of renewable energy);

contribute to conserving and enhancing the natural environment and reducing pollution. Allocations of land for development should prefer land of lesser environmental value, where consistent with other policies in this Framework;

actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable;

Delivering Sustainable Development

5.12 There are thirteen key themes to delivering sustainable development within the NPPF. Those most relevant to the proposed development are as follows.

Building a strong, competitive economy

20. To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century.

21. Investment in business should not be over-burdened by the combined requirements of planning policy expectations. Planning policies should recognise and seek to address potential barriers to investment, including a poor environment or any lack of infrastructure, services or housing.

Promoting sustainable transport

31. Local authorities should work with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development, including…transport investment necessary to support strategies for the growth of … airports...

33. 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.

Requiring Good Design

56. The Government attaches great importance to the design of the built environment. Good design is a key aspect of sustainable development, is


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indivisible from good planning, and should contribute positively to making places better for people.

61. Although visual appearance and the architecture of individual buildings are very important factors, securing high quality and inclusive design goes beyond aesthetic considerations. Therefore, planning policies and decisions should address the connections between people and places and the integration of new development into the natural, built and historic environment.

Meeting the challenge of climate change, flooding and coastal change

93. Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change, and supporting the delivery of renewable and low carbon energy and associated infrastructure. This is central to the economic, social and environmental dimensions of sustainable development.

In determining planning applications, local planning authorities should expect new development to:

comply with adopted Local Plan policies on local requirements for decentralised energy supply unless it can be demonstrated by the applicant, having regard to the type of development involved and its design, that this is not feasible or viable; and

take account of landform, layout, building orientation, massing and landscaping to minimise energy consumption.

100. Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere.

101. The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding. The Strategic Flood Risk Assessment will provide the basis for applying this test. A sequential approach should be used in areas known to be at risk from any form of flooding.

102. If, following application of the Sequential Test, it is not possible, consistent with wider sustainability objectives, for the development to be located in zones with a lower probability of flooding, the Exception Test can be applied if appropriate. For the Exception Test to be passed:


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it must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared; and

a site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall.

Both elements of the test will have to be passed for development to be allocated or permitted.

103. When determining planning applications, local planning authorities should ensure flood risk is not increased elsewhere and only consider development appropriate in areas at risk of flooding where, informed by a site-specific flood risk assessment20 following the Sequential Test, and if required the Exception Test, it can be demonstrated that:

within the site, the most vulnerable development is located in areas of lowest flood risk unless there are overriding reasons to prefer a different location; and

development is appropriately flood resilient and resistant, including safe access and escape routes where required, and that any residual risk can be safely managed, including by emergency planning; and it gives priority to the use of sustainable drainage systems

Conserving and enhancing the natural environment

109. The planning system should contribute to and enhance the natural and local environment by:

…

minimising impacts on biodiversity and providing net gains in biodiversity where possible;

preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability;

…

118. When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles:

if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;

…


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opportunities to incorporate biodiversity in and around developments should be encouraged;

planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss;

120. To prevent unacceptable risks from pollution … planning policies and decisions should ensure that new development is appropriate for its location. The effects (including cumulative effects) of pollution on health, the natural environment or general amenity, and the potential sensitivity of the area or proposed development to adverse effects from pollution, should be taken into account…

Aviation Policy Framework (2013)

5.13 The Government’s Aviation Policy Framework (APF) was published in March 2013. It sets out the Government’s objectives and principles to guide plans and decisions on airport developments.

5.14 The Government recognises that aviation is essential to the country’s economic wellbeing.

5.15 The Government supports growth of the sector within a framework which maintains a balance between the benefits of aviation and its costs – including respecting the environment and protecting quality of life.

5.16 In relation to Land-use planning and management the APF states:

3.21 The NPPF expects local planning policies and decisions to ensure that new development is appropriate for its location and the effects of pollution – including noise – on health, the natural environment or general amenity are taken into account...

The Development Plan

Crawley Local Plan (2015)

5.17 The Crawley Local Plan was adopted in 2015. It is the Development Plan for Crawley and sets out a vision, policies and proposals for future development and land use in Crawley to 2030. Key relevant policies are presented below.

Policy SD1: Presumption in Favour of Sustainable Development

5.18 Policy SD1 states:


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In line with the planned approach to Crawley as a new town, and the spatial patterns relating to the neighbourhood principles, when considering development proposals the council will take a positive approach to approving development which is sustainable. The council will work proactively in partnership with applicants, stakeholders and other partners to jointly find solutions which mean that development can be approved wherever possible, whilst securing development that improves the economic, social and environmental conditions of Crawley and the wider Gatwick Diamond sub region. Development will be supported where it meets the following strategic objectives:

1. Progress towards Crawley’s commitment to being carbon neutral by 2050 and adapts to climate change;

2. Complements Crawley’s character as a compact town within a countryside setting, developed on a neighbourhood principle and maximises the use of sustainable travel;

3. Respects the heritage of the borough;

4. Protects, enhances and creates opportunities for Crawley’s unique Green Infrastructure;

5. Provides a safe and secure environment for its residents and visitors;

6. Provides for the social and economic needs of Crawley’s current and future population; and

7. Accords with the policies and objectives set out in this Plan unless material considerations indicate otherwise.

Policy GAT1: Development of the Airport with a Single Runway

5.19 Policy GAT1 states:

Within the airport boundary as set out on the Local Plan Map, the council will support the development of facilities which contribute to the safe and efficient operation of the airport as a single runway, two terminal airport up to 45 million passengers per annum provided that:

i. The proposed use is appropriate within the airport boundary and contributes to the safe and efficient operation of the airport; and

ii. Satisfactory safeguards are in place to mitigate the impact of the operation of the airport on the environment including noise, air quality, flooding, surface access, visual impact and climate change; and


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iii. The proposed use would not be incompatible with the potential expansion of the airport to accommodate the construction of an additional wide spaced runway.

Policy CH3: Normal Requirements of All New Development

5.20 Policy CH3 states:

All proposals for development in Crawley will be required to:

a) Be based on a thorough understanding of the significance and distinctiveness of the site and its immediate and wider context and demonstrate how attractive or important features which make a positive contribution to the area would be integrated, protected and enhanced. These features include: views, landmarks, footpaths, rights of way, trees, green spaces, hedges, other historic landscape features or nature conservation assets, walls and buildings;

b) Be of high quality in terms of their urban, landscape and architectural design and relate sympathetically to their surroundings in terms of scale, density, height, massing, orientation, views, landscape, layout, details and materials…

c) Provide or retain a good standard of amenity for all existing and future occupants of land and buildings, including compliance with internal standards for new dwellings as set out in Policy CH5, and not cause unreasonable harm to the amenity of the surrounding area by way of overlooking, dominance or overshadowing, traffic generation and general activity, for example noise, smells and/or vibration;

d) Retain existing individual or groups of trees that contribute positively to the area and allow sufficient space for trees to reach maturity. … Where a development is proposed or where trees would be lost to development, tree planting should accord with the standards set out in Policy CH6;

e) Demonstrate how “Secure by Design” principles and guidance set out in “Secured by Design” design guide (as amended) have been incorporated into development proposals to reduce crime, the fear of crime, anti-social behaviour and disorder...;

f) Meet the requirements necessary for their safe and proper use, in particular with regard to access, circulation and manoeuvring, vehicle and cycle parking, loading and unloading, and the storage and collection of waste/recycling; and…

Development proposals should comply with any relevant supplementary planning guidance produced by the council…


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Policy CH6 Tree Planting and Replacement Standards


…Where development proposals would result in the loss of trees, applicants must identify which trees are to be removed and replaced in order to mitigate for the visual impact resulting from the loss of the tree canopies. Proposals must demonstrate that the number of replacements accords with the following requirements:

Trunk diameter of each tree (measured in cms at 1.5m above ground level) to be removed:

No. of replacement trees required:

Less than 19.9 20 – 29.9 30 – 39.9 40 – 49.9 50 – 59.9 60 – 69.9 70 – 79.9 80+

1 2 3 4 5 6 7 8

The girth of replacement trees will vary depending on species and location but should balance the need to reduce the likelihood of new tree stock failing to survive whilst providing visual amenity from the outset.

The additional and replacement tree planting requirements would normally be expected to be met within the development site. Where the local planning authority agrees that this is not feasible or desirable, commuted sums will be sought in lieu on a per tree basis, taking account of constraints to planting. The approach would enable the green character and appearance of the borough to be maintained through tree planting on appropriate and available land.

Policy CH12: Heritage Assets


All development should ensure that Crawley’s designated and non-designated heritage assets are treated as a finite resource, and that their key features or significance are not lost as a result of development.

Where a development affects a heritage asset or the setting of a heritage asset, a Heritage Impact Assessment will be required. This should describe the significance of any heritage assets affected and the contribution made by their setting, the impact of the development, and any measures adopted to ensure the heritage asset is respected, preserved or enhanced or, for exceptionally significant development, relocated.


