Application Number : S/2017/0638/MAF Application expiry date : 2 June 2017

Parish : Evenley Croughton

Case Officer : Wayne Campbell Applicant : Ministry of Defence Location : - RAF Croughton Croughton Brackley, Northamptonshire. NN13 5XP

Description : - New Elementary, Middle and High School with playing fields to replace the existing school.

RECOMMENDATION – DELEGATE TO THE HEAD OF DEVELOPMENT MANAGEMENT TO GRANT PERMISSION, SUBJECT TO THE CONDITIONS SET OUT AT THE END OF THIS REPORT (AND ANY AMENDMENTS TO THOSE CONDITIONS AS DEEMED NECESSARY) S/2017/0638/MAF WARD : Little Brook WARD MEMBER : Cllr John Townsend REASON FOR REFERRAL TO COMMITTEE:

Major application;

1. APPLICATION SITE

1.1 RAF Croughton comprises a former airbase which is currently used as a communications facility. Although the site is owned by the MOD, it is currently occupied by the United States Air Force (USAF).

1.2 The base is located approximately 1.2km east / south-east of the village of Croughton and is adjacent to the north-bound carriage way of the A43 which forms the south-eastern boundary of the site. The northern part of the base contains the vast majority of the existing buildings. These have a wide range of uses, including accommodation, amenity, offices, workshops and storage, with a mixture of single, two storey and three storey heights.

1.3 Although the main perimeter fence to the application site is readily visible from outside the site, there is some screening present in the form of scattered trees and hedging which separate the site from the A43 and areas of open countryside to the south and west.

2. CONSTRAINTS

2.1 Outside village confines;

2.2 Potential archaeological asset – RAF Croughton - Modern military site;

2.3 Potential wildlife site;

2.4 Within 2km buffer zone of local wildlife sites: The Moors; Old Astwick Village Moat;

Slade Covert; Croughton Spinney; and Croughton Spring Copse.

3. PROPOSAL

3.1 This application seeks planning permission for the construction of a new Elementary, Middle and High (EMH) School at RAF Croughton to cater for an increasing base establishment. The proposed development contains a two storey school building with an adjoining single storey energy centre. The proposed school occupancy will be 468 students for all age ranges supported by 60 full time staff, excluding food service which is an outsourced service managed by the Army and Air Force Exchange Service. The provision of the school will allow for the existing Child Development Centre (primary school) to be refurbished as office accommodation and three poorly insulated and outdated office buildings on the base to be demolished.

3.2 The position of the building within the school site area is slightly to the east of the centre and to the west of the three large, geodetic domes on the site and the immediate south of a large warehouse building. The main access to the EMH School will be off the existing base perimeter road to the north leading to an open car parking area providing 130 spaces, a separate bus drop-off area with spaces for 12 buses along with an area allocated for cycle parking for 20 cycles all of which are allocated in an area to the north of the EMH School. The area of school site to the west of the main building will be maintained as sports facilities in the form of an enclosed 4 court MUGA, a 400m running track around a football / American football pitch, a replacement softball pitch and two baseball pitches.

3.3 In the main, buildings will be clad in grey cladding with section of light coloured brick for them to fit in with most the existing development at RAF Croughton.

3.4 The applicant has advised that some residential accommodation for the transferring personnel will be provided by the USAF either within the base or within existing under-utilised off-base housing at Caversfield, near Bicester, approximately 11 km south of the base. It is accepted however that in addition to this a number of dwellings could be required within surrounding communities but the exact number has yet to be determined and could be met through a mixture of on or off-base accommodation and by the applicant or provided by private developers. In terms of future dwellings required, these will be provided by the open market. This future requirement does not form part of this planning application nor does it form part of the planning assessment undertaken within this application.

4. RELEVANT PLANNING HISTORY

4.1 S/2016/0791/MAF - approved at the Planning Committee 30 June 2016 for the erection of operational buildings and associated development including access road, car parking area, external plant, hard and soft landscaping, hardstanding areas and infiltration basin.

4.2 S/2016/1645/MAF – approval at the Planning Committee 15 December 2016 for hybrid application for full planning permission for administration building, car park, screening bund, landscaping and ancillary developments/works; warehouse, recycling bin storage centre and other associated works (including demolition) and

landscaping. Outline planning application seeking approval with all matters reserved for dormitory, fitness centre, commissary (shop), substation, extensions to existing post office and child development centre and other associated development (including demolition).

5. PRE-APPLICATION ADVICE

5.1 Pre-application advice provided through a series of discussions and meeting regarding the submission details and type of development proposed.

6. KEY ISSUES

6.1 The main issues to consider are:

the principle of development

visual impact on the area and the character of the open countryside;

impact upon neighbour amenity;

impact historic assets;

highway implications;

flood risk; and

impact upon biodiversity and protected species.

7. RELEVANT PLANNING POLICIES

7.1 Planning law requires that applications for planning permission must be determined in accordance with the Development Plan, unless material considerations indicate otherwise.

The Development Plan

7.2 SOUTH NORTHAMPTONSHIRE LOCAL PLAN (SNLP): G3, EV1, EV2, and EV24.

7.3 WEST NORTHAMPTONSHIRE JOINT CORE STRATEGY (JCS): Policies SA, S1, S2, S7, S8, C2, E1, BN2, and BN5

Material Considerations

7.4 NATIONAL PLANNING POLICY FRAMEWORK (NPPF): Section 7 ‘Requiring good design’, Section 10 ‘Meeting the challenge of climate change, flooding and coastal change’ and Section 11 ‘Conserving and enhancing the natural environment’

7.5 PLANNING PRACTICE GUIDANCE (PPG): Sections covering Crown Development; and Design.

7.6 COUNCIL CORPORATE PRIORITIES: The Council’s 2016/17 Business Plan sets out a five year business strategy which sets out the long-term strategic priorities for the District. These are to (1) Serve the Residents & Business; (2) Protect the District and (3) Grow the District.

The corporate priority of most significance to the determination of planning

applications and appeals is to “Protect the District”. It seeks to do this via the key objectives of; (1) ensuring the character of the district is preserved; (2) protect the built heritage; (3) preserve the environmental quality of the District; (4) mitigate the effects of High Speed 2 construction; (5) develop and sustain access to local services; and (6) deliver affordable housing.

The remaining corporate priorities are of significance to the determination of planning applications and appeals via the key objectives of delivering the Brackley, Towcester and Silverstone Masterplans, increasing tourism and employment in the District, providing enhanced leisure facilities, safeguarding the vulnerable, increasing a return on assets and delivering a high quality service.

The above corporate priorities are considered to be fully compliant with the policy and guidance contained within the National Planning Policy Framework and National Planning Practice Guidance.

8. CONSULTATIONS

8.1 EVENLEY PARISH COUNCIL: NO OBJECTIONS.

8.2 ENVIRONMENT AGENCY: NO COMMENTS.

8.3 SNC BUSINESS SUPPORT UNIT – NO OBJECTION. It is estimated that the impact will be negligible in terms of the potential to secure additional business rates under current arrangements for the Council.

Officer comment:- Section 70(2) of the Town and Country Planning Act 1990 (as amended) provides that a local planning authority must have regard to a local finance consideration as far as it is material. Section 70(4) of the 1990 Act (as amended) defines a local finance consideration as a grant or other financial assistance that has been, that will or that could be provided to a relevant authority by a Minister of the Crown (such as New Homes Bonus payments), or sums that a relevant authority has received, or will or could receive, in payment of the Community Infrastructure Levy.

In this particular instance, the above financial payments are not considered to be material to the decision as they would not make the development acceptable in planning terms. It would not be appropriate to make a decision based on the potential for the development to raise money for a local authority and hence the above response from the Business Support Unit is therefore provided on an information basis only.

8.4 SNC ENVIRONMENTAL HEALTH OFFICER: NO COMMENTS.

8.5 SMC LEISURE FACILITIES: NO OBJECTION. It would be desirable for community use to be extended to the outdoor sports facilities as well as the indoor fitness centre, with a formalised agreement capturing this.

8.6 NCC LEAD LOCAL FLOOD AUTHORITY: NO OBJECTIONS, subject to conditions.

8.7 NCC ARCHAEOLOGY ADVISOR: COMMENTS. Not convinced that the removal of the perimeter taxiway can be dismissed as readily as it is within the Heritage Statement. The removal of a relatively large part of the taxiway will have a detrimental impact on the character and the historic significance of the other buildings and structures within the airbase. I however appreciate that development

is required to ensure the long term use of the site. The former taxiway runs roughly between the school building and the sports building and as such it would not be too difficult to preserve the route within the scheme by design. This would ensure that the former route of the taxiway was legible within the context of the airfield. This could take the form of creative landscaping and I would ask that the applicant seriously consider this proposal. I was under the impression that Mott MacDonald were intending to undertake the geophysical survey and trial trenching before submission of the application. However information regarding this has not been forthcoming. The current application has not provided sufficient information with regard to the potential for buried archaeological remains. In order to rectify this omission I would advise that the applicant’s archaeological consultant should undertake the works as detailed within their Heritage Statement and submit them in conjunction with this application. This would allow an informed assessment to be made regarding the impact of the proposals on the historic environment.