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If, in exceptional circumstances, a heritage asset is considered to be suitable for loss or replacement, and it has been demonstrated its site is essential to the development’s success, proposals will need to demonstrate how they have recorded the heritage asset:

i. in line with a written scheme of investigation submitted to, and approved by, Crawley Borough Council; or

ii. in the case of standing structures, to a minimum of Historic England recording Level 2, or higher if specified by the council.

Policy EC1: Sustainable Economic Growth

5.23 Policy 4/6 states:

Crawley’s role as the key economic driver for the Gatwick Diamond will be protected and enhanced. The council will ensure that all suitable opportunities

within the borough are fully explored to enable existing and new businesses to grow and prosper.

Policy ENV2: Biodiversity

5.24 Policy ENV2 states:

All development proposals will be expected to incorporate features to encourage biodiversity where appropriate, and where possible enhance existing features of nature conservation value within and around the development.

Habitat and species surveys and associated reports will be required to accompany planning applications which may affect the areas listed below or sites showing likely ecological value based on past ecological surveys.

Hierarchy of Biodiversity Sites

To ensure a net gain in biodiversity, the following areas will be conserved and enhanced where possible and the council will support their designation and management:

1. Nationally designated sites:

Sites of Special Scientific Interest (SSSI).

SSSI will receive the highest level of protection for habitat conservation value in line with national legislation, policy and guidance.

2. National Planning Policy Framework Sites

Ancient Woodland, and aged or veteran trees


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Planning permission will not be granted for development that results in the loss or deterioration of ancient woodland and aged or veteran trees unless the need for, and benefits of, the development in that location clearly outweigh the loss. A buffer zone between development and ancient woodland will be required in line with Natural England Standing Advice.

3. Locally designated sites, and habitats and species outside designated sites:

Local Nature Reserves

Sites of Nature Conservation Importance

Nature Improvement Areas

Habitats of Principle Importance identified in S41 of the Natural Environment and Rural Communities Act 2006 or Biodiversity Action Plans

Biodiversity Opportunity Areas

Where Protected Species are present

Where Species of Principal Importance are present, as identified in S41 of the Natural Environment and Rural Communities Act 2006.

Proposals which would result in significant harm to biodiversity will be refused unless:

i. this can be avoided by locating on an alternative site with less harmful impact; or

ii. the harm can be adequately mitigated, or, as a last resort, compensated for

Policy ENV6: Sustainable Design and Construction


In order to maximise carbon efficiency …Proposals for new non-domestic buildings should achieve BREEAM Excellent (for water and energy credits) where technically and financially viable.

All development, including the alteration and extension of existing buildings, should consider how it may achieve the following sustainability objectives: In relation to carbon:

i. Take an active approach to reducing its need to consume energy;

ii. Utilise renewable and low carbon energy technologies where appropriate;

iii. Look at ways to improve the existing building when adding improvements or extensions;


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iv. Minimise the amount of carbon emitted throughout the implementation and construction process and ensure any existing embedded carbon onsite is retained;

v. Consider the establishment of district energy networks within heat priority areas or near potential sources of waste energy and consider connection or futureproofing developments for connection (see Policy ENV7);

For other locally-specific climate change issues relating to Crawley, all development should consider how it will:

vi. Tackle the serious water stress in the borough (see Policy ENV9);

vii. Cope with future temperature extremes, and ensure it does not unduly increase the impact of heatwave events.

All development involving the creation of a new dwelling or the creation, change of use, or refurbishment of over 100sqm of internal floorspace should submit a Sustainability Statement demonstrating how the sustainability objectives above have been addressed during the design and construction processes. Further details on how these objectives can be addressed can be found in the Planning and Climate Change SPD.

Policy ENV7: District Energy Networks


The development of district energy networks and associated infrastructure is encouraged and should be approved unless it results in significant adverse impacts on the environs.

Priority areas for the delivery of District Energy Networks are identified on the Local Plan Map.

Any major development within the borough, and all development proposals within a priority area for District Energy Networks that would involve the creation of a new dwelling or the creation of over 1000sqm of internal floorspace, should demonstrate how they have considered the following hierarchy:

i. where a network is in place in the immediate area: connect to an existing District Energy Network; or

ii. where a network is not yet in place, development should:

a) consider developing its own system for supplying energy to any surrounding existing or planned buildings. Any system installed should be compatible with a wider district energy network and developments should ensure that connection


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to a wider network is facilitated in the future through good design and site layout; or

b) consider how it may include site-wide communal energy systems; or

c) be “network ready”, optimally designed to connect to a District Energy Network on construction or at some point after construction.

An alternative approach to securing decentralised low carbon energy may be justified, on a case-by-case basis, where developments demonstrate that the objectives of Policy ENV7 cannot be achieved in line with the criteria above, due to technical or financial viability, or due to site or development specifics.

All development subject to the requirements of Policy ENV7 must be supported through the submission of a Sustainability Statement in compliance with the Planning and Climate Change SPD.

Policy ENV8: Development and Flood Risk


Development proposals must avoid areas which are exposed to an unacceptable risk from flooding, and must not increase the risk of flooding elsewhere. To achieve this, development will:

i. be directed to areas of lowest flood risk, having regard to its compatibility with the proposed location in flood risk terms, and demonstrating (where required) that the sequential and exceptions tests are satisfied;

ii. refer to the Environment Agency Flood Map for Planning and Crawley Strategic Flood Risk Assessment to identify whether the development location is situated in an area identified as being at risk of flooding;

iii. where identified in the SFRA, demonstrate through a Flood Risk Assessment how appropriate mitigation measures will be implemented as part of the development to ensure risk is made acceptable on site, and is not increased elsewhere as a result of the development;

iv. ensure that proposals on all sites of 1 hectare or greater are accompanied by a Flood Risk Assessment, to include detail of mitigation demonstrating how surface water drainage from the site will be addressed;

v. reduce peak surface water run-off rates and annual volumes of run-off for development through the effective implementation, use and maintenance of SuDS, unless it can be demonstrated that these are not technically feasible or financially viable.

Further guidance on how to achieve these objectives will be provided in the Planning and Climate Change SPD


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Policy ENV9: Tackling Water Stress


Crawley is situated within an area of serious water stress, and development should, therefore, plan positively to minimise its impact on water resources and promote water efficiency.

…For non-residential development, where technically feasible and viable, development should meet BREEAM Excellent including addressing maximum water efficiencies under the mandatory water credits…

Applicants must demonstrate how they have achieved the requirements of this Policy within their Sustainability Statement as required by Policy ENV6.

Policy ENV10: Pollution Management and Land Contamination


To prevent unacceptable risks from environmental pollution and land contamination, development, including extensions and intensification of existing uses, will be permitted where the proposed use:

a) would not lead to a significant increase (including cumulative increase) in levels of pollution or hazards, or where impacts can be appropriately mitigated to ensure impacts are controlled, and as far as possible reduced; and

b) is appropriate to its location in that it would not result in unacceptable disturbance or nuisance to the amenity of adjacent land uses and occupiers. Where a site is known or suspected to be at risk from contaminants or materials that present a hazard to health, information must be provided detailing the methodology through which risks will be addressed, and ensuring the treatment and/or removal of all such contaminants and materials prior to the commencement of development.

Policy ENV11: Development and Noise


People’s quality of life will be protected from unacceptable noise impacts by managing the relationship between noise sensitive development and noise sources. To achieve this, Policy ENV11 should be read in conjunction with the Local Plan Noise Annex.

…

B. Noise Generating Development

Noise generating development will only be permitted where it can be demonstrated that nearby noise sensitive uses (as existing or planned) will not


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be exposed to noise impact that will adversely affect the amenity of existing and future users. Proposals will adhere to standards identified in the Local Plan Noise Annex to establish if the proposal is acceptable in noise impact terms, and will be required to appropriately mitigate noise impacts through careful planning, layout and design. Development that would expose users of noise sensitive uses to unacceptable noise levels will not be permitted.

C. Noise Impact Assessment

A Noise Impact Assessment will be required to support applications where noise sensitive uses are likely to be exposed to significant or unacceptable noise exposure. The Noise Impact Assessment will:

i. assess the impact of the proposal as a noise receptor or generator as appropriate; and

ii. demonstrate in full how the development will be designed, located, and controlled to mitigate the impact of noise on health and quality of life, neighbouring properties, and the surrounding area.

In preparing a Noise Impact Assessment, applicants will adhere to Planning Noise Advice Document: Sussex (2013) for further guidance.

D. Mitigating Noise Impact

Where proposals are identified as being subject to significant or unacceptable noise impact, either through noise exposure or generation, the best practical means must be employed to mitigate noise impact to an acceptable level.

Policy ENV12 Air Quality


Development proposals that do not result in a material negative impact on air quality will normally be permitted. In determining whether or not a development will have a material negative air quality impact, the local planning authority will refer to the criteria set out in Air Quality and Emissions Mitigation Guidance for Sussex.