8.8 NCC HIGHWAY AUTHORITY: COMMENTS. The Transport Assessment appears robust, in so far as it takes the wider RAF Croughton development into account as committed development, the access junction modelling has been checked and trip rates / assumptions, growth factors etc. largely appear reasonable.

1. The site access is shown to be operating over capacity in the forecast year (albeit with the only predicted queuing being within the site). The applicant proposes that the same condition as applied to the wider RAF Croughton development is applied to this application i.e. that within 12 months of occupation either a revised access and timescale for delivery is agreed or that a re-survey and updated reported determining the need for the upgraded access is provided and agreed by the LPA. As the queuing is limited and entirely within the site the LHA could accept a similar condition, but related to the first occupation of the school rather than the EIC building.

2. The schools transport strategy is reliant upon the provision of a fleet of 10 private buses, without which the traffic impacts would be significantly greater than predicted. As such we would require an appropriate condition or undertaking to guarantee the provision of the bus services proposed; or a means of requiring further assessment in the event of the bus services not being provided or ceasing to operate within a prescribed period of time. One means of managing this would be via the Travel Plan review process for the school (on an annual basis). I also note that the TA makes reference to the buses picking up from a ‘managed housing location on the periphery of Brackley’, but it is unclear what this statement means / refers to?

9. REPRESENTATIONS

9.1 None received.

10. OFFICER’S REPORT

10.1 THE PRINCIPLE OF DEVELOPMENT: In terms of the need for this development the applicant has advised that in January 2015 the USAF announced plans to shut three of its airbases in the UK; RAF Mildenhall in Suffolk, and RAF Alconbury and RAF Molesworth in Cambridgeshire. As a result of these closures, approximately

1300 military personnel will be reassigned to RAF Croughton by 2022. The proposed facilities and enhanced facilities are required to accommodate the additional personnel and to enable the base to take over the communications role that RAF Molesworth previously fulfilled.

10.2 In support of the increasing USAFE establishment at RAF Croughton there will be a requirement to relocate schools currently located at RAF Alconbury to RAF Croughton. The approved design brief requirement is to construct a new EMH School with a gross area limit of 14,028m2 designed to comply with 21st Century Education Facilities Specifications published by Department of Defence Education Activity.

10.3 Paragraph 11 of the National Planning Policy Framework (NPPF) states that planning law requires applications for planning permission to be determined in accordance with the development plan unless material considerations indicate otherwise. The NPPF continues with paragraph 12 by underlining the fact that the NPPF does not change the statutory status of the development plan as the starting point for decision making. Proposed development that accords with an up-to-date Local Plan should be approved and proposed development that conflicts should be refused unless other material considerations indicate otherwise. Furthermore it is also stated that the NPPF constitutes guidance for local planning authorities and decision-takers both in drawing up plans and as a material consideration in determining applications.

10.4 The application site is located outside of any village or town confines as denoted by the Local Plan and as such the site is technically allocated as an area of open countryside. In considering this aspect Policy EV2 of the Local Plan states that, subject to exceptions, permission will not be granted for development in the open countryside. These exceptions include;

the conversion of an existing building in accordance with policies EV16 and EV17;

development necessary for the purposes of agriculture, forestry, tourism or recreation;

in the Special Landscape Areas, appropriate development essential for the purposes of agriculture, forestry, tourism or recreation; or

development in accordance with the special Policies that apply to the particular sites dealt with in Chapter 13

10.5 RAF Croughton is a 280 hectare site that contains a mix of Administrative, Community Commercial, Community Services, Housing, Industrial, Outdoor Recreation, and Open Space land use classifications. The applicant’s use / operations contained within the area of the site have been established over a number of years. Although it is accepted that the development as proposed is clearly not included under the list of exceptions under Policy EV2, the proposed development on the site will enhance the vital work the base provides. Furthermore although technically located in the open countryside the buildings are located within the operational military base and positioned away from the base perimeter fences.

10.6 The applicant provides an important and vital service for both National and International security which requires the provision of necessary equipment and buildings and for these reasons it is considered that the principle of the

development is acceptable

10.7 VISUAL IMPACT UPON THE AREA AND THE CHARACTER OF THE OPEN COUNTRYSIDE: Although located within the open countryside the development is well accommodated within the confines of the base. The base has a very distinct character and is already well developed with a range of on-site facilities including housing, primary school, personnel facilities, sports facilities and structures for the purpose of the military operations undertaken on site.

10.8 In terms of location the boundary for the proposed school is located close to the western boundary of the site which backs onto an area of open countryside. The site is currently undeveloped land used as part of the antenna array field and is leased to local farmers for grazing sheep. Surrounding the site on the south, southeast and southwest are further antenna fields.