To ensure that development is appropriate in air quality terms:

a) Where identified in Air Quality and Emissions Mitigation Guidance for Sussex, development will be required to be supported by evidence detailing the air quality impact of the proposed development, and outlining an appropriate mitigation strategy that will be implemented to ensure that air quality is not materially worsened, and is where possible improved. This may be in the form of an Emissions Statement, Mitigation Statement, and/or Air Quality Statement, as appropriate.


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b) Development proposals within a declared Air Quality Management Area, will demonstrate how mitigation measures will be incorporated that help address objectives identified in the relevant Air Quality Action Plan.

c) Development that may reasonably be considered to impact upon air quality beyond the borough boundary, will be expected to contribute towards achieving a reduction in levels of air pollution, and should demonstrate how this will be achieved through an Air Quality Assessment.

In all relevant cases, development that cannot demonstrate how material negative air quality impacts will be mitigated may be refused.

Policy IN3: Development and Requirements for Sustainable Transport

5.32 Policy IN3 states:

Development should be concentrated in locations where sustainable travel patterns can be achieved through the use of the existing transport network, including public transport routes and the cycling and walking network.

Developments should meet the access needs they generate and not cause an unacceptable impact in terms of increased traffic congestion or highway safety. Developments will be permitted unless the cumulative impact on the transport network is severe and cannot be satisfactorily mitigated.

In order to consider such impacts, developments that generate significant amount of movements (thresholds as outlined in the Local List) should be supported by a:

a) Transport Statement, which assesses the impact of a development with relatively small transport implications; or a

b) Transport Assessment, which assesses the impact of a development when there are significant transport implications, and a Travel Plan, which identifies how the development will maximise the usage of sustainable modes of transport as opposed to the private motor vehicle.

The applicant should view the Local List of Planning Requirements (or any subsequent document) to ensure that they submit an appropriate Transport Statement or Transport Assessment with their planning application.

Supplementary Planning Documents

5.33 The following relevant Supplementary Planning Documents (SPDs) have been adopted or are under preparation by CBC:


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Development at Gatwick Airport SPD

5.34 This Supplementary Planning Document (SPD) was adopted by the Council in December 2008 shortly after agreement was reached on the revised Section 106 agreement between CBC, West Sussex County Council and GAL.

5.35 The SPD sets out the way in which CBC will implement policies in relation to Gatwick Airport. As such it provides further guidance for the determination of planning applications at the airport.

5.36 The SPD refers to Policy G1 of the 2008 Core Strategy (now policy GAT1 of the Local Plan) and sets out further guidance on its interpretation specifically in relation to appropriate development and uses at the airport (by reference to the Capital Investment Programme and Interim Master Plan) and environmental mitigation measures.

5.37 It confirms the Council’s continued support for the development of the airport (subject to there being satisfactory environmental safeguards) and re-confirms the principle that the Council would support development which contributes to the safe and efficient operation of the airport.

5.38 In respect of the design and visual impact Paragraph 41 confirms that the Council considers that all proposals at the airport should be of a high quality design with the scale, design and layout of new buildings complementing the existing features and built form.

Green Infrastructure SPD and Green Infrastructure Map

5.39 Crawley adopted its Green Infrastructure SPD in October 2016. Its purpose is to provide guidance on how to meet the requirements of Crawley Local Plan policies in relation to Crawley’s Green Infrastructure assets.

5.40 The SPD references policies which provide for maintaining the local Green Infrastructure network, and for the protection and enhancement of trees, open space, biodiversity, and Crawley’s relationship with the Countryside and High Weald AONB. The SPD identifies that the land east of the railway line at Gatwick is part of a Biodiversity Opportunity Area.

5.41 Developments are expected to contain measures to enhance biodiversity.

5.42 The SPD also recognised that Crawley is within the 13km aerodrome safeguarding zone around Gatwick Airport and explains that any development within this zone should not give rise to increased risk of bird strike hazard. Some aspects of proposed development, including provision of amenity planting, restoration of watercourses and implementation of Sustainable Drainage Systems, and large areas of flat/shallow pitched and green roofs have to be particularly carefully evaluated as they are known to have the potential to increase bird strike risk.

http://www.crawley.gov.uk/pw/web/int165738

http://www.crawley.gov.uk/pw/web/PUB285867



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5.43 The SPD provides guidance regarding how trees are to be considered from the outset in development proposals, how their value should be assessed, and what will be expected from a developer where development unavoidably requires their removal.

Urban Design SPD

5.44 This SPG provides guidance to developers on achieving designs which conserve energy, water and non-renewable resources. The guidance covers advice on general design principles and specific design guidance on matters such as site and building layouts, renewable energy, water conservation, crime and materials to achieve sustainable designs.

Planning and Climate Change SPD

5.45 The ‘Planning and Climate Change’ SPD describes how development in Crawley should be designed to comply with the Crawley’s Local Plan policies which address climate change. The SPD covers:

- Sustainable Design and Construction

- District Energy Networks

- Tackling Water Stress

- Development and Flood Risk

- Sustainable Transport

Guidance Note: Energy and Water Efficiency for Alterations and Extensions to Buildings

5.46 Guidance Note is to be used alongside the ‘Planning and Climate Change’ SPD. Although not mandatory, it seeks to encourage greater sustainability when carrying out alterations or extensions to buildings in Crawley. This covers:

- Reducing the need for energy in development

- Minimising carbon emissions during the development process

- Supporting District Energy Networks

- Using renewable/low carbon energy sources

- Tackling water stress

- Coping with future temperature extremes

Gatwick Airport Masterplan

5.47 In 2012 GAL published an updated Masterplan for the airport, which replaced the Interim Masterplan of 2006. The Masterplan was produced following a three month period of public consultation in Autumn 2011.




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5.48 The Masterplan looks forward to 2020 and identifies proposals envisaged for further development of the airport. It looks forward in less detail to 2030. It reports on how the development of the airport could impact local communities, for example through employment generation and environmental impacts. It also describes how the airport’s environmental impacts are managed.

5.49 The plan identifies the prospect of further hangar development in the North West Zone by 2020 on the site which is now proposed in this planning application. It also recognises that its development could result in the loss of a small area of woodland, but that it would not be expected to impact on Brockley Wood. It also identifies a need for suitable mitigation schemes to address any impacts on biodiversity, visual impact and noise.3

S.106 Agreement - GAL, Crawley BC and West Sussex CC

5.50 In December 2015 the strategic S.106 agreement between GAL, Crawley BC and West Sussex CC was refreshed.

5.51 The agreement recognises the parties desire to see Gatwick grow as a single runway, two terminal airport, and provides a series of obligations on how GAL will manage the impacts of the airport’s development. Obligations relate to matters such as air quality, noise (including engine testing), surface access, the design of development, community and the economy, and also provides for the review and preparation of action plans for air quality, noise, water quality, waste and utilities.

3 Gatwick Masterplan (July 2012) - Paragraph 9.9.11


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6 Planning Considerations

6.1 The key planning considerations are considered to be:

i) The Principle of the Development

ii) Economic and Employment Benefits

iii) Noise Impacts

iv) Landscape and Visual Impacts

v) Biodiversity

vi) Design

vii) Traffic and Transport

viii) Flood Risk and Water Resources

ix) Air Quality

x) Heritage

xi) Aerodrome Safeguarding

xii) Ground Conditions

xiii) Construction

6.2 These matters are considered below.

i) The Principle of the Development

6.3 The development of new facilities at the airport which support the safe and efficient of its operation are supported by CLP Policy GAT1.

6.4 Gatwick’s operation creates a need for a variety of functions to be located within or close to the airport to support its safe and efficient operation. These facilities support the functional needs of the airport. The provision of hangars is clearly such a facility.

6.5 The proposed hangar will provide important facility providing base and line maintenance requirements that will support efficient operation of Gatwick’s airlines.

6.6 Gatwick is also the logical and efficient choice for the BCASEL European GoldCare facility given that Norwegian are one of Gatwick’s most important airlines, with a significant operation already based at Gatwick.


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6.7 The development would therefore respond to a functional needs of the airport and its users and support the efficient and safe operation of the airport, in accordance with Policy GAT1 of the CLP.

ii) Economic and Employment

6.8 Boeing is one of the world's leading aerospace companies and the largest manufacturer of commercial and military aircraft. It is also a leading employer, employing more than 170,000 people in the United States and 2,000 across the UK. Its activities also draw on the talents of hundreds of thousands more skilled people from its worldwide supplier base, which in the UK supports a further 13,000 jobs.

6.9 The investment will provide a new £88 million, ‘state of the art’, maintenance hangar to facilitate line maintenance work that needs to be undertaken in a controlled hangar environment.

6.10 BCASEL have advised that the development would generate some 134 full and part time direct jobs. 100 of these will be skilled aircraft maintenance engineers and technicians, with other jobs in management, office, administration and support staff.

6.11 An economic assessment by Oxford Economics has estimated the local economic benefits to the Gatwick Diamond area. This has considered both the construction phase and that which would be derived from the operation of the development.

6.12 The construction phase is estimated to generate £79 million to the local (Gatwick Diamond) economy. This comprises £31 million among Tier 1 contractors, £43 million within their Gatwick Diamond-based supply chains supporting the contractors and a further £5 million induced benefit generated through wage-financed consumption in the local economy. A further £11 million in tax revenues is estimated within the Gatwick Diamond area

6.13 In operation the development the facility will sustain around 217 jobs per year in the Gatwick Diamond area - 134 jobs at the site, and 84 indirectly and through spending power of direct and indirect employment.

6.14 This employment will generate a total of £135 million within the Gatwick Diamond area (at 2017 prices) over the period to 2040, which is equivalent to around £5.9 million per year to the local economy. A further £80 million in total tax revenues is estimated within the Gatwick Diamond area, at some £3.8 million per year.

6.15 Boeing prides itself on its training education and scholarship programmes. In 2014/15 more than 5,000 of its workers benefited from these programmes providing the opportunity to learn whilst working for Boeing. The new facility


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will be a key site for the company’s training and apprenticeship schemes, with significant investment planned to enable workforce training, offering young people in the local area (and beyond) the opportunity to further-develop their skills while working and earning a wage.

6.16 Boeing aims to provide around 10 places per year for apprenticeships and training schemes within the new facility. Apprentices will have the opportunity to work towards qualifications in fields such as engineering, whilst gaining on-the-job work experience.

6.17 Programmes such as these represent investments in the human capital of the local area, helping to ensure the future productive capacity (and hence prosperity) of the Gatwick Diamond area.

6.18 The development will also provide a significant up-lift in Gatwick’s aircraft maintenance capability and capacity, and bring a prestigious Aviation brand to Gatwick Airport and the Gatwick Diamond Economic Area.

6.19 The proposed development supports sustainable economic development in accordance with national employment and economic policies and objectives and Policy EC1 of the Crawley Local Plan.

iii) Noise

6.20 A ground noise assessment has been undertaken by Hayes McKenzie. This considers noise from aircraft maintenance and taxiing to and from the hangar site, and also considers potential noise from fixed plant, traffic and construction.

6.21 The report concludes that there is no reason to consider that impacts from traffic, fixed plant or construction noise would be significant.

6.22 In respect of noise from aircraft maintenance activities and aircraft engine and auxiliary power unit (APU4) noise on the apron and adjacent taxiway detailed modelling has been carried out. This compares predicted average and short maximum noise levels at the closest local receptors with the daytime and night time threshold bands set out in the Crawley Local Plan Noise Annex for ‘Observed Effect Level’, ‘Significant Observed Adverse Effect Level’ and ‘Unacceptable Adverse Effect Level’ (OEL, SOAEL and UAEL) .

6.23 The modelling has used conservative ‘worst-case’ assumptions. For example it assumes that aircraft always taxi to and from the site under their own power, run their engines at idle power for 5 minutes after arrival and before

4 An aircraft’s APU is a tail mounted engine, which is used to power aircraft systems when its main engines are not running and when it is not connected to a fixed electrical ground power source.


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departure, and run their APUs for 30 minutes after arrival and for 10 minutes prior to departure.

6.24 These are worst case assumptions because:

i) It is expected that aircraft will normally be towed to and from the hangar, and whilst the APU would be running it would normally be shut down as soon as the aircraft is parked.

ii) Under any live taxing operations to the apron, aircraft engines would be shut down as soon as the aircraft is parked, and under live taxiing operations from the apron, aircraft engines would only be started during push-back,

iii) Aircraft engines would not be run on the apron, except for 10-15 minutes, following an infrequent aircraft engine wash; and

iv) APUs would only be operated for testing the APU or associated systems.

6.25 Even when applying these conservative assumptions the predicted LAeq (average) sound levels do not fall above the daytime lowest thresholds of UAE L (66 LAeq,16hr) or SOAEL (57 LAeq,16hr)) at any representative community location.

6.26 At night there is a risk that average sound levels would fall within the SOAEL threshold at 2 properties closest to the development site when an aircraft arrives (and is assumed to run its engines at idle power setting for 5 minutes and APU for 30 minutes), and at 1 property when an aircraft departs (and is assumed to run its APU for 10 mins and its engines are run for 5 mins at idle power).

6.27 In terms of the short term maximum noise levels, at one location – No. 3 Brook Farm – short term noise is predicted to marginally exceed the SOAEL (i.e. just fall within the SOAEL criterion) when an aircraft’s engines are run at idle power and the aircraft is standing on the hangar apron). However, engine ground running for engine testing purposes is strictly controlled by the current airport directive and BACSEL does not anticipate any requirement for engine ground running on this site except as part of standard engine shut-down and start-up procedures immediately prior to or after a departure or arrival. Any such event, if it were to occur, would therefore be for an extremely short duration.

6.28 Neither during the day or at night, even under the worst case predictions used in this assessment, are noise levels predicted to occur at levels that the Crawley Local Plan Noise Annex defines as unacceptable.

6.29 BCASEL anticipate that the need for high power engine tests would occur only rarely. Any tests would be performed in accordance with the strict controls


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and restrictions for Aircraft Engine Testing (as noted earlier in this statement) which are designed to protect the surrounding community from noise from such activities.

6.30 In conclusion, even under the worst case assessment that has been undertaken, the proposed development would not expose the local community to unacceptable noise levels. The proposed development complies with CLP Policy ENV11 and national noise policy.

iv) Landscape and Visual

Context

6.31 Gatwick Airport comprises an intensively developed area of flat, open land, which comprises a number of large airport structures such as terminal buildings and piers, a control tower, maintenance hangars and multi storey car parks as well as other large scale infrastructure such as and airfield.

6.32 The development site lies on the north side of the airport west of North Terminal, the control tower and the Virgin Atlantic hangar.

6.33 The layout and design of the facility has been very carefully considered, having regard in particular to the protection of Brockley Wood, visual impact from outside the airport and the operational needs of the development.

6.34 A Landscape and Visual Impact Appraisal has been commissioned which has informed the development and assesses the landscape and visual impacts on its surroundings.

Landscaping

6.35 The application includes a Landscape Plan and detailed landscape proposals are set out within the Landscape and Ecological Mitigation and Enhancement Strategy.

6.36 The development will result in the loss of 141 trees. One of these is assessed to be category A (high value) and sixty eight are considered to be category B (moderate value). The remaining trees are considered to be category C (low value) or category U (unsuitable for retention).

6.37 A 20 metre wide protection buffer zone is provided around Brockley Wood where it is proposed to plant 500 replacement trees and other landscaping with species that accord with aerodrome safeguarding requirements. This is the number of replacement trees required under CLP replacement tree planting Policy CH3.

6.38 This planted buffer will provide enhanced opportunities for biodiversity by helping to protect the ancient woodland.


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External Appearance and Visual Impact

6.39 The LVIA recognises that the most sensitive receptors to the development are likely to be to the north and west of the airport and that, from some limited viewpoints, the hangar would be visible above Brockley Wood and the airport perimeter landscaped bund.

6.40 In recognition of the landscapes sensitivity to a development on the scale proposed, the design of the hanger has gone through a number of iterations, informed in part by the ongoing landscape and visual appraisal. This iterative process has achieved a development which is considered to have the least possible landscape and visual impacts.

6.41 The development is logically designed to meet operational requirements and this requires the hangar building to be the dimensions it is. The design approach, however, has been to minimise its visual impact by adopting a stepped design which also reduces its bulk and breaks up its massing and visual impact.

6.42 At some 32m high the front section of the hangar would be higher than the Virgin Atlantic hangar (24m) and the concrete batcher plant towers (22m), but not dissimilar in height to other large buildings which are a characteristic of the airport.

6.43 High quality and carefully selected palette of materials are proposed which will assist with the integration of the building into the landscape. For example it is proposed that the high bay element would be coloured ‘goosewing grey’ – a light shade of grey - which is recognised as helping to blend the development into its surroundings. The Lower bays would be clad in darker shades of grey.

6.44 Light emanating from windows on the highest elevation of the hangar facing west were identified as having the potential to be visible at night above the tree line of Brockley Wood, and have therefore been removed from the design and replaced by roof lights.

6.45 Additional planting is also proposed on the airport perimeter bund which will help to filter views from the north and north-west.

6.46 As set out in the Landscape and Visual appraisal, although the character of the site would clearly change as a result of tree removal and the introduction of the proposed building, roads and parking areas, the proposed development would be in character with the local airport landscape which contains other large buildings the height, scale and massing of which is are not dissimilar to the proposed development.


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6.47 There would be minor impacts on the landscape character within the wider study area5 during construction. After completion of the development the impact on the landscape would be initially be moderate due to the visibility of the uppermost part of the hangar. But the establishment of trees on the landside bund would, over time, assist with the scheme’s integration into the landscape, causing a reduction in the magnitude of change to a minor or negligible adverse impact.