10.9 The proposed development contains a two storey school building with an adjoining single storey energy centre. The development will have a contemporary design that reflects the modern character of RAF Croughton as a working USAF base. In terms of appearance the main part of the school will maintain an single main ridge line running through the centre of the building block to a maximum height of 9.8m although the plant space on the main roof area will add a further 2.5m height to parts of the main building. However a section of the roof over the area of the internal gymnasium will require a higher ceiling level and as such the roof height on this part of the building will be to a maximum of 12.8m. Notwithstanding this point due to the fact that the footprint of the building will vary with projections and inserts, the overall bulk of the building will not appear as one mass. Furthermore the height and bulk of the building needs to be viewed in context with the other buildings to the north and the large, geodetic domes located to the west of the proposed EMH School all of which are of similar or higher heights.

10.10 The western edge of the school site is positioned alongside the existing boundary to the USAF base and as such will be one of the tallest buildings on the base closest to the boundary. The EMH School building will therefore appear visible from the narrow public highway and public rights of way which run the length of the western edge of the base site. However, the EMH school will be positioned a minimum distance of 170m between the edge of the building and the western boundary fence of the air base. This distance together with the mature landscape buffer along the western edge of the air base and the fact that the EMH School will be seen alongside other tall buildings / structures on the site will ensure that the impact of the development on the area will kept to a minimum.

10.11 IMPACT UPON NEIGHBOUR AMENITY: The nearest dwellings are approximately 363m to the north of the main EMH School building and are located within the base. The nearest residential building outside the confines of the air base is located at Park Farm and is located approximately 775m to the north of the EMH School building. Given the distances between the proposed development and the nearest dwellings and the nature and use of the proposed building it is not considered that there will be any detrimental impact upon residential amenity in terms of light, noise, pollution or being overbearing.

10.12 IMPACT ON HISTORIC ASSETS: Section 66 of The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the duty of Local Planning Authorities (when considering whether to grant planning permission for development which affects a

listed building or its setting) to have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses. Although the site is not located within a conservation area it is within an ‘archaeological asset’ that covers the whole airbase and includes grade II listed structures in the north section of the air base in the form of 3 brick built World War II fighter pens.

10.13 The applicant has acknowledged the importance of the historic issues around the site and the application is supported by a detailed heritage statement which acknowledges the historical background of the site as a military base in terms of the archaeology but as much of the site has been the subject to various developments over the years it is considered that the proposal will not impact on any asset relating to the site’s historic use as a military airbase. Furthermore this heritage statement also acknowledges that the original cluster of buildings to the north of the perimeter taxiway has expanded into the landing ground during the latter part of the 20th century and early 21st century, including a new medical and dental centre, along with the aerials, geodetic domes and associated support buildings.

10.14 The applicant’s Heritage Statement does however accept that the development of the EMH School will have the potential to have a negative impact on the significance of the airfield due to development on the landing ground and removal of a section of the perimeter taxiway which is currently intact. Members will also see that the comments of the County Archaeological Advisor that although it is accepted that the development is required to ensure the long term use of the site concern expressed over the development and that the removal of a relatively large part of the taxiway will have a detrimental impact on the character and the historic significance of the other buildings and structures within the airbase.

10.15 In order to mitigate this harm it is suggested that as the route of the former taxiway runs roughly between the school building and the sports building and as such it would not be too difficult to preserve the route within the scheme by design. This would ensure that the former route of the taxiway was legible within the context of the airfield. This could take the form of creative landscaping and I would ask that the applicant seriously consider this proposal. It is also stated by the County Archaeologist that geophysical survey and trial has not been provided. As such it is considered that the current application has not provided sufficient information with regard to the potential for buried archaeological remains. In order to rectify this omission I would advise that the applicant’s archaeological consultant should undertake the works as detailed within their Heritage Statement and submit them in conjunction with this application.

10.16 In considering these two points although it is accepted that the development of the site for the EMH School will result in the removal of a section of the original concrete perimeter taxiway from the site. However this taxiway has been covered along the entire length with a tarmac top across a third of its width to allow for the provision of a circular roadway around the base. The remaining two thirds of the taxiway is equally spilt either side of the tarmac road and as it is a feature no-longer required by the applicant is of a poor condition and is not maintained. In terms of actual length of lost taxiway this will be equal to approximately 290m all of which will be replaced with the sports pitches and leisure facilities on the base. Under Class E of the GPDO (development on operational Crown land relating to an airbase) it is Permitted Development for the carrying out on operational Crown land, by or on

behalf of the Crown, of development (including the erection or alteration of an operational building) in connection with the provision of services and facilities at an airbase. The provision of the sports pitches is for the use of the service personnel and their children as a direct service in association with the operation of the air base. As such the provision of the sports facilities would be covered as permitted development and therefore the removal of the former taxiway cannot be resisted in this instance.