6.48 In respect of visual impact the construction impacts are considered to be moderate for residents living on the eastern edge of Charlwood and from parts of some public rights. Impacts are assessed as minor in respect of more remote views from elsewhere within the study area and views from the Sussex Border Path rights of way, due to the fact that views of the construction works would be a small additional component in the context of a wider view of the airport and other urban development on the northern edge of Crawley and Horley.

6.49 Once the hangar is completed the visual impacts are assessed as being minor or negligible from different viewpoints:

- From near distance views, the hanger would be substantially or completely enclosed by the existing bund, woodland and roadside vegetation.

- From isolated farms and individual properties within the countryside west of Gatwick, and from properties on the eastern edge of Charlwood the upper part of the hangar building would be visible above Brockley Wood and the landscaped bund. Summer views are likely to be more limited than winter ones, due to the screening effect of summer foliage. An initial moderate impact would reduce to minor over time with trees establishing on the landscaped bund.

- For the more distant properties on the ridge west and north-west of Charlwood, and from public rights of way, including the Sussex Border Path the hangar would be visible, but not prominent and it would be seen as a small component within the of the overall view, which extends over Gatwick and towards Crawley.

6.50 There would be no adverse impacts on any designated landscapes.

6.51 In conclusion, the design of the development has been based on a thorough understanding of the site and its immediate and wider context. The loss of trees and woodland is unavoidable in this location, but the development protects the Ancient Woodland, and provides for landscape enhancements

5 The study area includes the NW Zone of the airport and the landscape to the west, south west and north west, extending approximately 3km, from the site to the ridgeline of Norwood Hill, Stan Hill and Russ Hill in Mole Valley.


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and replacement tree planting in accordance with the requirements of Policy CH6. The development also complies with Crawley Local Plan Policies SD1 and CH3.

v) Biodiversity

6.52 In planning the development a number of ecology surveys were carried out.

6.53 A baseline ecological survey using Phase 1 habitat methodology was conducted to identify the presence or potential presence of statutory protected species or species of nature conservation interest and to recommend further ecological surveys. The recommendations lead to further reptile and bat surveys being carried out in 2016 and 2017.

6.54 The reptile survey revealed presence of a low population of grass snake within the development site.

6.55 The bat surveys revealed the presence of bats foraging on and near the site, and some evidence of bat roosts within the trees on the site.

6.56 In order to address the potential effects of the proposed scheme on ecological interests a suite of mitigation and enhancement measures have been proposed. These are set out in the Landscape and Ecological Mitigation and Enhancement Strategy.

6.57 There will be a requirement for a European Protected Species Licence from Natural England before development can begin to mitigate impacts on bats. This is likely to establish timing restrictions to felling the trees with bat potential to between March/April or September/October and a requirement for emergence surveys (or re-entry dawn surveys) immediately prior to the tree felling. If a bat is found in a tree roost during the felling, works would stop and Natural England contacted for advice.

6.58 The recommendations of the ecologist as set out in the bat survey report. 20 Bat boxes will be erected on suitable mature trees within the woodlands and hedgerows to the west of the River Mole to compensate for the loss of roosts. The provision of bat boxes will be undertake in collaboration with members of the Surrey Bat Group, who monitor bat populations in the area, including on Gatwick Airport’s land. The provision of these additional roost boxes would be an extension to this ongoing work. There would, therefore, be a no net loss in the bat population of the NWZ as a result of the proposed scheme.

6.59 In order to address the sensitivity of Brockley Wood with respect to the bats it supports, additional tree planting is proposed in the 20m wide buffer along the woodland’s eastern boundary. This planting will help to reduce light spill from neighbouring operational areas of the airport, including activities associated with the hangar. It is proposed that the buffer planting will be dominated by a


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variety of willow species and some alder, with an understorey of shrubs. Although, for aerodrome safeguarding reasons, the mix will be relatively species poor, willows are typically fast growing species, which will help to provide the required screening effects more quickly than may otherwise be the case. Moreover, it is intended that the combination of tree and shrub understorey planting will provide an irregular woodland edge that has potential to provide additional foraging habitat.

6.60 It is anticipated that once constructed, the hangar will significantly reduce current levels of light spill currently experienced by parts of the North West Zone. Nevertheless, lighting will be associated with the exterior of the hangar, once operational. Details of the lighting design will be informed by the Bat Conservation Trust’s best practice guidance on lighting design.

6.61 The woodland to be lost will support birds and any tree felling will be carried out as far as possible to avoid the bird breeding season. Any felling within this period would be subject to ecological supervision with checks made for breeding birds. Any breeding birds present would be left undisturbed until such time as the chicks have fledged.

6.62 Grass snakes and harvest mice will be captured and relocated to nearby sites that have been identified as suitable for translocation.

6.63 In addition, as described in Section 4, the development leads to the loss of a remnant section of the Man’s Brook. It had originally been proposed to divert this around the site, but due to the sensitivity of creating new open water bodies in the vicinity of the airport’s flight path which risks attracting birds, it has instead been agreed with the Environment Agency and Crawley that an appropriate mitigation would be to enhance a number of other ponds on the east side of the airport. The pond enhancements will contribute towards the airport’s continuing biodiversity enhancement strategy in one of Crawley’s designated Biodiversity Opportunity Areas.

6.64 Additional bird nesting boxes will also be installed in this Biodiversity Opportunity Area.

6.65 For invertebrate enhancement new bunds will be created along the western side of the realigned Larkins Road and sown with a grass seed mix containing some flowering plants. The bunds provide new nesting opportunities for solitary bees and wasps present within the area. Further sites in the land east of the railway line will also be identified for enhancing invertebrate diversity.

6.66 The ecological interests of the site are well understood. The ancient woodland is protected and enhanced with a planted buffer zone, and the LEMES prescribes the measures that will be taken to avoid harm to protected species


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and provide replacement habitat, as well as provision for future surveys and monitoring of species populations.

6.67 The development complies with Crawley Local Plan Policy ENV2 and national policy for the protection and enhancement of nature conservation interests.

vi) Sustainable Design

6.68 A Design and Access and Sustainability Statement summarises the design considerations that have influenced the development and explains how the design responds to the sustainable design policies in the NPPF, the Crawley Local Plan, and the Sustainable Design and Construction SPD.

6.69 The DAS also includes a BREEAM pre-assessment. This confirms a predicted assessment of “Excellent” in accordance with Local Plan Policy ENV6.

Energy

6.70 In developing the environmental design a number of renewable energy solutions were considered. In addition to their viability within the development any such solution must to comply with the aviation safeguarding environment. As such the likes of wind turbines were discarded at an early stage.

6.71 The following technologies have, however, been adopted:

- A substantial array of photovoltaic panels is proposed for the lower bay roof of the hangar.

- Ground source heat pumps for office heating and cooling.

6.72 In addition, energy usage requirements are reduced through lines of translucent roof lights interspersed with the PV array on the lower bay roof of the hangar and diffused glazing to the vertical sections of the hangar doors.

6.73 Heating of the hangar will be through radiant heaters rather than space heating.

6.74 In the office and workshop environments ultra-low energy LED lighting units with sensitivity settings will be used as standard, natural light to internal spaces and appliances, equipment and systems with high energy efficiency ratings will be used.

Water Resources

6.75 Water efficient facilities and appliances will be provided throughout the building in accordance with latest water efficiency and fitting regulations.

6.76 In addition a rainwater harvesting tank will collect and store rainwater for re-use within the building, also helping to minimise water consumption.


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6.77 Of the site layout options considered for the development the proposed layout provides the smallest areas of concrete hardstanding, minimising the overall development footprint and incorporating grass areas into the landscape scheme to attenuate surface water run-off.

Waste, Services and Utilities

6.78 The DAS explains how waste will be managed within the facility, including a waste recycling store alongside general waste collection.

6.79 Other potentially hazardous waste streams, such as oils and spent fluids, will be stored in a bunded, ventilated store in the western service yard prior to removal and disposal to a specialised licensed contractor.

6.80 All ventilation, air handling equipment and plant is integral to the building design and will not affect residential amenity by reason of noise.

Lighting

6.81 The hangar lighting scheme will meet the specific requirements of the operational areas around each elevation of the building, however, great care will be taken to minimise light spill to Brockley Wood

6.82 Exterior Lighting, including floodlights to the front of the hangar to light the apron, exterior safety lighting to the ancillary areas to the north, south and west and lighting to the realigned Larkins Road will be full cut off directional lighting, designed in accordance with aerodrome safeguarding requirements and to minimise visual and ecological impact.

6.83 The Hangar design consciously avoids windows facing west on the highest elevation of the hangar, where they could be visible at night above the tree line of Brockley Wood.

6.84 It is proposed that details of the lighting design would be a condition of the planning permission.

Signage

6.85 The hangar will an integrated signage palate comprising a hierarchy of signs which meets the operational needs of the site. These range from a main Boeing sign on the front and side elevations to low level directional signage above doors and at the entrance to the reception area.