10.17 Notwithstanding this point the applicant has been advised of the request to incorporate the position / route of the taxiway through the final development. In considering this request the applicant has advised during the development of the concept design the applicant had developed an option which retained the base ring road, but this option was rejected due to the traffic safety concerns of splitting the school site into two portions. The safety of students in this respect is paramount even with the introduction of reduced speed limits. The applicant states that they are committed to evaluating the site for the presence of in ground heritage assets by both Geophysical and Intrusive means, but contend that the removal of this section of the base taxiway / ring road is a proportionate design solution to ensuring the safety of the school population.

10.18 Furthermore the applicant continues by stating that the former taxiway is no longer in a suitable condition for retention nor does it clash with the proposed footprint of the building. The former taxiway is not a protected asset and can be removed as proposed under established permitted development rights for the creation of new playing fields. The main area of new development across the route of the taxiway is that of the football / American football pitch which as highlighted under the guidance of Sport England‘s Design Guidance Note states that the optimal orientation of the pitch should be due North – South with some variation by between 32.5 degree west or 20 degree east. In order to move the pitch away from the route of the taxiway would mean the pitch could not be positioned in this location and the site area would need to be changed. In this instance as the taxiway is not a protected feature and only a small section out of the overall length of the taxiway is to be remover it is not considered that these significant changes to the layout are justified in this instance.

10.19 With regards to the request for the geophysical survey and trial pits the applicant’s Heritage Statement confirms that the limestone bedrock lies approximately 0.5m below ground level meaning that there is a limited amount of topsoil with the potential to contain archaeology. The footprint of the proposed EMH School is within the landing ground area of the former airfield which prior to the construction of RAF Croughton this had been undeveloped agricultural land. The applicant has confirmed that it is unknown whether any levelling was undertaken to facilitate the construction of the landing ground however the topography of the area would suggest that if any was undertaken it would be limited. It is known that RAF Croughton was bombed on a number of occasions through 1941 although no details of where bombs fell or of crater depths are available. Notwithstanding this point the applicant is of the view that it can be assumed that the landing ground and runways were targeted along with planes on the ground and in the fighter pens. This, given the depth of the bedrock in this location, may result in some truncation of archaeology within the landing ground, potentially concentrated around the location of fighter pens which were located around the landing ground perimeter.

10.20 During the use of RAF Croughton by the USAAF masts and telecommunications equipment have been erected in various sites on the former landing ground and that this includes in the location of the proposed EMH School. As such this intrusive work would have resulted in foundations, potentially down to or near to the depth of the bedrock which would result in localised truncation of any archaeology. Furthermore as in other parts of the airbase site there have also been a number of services installed within the footprint of the proposed new school within the landing ground, which again given the depth of bedrock this is likely to have resulted in localised truncation of archaeological deposits.

10.21 Paragraph 128 of the NPPF clearly states that “in determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary. Where a site on which development is proposed includes or has the potential to include heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.” The applicant accepts that in areas where limited former development has taken place it is not considered there is any potential for archaeology in these locations due to the depth of previous excavation in these areas.

10.22 In conclusion the applicant accepts that due to the potential for archaeological remains within the landing ground it is recommended that archaeological evaluation be undertaken. The applicant considers that this should cover all areas to be excavated within the site boundary of the EMH School. Furthermore a geophysical survey should be undertaken initially as service plans suggest that there is a limited number of services running through this area. This survey can then be used establish whether trial trenching should be undertaken and if it is felt expedient to undertake trial trenching then a sample amount of trenches based on the area to be excavated and the findings of the geophysical survey should be considered. This approach has been adopted on the previous application on the airbase where a condition has been attached to address the issue of any potential archaeology on the site. Although this approach is not supported by the County Archaeological Advisor who considers that the trail trenching should be done prior to the decision being made on this application and that as such the applicant has not complied with paragraph 128 of the NPPF. Although the position of the Archaeologist is understood it is considered that the applicant has provided evidence to justify that a condition requiring trial trenches would be acceptable and therefore it is considered that the development is in accordance with the NPPF.

10.23 HIGHWAY IMPLICATIONS: The site is well within the confines of the RAF Base which has its own highways network and emergency services provision. A site wide Transport Assessment was provided by the applicant to cover the development on the airbase for European Infrastructure Consolidation (EIC) development at RAF Croughton. This was submitted as part of the planning application for the EIC development and assessed travel to and from the base by the RAF Croughton population and the proposed increase in military personnel as part of the EIC

proposals.

10.24 The proposed EMH School will accommodate approximately 550 staff and students. It is proposed that staff and students from RAF Alconbury and RAF Molesworth will transfer to the proposed schools at RAF Croughton following the closure of these bases. In addition, staff and students at the existing elementary school within RAF Croughton will transfer to the new school. RAF Croughton is in a rural location with access from the B4031 to the west of the A43 / A421 / B4031 Barleymow Roundabout. Given its rural location access to the site via public transport, walking and cycling is difficult and the majority of trips to and from the base are made by motor vehicle.

10.25 Within the Transport Assessment the applicant states that the traffic impact of the proposed development has been assessed for the future years of 2020 and 2031 for consistency with previous assessments undertaken for the RAF Croughton site. The traffic impact assessment has shown that the RAF Croughton site access with the B4031 will be approaching its reserve capacity (RFC approaching 0.85) following the completion of the EIC development. The addition of traffic associated with the school is forecast to result in the junction, and the right-turn out of the base in particular, approaching its absolute theoretical capacity (RFC approaching 1.00) in the evening peak. It is noted that the EIC development includes a planning condition to monitor the operation and/or make improvements to the site access junction and it is recommended that a similar condition is applied to the current EMH School planning application.

10.26 As part of the consideration of this application the NCC comments have raised no objection to the principle of the application stating that the submitted Transport Assessment appears robust. The Highway Engineers have also confirmed that the applicant suggestion that similar conditions used on the previous application be applied to the development of the EMH School would also be acceptable.

10.27 FLOOD RISK: The application is supported by a detailed drainage master plan and a flood risk assessment. In considering the details the Environment Agency has confirmed that they have no objection to the proposed development subject to the attachment of conditions to any permission granted. In addition to this the NCC Lead Local Flood Authority officer has also confirmed that, following the receipt of additional information, the proposed development is acceptable and that subject to conditions there is no objection to the proposal.

10.28 For these reasons it is considered that the proposed development will have no adverse impact in terms of a flood risk. Although the area of the application site is currently laid to grass the development will result in a reduction in the level of grassland however it is accepted that the remainder of the site will remain as grass and so surface water run off should not increase exponentially. It is therefore considered that the proposal complies with the Local Plan policies relating to flood risk and section 10 of the NPPF which relates to climate change and flooding.

10.29 IMPACT UPON BIODIVERSITY AND PROTECTED SPECIES: Section 11 of the National Planning Policy Framework (NPPF) addresses issues regarding ‘Conserving and enhancing the natural environment’. When determining applications local planning authorise should aim to conserve and enhance biodiversity by following a number of principles. Firstly, if significant harm resulting from a development cannot be avoided (through locating on an alternative site with

less harmful impacts) or adequately mitigated or compensated for then planning permission should be refused. Opportunities to incorporate biodiversity in and around developments should be encouraged.

10.30 In addition to this paragraph 99 of Circular 06/05 states that “it is essential that the presence or otherwise of protected species, and the extent that they may be affected by the proposed development, is established before the planning permission is granted, otherwise all relevant material considerations may not have been addressed in making the decision”. Section 40 of the Natural Environment and Rural Communities Act 2006 (NERC 2006) states that “every public authority must, in exercising its functions, have regard … to the purpose of conserving (including restoring / enhancing) biodiversity”.

10.31 Strict statutory provisions apply where European Protected Species (EPS) are affected, as prescribed in Regulation 9(5) of Conservation of Habitats and Species Regulations 2010. When determining a planning application that affects an EPS, local planning authorities must have regard to the requirements of the EC Habitats Directive which states that “a competent authority, in exercising any of their functions, must have regard to the requirements of the Habitats Directive so far as they may be affected by the exercise of those functions”. In this application the Council has to have regard to EPS when exercising their statutory functions, of which Planning Permission applications are one.

10.32 To support this application the applicant has provided a preliminary ecological appraisal of the site. Within this assessment the applicant acknowledges that there are seven non-statutory designated Local Wildlife Sites, four Potential Wildlife Sites and two Pocket Parks within 2km of the base. The southern part of RAF Croughton is allocated as a Potential Wildlife Site (PWS) and the proposed works are within this area, so the habitat on the western side of the PWS will be lost as part of the scheme. This designation is for sites which have not been surveyed to confirm their status as a Local Wildlife Site. The areas of the proposed work for the proposed buildings comprise the following habitat types: Improved grassland, species-poor semi-improved grassland, hedgerows and scattered scrub. The existing recycling centre building has potential to support nesting birds and an outside toilet has potential to support roosting bats. A single bat emergence survey was completed on 15 August 2016, which concluded that although the base was used for foraging, no bats emerged from the toilet block. Both buildings are outside of the proposed works area.