District Energy

6.86 Crawley Local Plan Policy ENV7 requires consideration of district energy networks for all major developments.


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6.87 Gatwick is not identified as a priority area for the delivery of District Energy Networks but consideration has been given to the development developing its own system.

6.88 The major heating energy demand for the building is hangar space, and it is proposed to adopt an energy efficient gas fired radiant tube heating system for the hangar. This is considered to be best industry practice for hangars. It requires a mains gas supply, which will be extended from the existing gas network serving the airport. It would not be feasible to create a new system to supply energy to surrounding buildings.

6.89 Other systems such as office heating and cooling are not of a scale to warrant creating local networks but they will be served by ground source heat pump systems which will minimise the carbon impact of the building.

6.90 Furthermore the heating system described above for the hangar does not lend itself to a site wide energy system. Similarly the office environmental control systems are not of a scale to warrant creating to a community energy system.

6.91 Whilst it may be possible to connect the plant serving the office and workshop area to a future network with minimal disruption, should one become available, the ground source heat pump system proposed is considered to have minimal environmental impact, and is considered to be a preferable solution from a carbon perspective.

Conclusion on Sustainable Design

6.92 The design and layout of the development has been carefully considered. The proposed development will achieve the BREEAM rating of “excellent required by Local Plan Policy ENV6 as well as a range of other sustainability objectives in relation to energy and carbon efficiency, water resources and waste management in Policies ENV6 and ENV9 as well as Policy CH3. Consideration has been given to Policy ENV7 and there are sound reasons for development developing its own energy systems.

vii) Traffic and Transport

6.93 The Transport Statement considers trip generation and sustainable travel considerations.

Trip Generation

6.94 The hangar will be in use 24 hours a day 7 days a week.

6.95 The 134 employees and service related traffic will generate additional trips and some of these will be at peak times. But after allowing for shift patterns and use of public transport, the level of trips generally and in the peak hours is


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predicted to add approximately 1% of current traffic in the a.m. peak hour and 0.3% in the p.m. peak hour.

6.96 The level of additional trip generation will overall therefore be very small compared with levels of traffic on the surrounding road network and will not materially impact on network conditions.

Car Parking

6.97 Staff parking will be met in GAL managed staff car parks, which provide wider provision for airport employee car parking.

Public Transport and Sustainable Travel

6.98 The prevalence of high quality public transport services will increase the opportunity for employees to be able to access the development by public transport services.

6.99 The absence of on-site provision for employee parking will further encourage use of sustainable modes.

6.100 The proposed development is acceptable in highway terms, improves road and pedestrian safety and overall complies with policy IN3 of the Local Plan.

viii) Flood Risk and Surface Water

6.101 The existing site is with Flood Zone 3, which is defined as land assessed as having a 1 in 100 or greater annual probability of river flooding.

6.102 A Flood Risk Assessment (FRA) and Surface Water Drainage Strategy have been prepared in support of the planning application and following discussions with EA and CBC. The FRA has been informed by detailed local modelling.

6.103 There have been previous pluvial (rain-related) flooding incidents at the airport and a pluvial flood model has been used to assess what impacts the proposed development would have on the nature of such flooding.

6.104 Within Flood Zone 3 national policy identifies appropriate uses as being “water compatible” or “less vulnerable” uses.

6.105 Development is classified as a “less vulnerable” use and is therefore acceptable in Flood Zone 3 provided the ‘sequential test’ is passed and the development would not increase flood risk.

6.106 In respect of the sequential test, Gatwick Airport is constrained for development within the present airport boundary, and there are no other suitable sites for this development of lower flood risk which would accommodate the building without the requirement to relocate other essential airport infrastructure elsewhere. The development therefore satisfies the sequential test


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6.107 Flood risk modelling shows that the development will lead to the loss of a small area of floodplain, displacing this water into the remainder of the North West Zone development Area. This loss of floodplain volume does not give rise to new flooding downstream of it or exacerbate existing flooding.

Drainage Strategy

6.108 The surface water drainage system for the development will connect into the Airport’s existing surface water drainage network. Details are set out in the Drainage Strategy.

6.109 Surface water from areas of the development with a very low risk of contamination (primarily the roof area) will be discharged via a sustainable drainage system to the River Mole. Such discharges will be controlled to greenfield runoff rates using sustainable drainage features of attenuation and flow control.

6.110 Surface water draining parts of the site with a high risk of contamination will be collected in an artificial drainage system, attenuated, and then discharged into the M Pond drainage system. M Pond was designed to control the discharge from the entire North West Zone development to greenfield runoff rates for the 1, 30, and 100yr events, including an allowance for climate change. Subject to the discharge being via the M Pond drainage system, there is therefore is no increase in planned downstream flood risk.

6.111 Airport Safeguarding requirements limit the extent to which SuDS can be employed on the site, however, the development incorporates rainwater harvesting which will reduce surface water run-off.

6.112 The development complies with national policy and guidance on flood risk and Policy ENV8 of the Local Plan.

ix) Air Quality

6.113 An Air Quality Statement has been prepared.

6.114 The assessment considers construction effects (notably emissions of dust) and operational effects arising from increases in road traffic and aircraft maintenance activities at the site (NO2).

6.115 It is considered that the risk of dust affecting nearby receptors during construction is low and can be mitigated through appropriate measures in the Construction Environmental Management Plan.

6.116 The light nature of the maintenance activities to be undertaken at the site and the small changes to road traffic levels, as reported in the Transport Statement, will not lead to any material effect on air quality.

6.117 The development complies with Local Plan Policy ENV12.


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x) Heritage

6.118 Previous archaeological field evaluations and recording have been carried out across large parts of the NWZ of Gatwick Airport, including within the boundary of the development site, in connection with previous developments dating back to 2001.

6.119 An archaeological assessment has been prepared by Oxford Archaeology to identify the remaining archaeological potential of the development site. Based upon the results of the evaluation the site is considered to have a low potential to contain significant archaeological remains.

6.120 Consultation has been undertaken with the archaeological officer at Surrey County Council (who currently advises Crawley Borough Council) on the need for further archaeological work within the site. It was agreed that the site is unlikely to contain significant archaeological deposits. As a result, further evaluation work was not recommended, and a full programme of archaeological mitigation was not deemed necessary. It has, however, been agreed that a programme of archaeological monitoring and recording (an archaeological watching brief) and further environmental sampling and analysis should be carried out during construction. This work can be secured as a condition of any planning permission and will ensure any impacts are successfully mitigated.

6.121 The proposed development complies with Policy CH12 of the Local Plan.

xi) Aerodrome Safeguarding

6.122 The development has been subject to pre-application consultation with Gatwick Aerodrome Safeguarding and specialist bird strike advisors and as well as NATS-on route (NERL) and Air Navigation Solutions (ANS) to consider radar.

6.123 Discussions with Gatwick Aerodrome Safeguarding have also informed the design and species mix for the proposed replacement planting scheme in the 20m Brockley Wood buffer, and the additional planting proposed on the landside bund.

6.124 Due to concerns about open water being a bird attractant it was agreed with Aerodrome Safeguarding and the Environment Agency that compensation for the loss of the part of the Man’s Brook water body affected by the development, can best and most safely be addressed through pond enhancement works in the Biodiversity Opportunity Area on land to the east of the railway line.

6.125 The proposed planting on the landside bund and the enhancement works in the Biodiversity Opportunity Area are proposed to be covered in a S.106 agreement.


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xii) Ground Conditions

6.126 A ground investigation has been undertaken and the geo-environmental report presents a summary of the geo-environmental conditions encountered during the site investigation, a brief summary of desk based environmental information and a high level contaminated land risk assessment and waste classification. The extensive Ground Investigation Factual Report can be provided upon request.

6.127 It reports that the proposed redevelopment has the potential to generate contamination pathways to potential receptors with some moderate and low risks. It recommends that during construction works a watching brief should be undertaken to identify the presence of any potential contamination not detected by the site investigation and for remediation.

6.128 This can be made a condition of any planning permission.

6.129 The proposed development complies with Policy ENV10 of the Local Plan.

xiii) Construction

6.130 As noted in Section 3, the construction of the development would take about 18 months to complete and a temporary site compound would be set up on the site.

6.131 A Construction Environmental Management Plan (CEMP) would be prepared setting out how construction impacts will be controlled and minimised and how the works will be managed in relation to on site biodiversity interests.

6.132 With such a plan in place, and based on experience of other projects carried out at the airport there is no reason to consider that the temporary effects of construction works, would give rise to any unacceptable impacts.


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7 Conclusions

7.1 Section 38(6) of the Planning and Compulsory Purchase Act requires planning applications to be determined in accordance with the development plan unless material considerations indicate otherwise.

7.2 The Development Plan comprises the Crawley Local Plan 2015. Other material considerations include the NPPF and associated planning practice guidance, the Aviation Policy Framework, Crawley Supplementary Planning Guidance and the Gatwick Airport Masterplan.