10.33 The ecological report continues by stating that in the applicants view the proposed works have potential to support protected and notable species which may be adversely impacted under the current proposals. This includes breeding birds, wintering birds and badgers. It is however considered that the risk of adversely impacting other protected and notable species is low, however it is acknowledged by the applicant that pre-works badger checks are recommended. The ecological report concludes with a number of recommendations for enhancement measures on the site which aim to increase the nature conservation value of the site, and these include a pond habitat, installation of bird and bat boxes and management of grassland to promote biodiversity.

10.1 Given the above, it is considered that Art.12(1) of the EC Habitats Directive has been duly considered in that the welfare of any EPS found to be present at the site and surrounding land will continue and be safeguarded notwithstanding the

proposed development.

10.2 Linked to the issue of ecology is that of landscaping around the site and in association with the proposed development. Due to the relatively flat nature of this part of the airbase the proposed two storeys EMH School will appear as a large new structure within the airbase. The applicant’s landscape plan aims to provide a scheme which will assist in softening the impact / appearance of the EMH School building within the area.

10.3 The applicant has advised that scattered trees were recorded in many parts of the air base where they have been planted for amenity, particularly on areas of amenity grassland and adjacent to buildings and hard standing. The majority of trees on the base were young to semi-mature, and species recorded included sycamore Acer pseudoplatanus, oak Quercus robur, cherry Prunus avium, ash Fraxinus excelsior, horse chestnut Aesculus hippocastanum and false acacia Robinia pseudoacacia. With regards to the area of the site allocated for the EMH School there are no scattered trees and the character of this part of the airbase is predominantly flat grassland. However due to the existing landscaping the views of the bulk of the EMH School from the public right of way and the public highway are likely to be screened by the existing mature hedgerow / tree planting along the western boundary of the airbase.

10.4 As part of the landscape strategy the applicant points out that the 21st Century Schools Education Specifications highlights the importance of a good Landscape proposal as a key learning environment and integral part of the school. For this reason the applicant states that the proposed landscape design sets out to create this and has been designed to enhance these relationships and stimulate indoors/outdoors learning (and playing) opportunities. In doing so the applicant also states that the landscape design also seeks to retain the value of retaining the visual characteristic of the site with its distinctive landmarks, within the requirements of the external amenity required by the DoDEA Education Specifications.

10.5 The landscape scheme for the EMH School includes a mix of new trees and low level shrubs around the main building of the EMH School. Concern had been expressed with regards to the proposed tree planting as part of the previous application on the basis that the planting of numerous trees would impact on then historic nature of the site as an airbase. In taking account of this previous concern the applicant has advised that the landscape strategy for the EMH School shows that new trees are to be clustered close to the building and therefore of limited impact on the openness of the air base. Furthermore the strategy will ensure that there will be no impact on views of the ‘golf balls’ from the east or the south, while from the north, views are dominated by the existing collection of buildings. In addition, many of the proposed lines of tree planting occur to the north of the site, adjacent to the base’s housing and therefore would not impact on anyone’s experience of looking into/across the site from the base’s perimeter.

10.6 For the above reasons the landscaping strategy is considered acceptable and will help to reduce the impact of the development on this part of the airbase. In addition, the landscaping design using groups of trees close to and to the north of the main EMH School building will ensure that the impact on the openness of the airbase is limited.

11. CIL LIABILITY

11.1 The new school is located within the confines of the air base and not accessible to the general public. The school will form part of the sui generis military use of the whole base for this reason the development is not liable for CIL.

12. CONCLUSIONS

12.1 This application seeks planning permission for the construction of a new Elementary, Middle and High (EMH) School at RAF Croughton to cater for an increasing base establishment. The proposed development contains a two storey school building with an adjoining single storey energy centre. Designed to contain up to 468 students of all age ranges who will supported by 60 full time staff. The provision of the school will also allow for the existing Child Development Centre (primary school) to be refurbished as office accommodation and three poorly insulated and outdated office buildings on the base to be demolished.

12.2 It is accepted that in terms of Policy the proposal is not strictly in accordance with Policy EV2 which restricts development in the open countryside subject to assessments. However, the use of the base for military use has a long history and the proposal represents the continued use of the site. Furthermore as all the development is contained within the confines of the base the impact on the area of open countryside is limited and therefore the principle of development is considered acceptable.

12.3 It has been highlighted that the base contains a number of historical features in terms of the grade II listed fighter pens along with the historical background of the base itself although the impact on listed features is not an issue in this application. The concerns raised by the County archaeologist are noted however it is also accepted that any potential archaeological finds can be covered by a suitably worded condition.