7.3 The proposed development occupies a site within the airport boundary that has for a long time been identified for aircraft maintenance development. It is a development that will support the safe and efficient operation of the airport.

7.4 It will also bring to Gatwick a prestigious aviation company that will offer significant employment, training and apprenticeship opportunities and associated economic benefits to Crawley and Gatwick Diamond area.

7.5 The development has been carefully designed, taking into the account the views of key stakeholders.

7.6 The stepped form and choice of materials for the main hangar building is designed to reduce its visual impact, and supplementary planting on the landscaped bund will further reduce visual impact over time. The design accords with CBC policies on sustainable design and construction, incorporating for example a large scale roof mounted solar PV array, ground source heat pump rainwater harvesting and other measures designed to enhance the development’s sustainable performance and achieve a BREEAM rating of ‘excellent’.

7.7 Whilst the development will lead to the loss of trees and the remnants of former woodland, it provides for the long term protection of the designated Brockley Wood Ancient Woodland and provides for a woodland buffer to the woodland with replacement tree planting in accordance with the standards required by the Local Plan policy.

7.8 The site does not have any ecological designation but wildlife interests on the site, including breeding birds, bats and grass snake, are well understood. Impacts on protected species can be mitigated through the way the construction is managed. The Landscape and Ecological Mitigation and Enhancement Strategy provides for a suite of measures that will protect biodiversity and ensure successful relocation. It also provide for wider enhancements, including in the Biodiversity Opportunity Area to the east of Gatwick.


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7.9 The noise assessment demonstrates that even under the worst case assumptions the proposed development would not expose the local community to unacceptable noise levels from aircraft operations or maintenance activities.

7.10 Impacts on water resources, flood risk, air quality, transport and heritage have been considered. Studies demonstrate no unacceptable impacts and compliance with Local Plan policies, the NPPF and other guidance on these matters.

7.11 Construction impacts can also be adequately controlled by suitable planning conditions.

7.12 The development would comply with the Development Plan as a whole as well as with policies and guidance in the NPPF and SPDs.

7.13 The proposal is sustainable development. Accordingly planning permission should be granted.


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8 Appendices


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Appendix 1: Matters for Planning Conditions

Matters to be covered by Planning Conditions

Standard 3 year timescale for commencement of development

The development to be carried out in accordance with the approved drawings (drawings to be listed)

The development to be carried out in accordance with the LEMES

Approval of details of the replacement sub station

Approval of details of lighting scheme for the site

Approval of a Bird Hazard Management Plan for the site

Other Radar / Safeguarding conditions as required by NATS

Tree protection measures (for trees to be retained)

The development to be carried out in accordance with the approved drainage strategy

Approval of a Construction Environmental Management Plan

Requirement for Archaeological Watching Brief Investigation

Requirement for Site investigation and provisions to agree of any remediation measures to ensure any risks identified are eliminated.


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Appendix 2: Draft Section 106 Agreement

X:\Legal\Jonathan Kalman\GAL\GAL 1450 - Boeing Hangar land lease\S106\Draft S.106 1.docx 1

DATED 2017

GATWICK AIRPORT LIMITED

and

BOEING COMMERCIAL AVIATION SERVICES EUROPE LIMITED

and

DEUTSCHE TRUSTEE COMPANY LIMITED

to

CRAWLEY BOROUGH COUNCIL

UNILATERAL UNDERTAKING

Town and Country Planning Act 1990

Section 106

Relating to land at Gatwick Airport


This Deed of Agreement is made on the day of 2017

between:

(1) GATWICK AIRPORT LIMITED (Company Registration Number 1991018) whose

registered address is at 5th Floor, Destinations Place, Gatwick Airport, Gatwick,

West Sussex RH6 0NP, BN44 3LR (“the Owner”);

(2) BOEING COMMERCIAL AVIATION SERVICES EUROPE LIMITED (Company

Registration number 08186759) whose registered address is at 25 Victoria Street,

London SW1H 0EX (“the Developer”); and

(3) DEUTSCHE TRUSTEE COMPANY LIMITED (Company Registration number

0338230) whose registered address is at Winchester House, 1 Great Winchester

Street, London EC2N 2DB (“the Mortgagee);

TO

(4) CRAWLEY BOROUGH COUNCIL of Town Hall, The Boulevard, Crawley, West

Sussex RH10 1UZ (“the Council”)

INTRODUCTION

1. The Council is the local planning authority for the purposes of the Act for the area

in which the Site is situated and is the local authority by whom the obligations in

this Deed are enforceable.

2. The Owner is the freehold owner of the Site registered at HM Land Registry with

title absolute under title number[s] [ ].

3. The Developer jointly with the Owner has applied to the Council for planning

permission which the Council is minded to grant subject to prior completion of

this Agreement.

4. The Mortgagee has the benefit of a charge over the Site dated 15 January 2011.

5. On 20 August 2008 the Council formally adopted SPD1 which sets out the extent

of the planning obligations which may be sought in respect of proposals for new

development in Crawley Borough.

6. The Owner and the Developer have agreed to enter into this Deed to secure the

Works set out in Schedule 1 to this Deed in accordance with the provisions of

SPD1.


7. The Owner and the Developer and the Mortgagee have agreed to enter into this

Deed with the intention that subject to the provisions of clause 4 hereof the

obligations contained in this Deed may be enforced by the Council against the

Owner and the Developer and the Mortgagee in respect of the Site and their

respective successors in title.

8. The Owner and the Developer and the Mortgagee agree that the obligations in

this Deed are necessary to make the Development acceptable in planning terms,

are fairly and reasonably related in scale and kind to the Development and

directly related to the Development.

OPERATIVE PART

1. DEFINITIONS

For the purposes of this Deed the following expressions shall have the following

meanings;

“The Act” means the Town and Country Planning Act 1990

“The Application” means the application allocated reference number [

] for the construction of a hangar, apron and associated

taxiway and infrastructure.

“Commencement of

Development” means the carrying out on the Site of a material operation as

defined in Section 56(4) of the Act exclusively referable to

and comprised in the Development but excluding any

operations relating to works of investigations in respect of

land contamination or remedial action in respect thereof

enabling works site clearance demolition works ground

investigations archaeological investigations and digs

exploratory boreholes operations permitted by the Town and

Country Planning (General Permitted Development) Order

1995 the erection of hoardings and fencing temporary

diversion of services, signage and roadways (including the

formation of temporary construction accesses) preliminary

landscaping before construction activity occurs on the Site

and any works matters and operations to enable any of the

foregoing to take place and “Commence Development” and


cognate expressions shall be interpreted in accordance with

this definition

“Development” means the development permitted by the Planning

Permission

“Ecological Works” means the ecological works to be carried out as detailed in

Schedule Two consisting of:

pond enhancement works, installing bird nesting

boxes and enhancing habitat for invertebrates (the

“Ecological Enhancement Works”);

additional landscaped bund planting works (the

“Additional Planting Works”);

maintenance of additional landscaped bund planting

works in accordance with the Maintenance Plan

at the sites shown on the Plans at Gatwick Airport

“Maintenance Plan” means the plan attached at Schedule Two

“Notice of Commencement” means a written notice served on the Council by the Owner

and/or the Developer of its intention to Commence the

Development

“Notice of Commencement

of the Ecological Works” means a written notice served on the Council by the Owner

which certifies the intended date on which the Ecological

Works are to be commenced

“Notice of Completion” means written notice served on the Council by the Owner

which certifies the date on which the Pond Enhancement

Works and the Additional Planting Works are completed

“Occupation” and

“Occupied” means occupation for the purposes permitted by the

Planning Permission but not including occupation by

personnel engaged in construction fitting out marketing or

decoration or staff training


“Plans” the plans showing the sites on which the Ecological Works

will be carried out attached to this Deed at Schedule Three

“Planning Permission” the permission granted in accordance with the Application in

the form or substantially in the form of the draft attached to

this Deed at Schedule Four

“Site” means the land against which this Deed may be enforced as

shown edged red on the Plan being part of the land

registered at Land Registry under title number[s] [

]

“Site Plan” means the plan showing the Site attached to this Deed at

Schedule Three

“SPD1” means the Supplementary Planning Document No 1 on

Planning Obligations and S106 Agreements adopted by the

Council on [ ] 2015

2 CONSTRUCTION OF DEED

2.1 Where in this Deed reference is made to any clause, paragraph or schedule or

recital such reference (unless the context otherwise requires) is a reference to a

clause, paragraph or schedule or recital in this Deed.

2.2 Words importing the singular meaning where the context so admits include the

plural meaning and vice versa.

2.3 Words of the masculine gender include the feminine and neuter genders and

words denoting actual persons include companies, corporations and firms and all

such words shall be construed interchangeably in that manner.

2.4 Wherever there is more than one person named as a party and where more than

one party undertakes an obligation all their obligations can be enforced against all

of them jointly and severally unless there is an express provision otherwise.

2.5 Any reference to an Act of Parliament shall include any modification, extension or

re-enactment of that Act for the time being in force and shall include all

instruments, orders, plans regulations, permissions and directions for the time

being made, issued or given under that Act or deriving validity from it.


2.6 References to any party to this Deed shall include the successors in title to that

party and to any person deriving title through or under that party and in the case

of the Council the successor to its statutory functions.

2.7 The headings and contents list are for reference only and shall not affect its

construction.

2.8 References to the Site include any part of it.

2.9 References to “including” mean “including, without limitation,”

2.10 Any covenant not to do any act or thing includes a covenant not to permit or

allow the doing of that act or thing.

3 LEGAL BASIS

3.1 This Deed is made pursuant to Section 106 of the Act and Section 111 of the

Local Government Act 1972 and Section 1 of the Localism Act 2011 and all other

enabling powers.

3.2 The covenants, restrictions and requirements imposed upon the Owner and the

Developer under this Deed create planning obligations pursuant to Section 106 of

the Act and are enforceable by the Council as local planning authority against the

Owner and its successors in title and/or the Developer.

3.3 To the extent that any of the obligations contained in this Deed are not planning

obligations within the meaning of the Act, they are entered into pursuant to the

powers contained in section 111 of the Local Government Act 1972, section 1 of

the Localism Act 2011 and all other enabling powers.

3.4 This Deed (with the exception of clause 4) comes into effect upon the grant by

the Council of the Planning Permission.

3.5 This Deed shall bind the parties hereto and the Owner’s and the Developer’s and

the Mortgagee’s successors in title to each and every part of the Site and assigns.

3.6 This Deed shall be registered as a local land charge by the Council.

3.7 Clause [ ] is not made pursuant to section 106 of the Act but pursuant to the

Council’s power under section 1 of the Localism Act 2011 and any other enabling

powers.


4 CONDITIONALITY

The obligations in this Deed SAVE FOR the provisions of Clauses 6, 7, 8, 9, 10, 12

and 13 which shall come into effect immediately upon completion of this Deed are

subject to and conditional upon:

(i) grant of the Planning Permission; and

(ii) if the Planning Application is appealed under section 78 of the Act or

called in under section 77 of the Act a finding by the inspector

appointed by the Secretary of State in respect of each obligation in

this Deed, that it complies with Regulation 122 of the Community

Infrastructure Regulations 2010 and that the inspector would not have

granted the Planning Permission if the obligation had not been

offered.

4.2 If the Council adopts a Charging Schedule for the purposes of introducing the

Community Infrastructure Levy, prior to Planning Permission being granted, the

Owner shall not be bound by any obligation in this Deed that relates to an item or

project included on the Council’s regulation 123 list of infrastructure

5 THE OWNER’S AND DEVELOPER’S COVENANTS

The Owner and the Developer each covenant with the Council as set out under

their respective headings in the First Schedule.

6 PAYMENT OF THE COUNCIL’S COSTS

On the date of this Deed the Developer shall pay to the Council the reasonable

legal costs of the Council incurred in the negotiation, preparation, execution and

completion of this Deed and the sum of £500 (five hundred pounds) towards the

Council’s costs of administration, monitoring and management pursuant to

paragraph 3.11 of SPD1.

7 NOTICES

All notices consents and approvals required to be served on the Council shall be

sent to the Head of Planning and Environmental Services at the above address

and all those required to be served on the Owner and the Developer and the

Mortgagee shall be sent to the respective addresses aforementioned.

8 INVALIDITY


Insofar as any clause or clauses of this Deed are found (for whatever reason) to

be invalid illegal or unenforceable then such invalidity illegality or unenforceability

shall not affect the validity or enforceability of the remaining provisions of this

Deed.

9 TERMINATION OF THIS DEED

This Deed shall with the exception of clause 6 cease to have effect (insofar only

as it has not already been complied with) if the Planning Permission shall be

quashed, revoked or otherwise withdrawn or (without the consent of the Owner)

it is modified by any statutory procedure or expires prior to the Commencement

of the Development.

10 MISCELLANEOUS

10.1 No provisions of this Deed shall be enforceable under the Contracts (Rights of

Third Parties) Act 1999

10.2 Where the agreement, approval, consent or expression of satisfaction is required

by the Owner from the Council under the terms of this Deed such agreement,

approval or consent or expression of satisfaction shall not be unreasonably

withheld or delayed.

10.3 No person shall be liable for any breach of any of the planning obligations or

other provisions of this Deed after it shall have parted with its entire interest in

the Site but without prejudice to liability for any subsisting breach arising prior to

parting with such interest.

10.4 Nothing in this Deed shall prohibit or limit the right to develop any part of the Site

in accordance with a planning permission (other than the Planning Permission)

granted (whether or not on appeal) after the date of this Deed.

10.5 Nothing contained or implied in this Deed shall prejudice or affect the rights

discretions powers duties and obligations of the Council under all statutes by-laws

statutory instruments orders and regulations in the exercise of their functions.

11 WAIVER

No waiver (whether expressed or implied) by the Council or Owner of any breach

or default in performing or observing any of the covenants terms or conditions of

this Deed shall constitute a continuing waiver and no such waiver shall prevent

the Council or Owner or Developer from enforcing any of the relevant terms or

conditions or for acting upon any subsequent breach or default.


12 JURISDICTION

This Deed is governed by and interpreted in accordance with the laws of England

and Wales and the parties submit to the exclusive jurisdiction of the courts of

England.

13 DELIVERY

The provisions of this Deed (other than this clause which shall be of immediate

effect) shall be of no effect until this Deed has been dated.

14 CONSENTS

The Owner hereby warrants and confirms that they have obtained all other

necessary permissions and consents required from any covenantee or other

person before entering into this Deed.

15 CHANGE IN OWNERSHIP

15.1 The Owner warrants that no person other than the Owner has any legal or

equitable interest in the Site.

15.2 The Owner agrees with the Council and the County Council to give the Council

and the County Council written notice of any conveyance, transfer, lease,

assignment, mortgage or other disposition entered into in respect of all or any

part of its interest in the Site within ten days of such occurrence before all the

obligations under this Deed have been discharged and such notice to give details

of the full name and registered office (if a company or usual address if not) of the

person or company to whom the disposition was made and the nature and extent

of the interest disposed of.

16 VARIATION

The terms of this Deed shall be capable of being varied by a supplemental

agreement executed by the parties.

17 MORTGAGEE’S CONSENT

The Mortgagee acknowledges and declares that this Deed has been entered into

by the Owner with its consent and that the Site shall be bound by the obligations

contained in this Deed and that the security of the mortgage over the Site shall

take effect subject to this Deed PROVIDED THAT the Mortgagee shall otherwise

have no obligations and shall incur no liability under this Deed unless and until

such time (if any) as it takes possession of the Site as mortgagee in possession in


which case it will be bound by the obligations as if it were a person deriving title

from the Owner but only to the extent that the obligations falling to the Owner at

the date the Mortgagee exercises such powers are outstanding and continue to

bind the land over which the Mortgagee has exercised its powers.


SCHEDULE ONE

1 Covenants by the Owner

1.1 To serve the Notice of Commencement of the Ecological Enhancement

Works and the Additional Planting Works on the Council prior to the

Commencement of those works.

1.2 Not to Commence the Ecological Enhancement Works and the Additional

Planting Works unless and until Notice of Commencement of such works

has been served on the Council.

1.3 To Commence the Ecological Enhancement Works and the Additional

Planting Works within 12 months of the Commencement of the

Development.

1.4 To complete the Ecological Enhancement Works and the Additional

Planting Works no later than two years after the occupation of the

development.

1.5 To provide Notice to the Council on completion of the Ecological

Enhancement Works and the Additional Planting Works.

2 Covenants of the Developer

The Developer hereby covenants with the Council as follows:

2.1 To serve the Notice of Commencement on the Council prior to the

Commencement of the Development

2.2 Not to Commence Development unless and until they have served the

Notice of Commencement on the Council.

2.3 To serve the Notice of Occupation on the Council prior to the first

Occupation of the Development.

2.4 No to Occupy or permit the Occupation of the Development unless and

until they have served the Notice of Occupation on the Council.


SCHEDULE TWO

Ecological Works

Ecological Enhancement Works [ ]

Additional Planting Works [ ]

Maintenance Plan

[ ]


SCHEDULE THREE

Plans


SCHEDULE FOUR

Draft Planning Permission


IN WITNESS whereof the parties hereto have executed this Deed the day and year first

before written

THE COMMON SEAL OF )

CRAWLEY BOROUGH COUNCIL )

was affixed to this Deed in )

the presence of:- )

Proper Officer

SIGNED AS A DEED BY )

GATWICK AIRPORT LIMITED )

in the presence of:- )


BOEING COMMERCIAL AVIATION )

SERVICES EUROPE LIMITED )




DEUTSCHE TRUSTEE COMPANY )

LIMITED )