12.4 The increase in staff / use of the base will result in an impact on the level of traffic comings and goings in the area. The applicant’s traffic assessment has assessed the impact of this development on both the strategic and local highway network and mitigation measures are suggested to a number of key junctions. These mitigation measures will assist in reducing the impact of the development related traffic on the highway network.

12.5 Furthermore it is also considered that the development is acceptable in terms of design, neighbour amenity, biodiversity and protected species, flood risk and the visual impact upon the open countryside and surrounding area.

13. HUMAN RIGHTS ACT

13.1 The Human Rights Act 1998 sets out fundamental freedoms which have been laid

out by the European Convention on Human Rights (ECHR). The Council in making a decision should be aware of and take into account any implications that may arise from the Human Rights Act 1988. It is unlawful for a public authority such as South Northamptonshire Council to act in a manner which is incompatible with the ECHR.

13.2 Consideration has been specifically given to Article 6 (right to a fair trial), Article 8

(right to respect for private and family life) and Article 1 of the First Protocol (protection of property) of the ECHR. It is considered that the applicant has been given the right to a fair and public hearing under the established planning process adopted by the Council. The Secretary of State and courts are involved in the planning process where appropriate. It is also considered that the recommendation does not interfere with the applicant’s right under Article 8 ECHR, except such as is in accordance with the law, in the interests of national security, public safety, economic wellbeing of the country, prevention of disorder/crime, protecting health/morals, or to protect the rights and freedoms of others. The Council is also permitted to control the use of property in accordance with the general interest, and the recommendation is considered to be a proportionate response to the submitted application based on the considerations set out in this report.

14. DUTY UNDER THE EQUALITIES ACT 2010 14.1 In assessing this proposal, the following impacts have been identified upon those

people with the following protected characteristics (age, disability, gender reassignment, marriage & civil partnership, pregnancy & maternity, race, religion or belief and sex or sexual orientation).

14.2 The proposal would have a neutral impact on the protected characteristics.

15. CONDITIONS

TIME LIMITS AND GENERAL IMPLEMENTATION CONDITIONS 1. The development hereby permitted shall be begun before the expiration of three

years from the date of this permission. Reason : To comply with the provisions of Section 91 of the Town and Country

Planning Act 1990, as amended by Section 51 of the Planning and Compulsory Purchase Act 2004.

2. The development shall not be carried out otherwise than in complete accordance with

the approved plans 1036--A-DR00-XX-001; LBY-362584_1036-A-DR-00-XX-0010; LBY-362584_1036-A-DR-00-XX-0100 Rev B; 1036-02-LBY-362584_1036-A-DR-00-XX-0200B; 1036-02-LBY-362584_1036-A-DR-00-XX-0201A; 1036-02-LBY-362584_1036-A-DR-00XX-0201B; 1036-02-LBY-362584_1036-A-DR-00-XX-0200A; 1036-02-LBY-362584_1036-A-DR-00XX-0202A; 1036-02-LBY-362584_1036-A-DR-00-XX-0202B; 1036-02-LBY-362584_1036-A-DR-00-XX-0300; 1036-02-LBY-362584_1036-A-DR-00-XX-0301; 1036-02-LBY-362584_1036-A-DR-00-XX-0400 RevA; 1036-02-LBY-362584_1036-A-DR-00-XX-0401 Rev A; LBY-362584_1036-A-DR-00-XX-510; MMD-362584-E-DR-00-XX-2601 Rev P1; MMD-362584-C-DR-00-XX-5103 Rev P3; MMD-362584-C-DR-00-XX-5104 Rev P3; MMD-362584-C-DR-00-XX-5105 Rev P3; MMD-362584-C-DR-00-XX-5106 Rev P1; MMD-362584-C-DR-00-XX-5201 Rev P3; MMD-362584-C-DR-00-XX-5202 Rev P3; MMD-362584-C-DR-00-XX-5203 Rev P3; MMD-362584-C-DR-00-XX-5221 Rev P4; MMD-362584-C-DR-00-

XX-5222 Rev P4; MMD-362584-C-DR-00-XX-5223 Rev P4; MMD-362584-C-DR-00-XX-5224 Rev P4; MMD-362584-C-DR-00-XX-5231 Rev P1; MMD-362584-C-DR-00-XX-5271 Rev P1; MMD-362584-C-DR-00-XX-5501 Rev P3; MMD-362584-C-DR-00-XX-5502 Rev P3; MMD-362584-C-DR-00-XX-5503 Rev P3; MMD-362584-C-DR-00-XX-5101 Rev P3; MMD-362584-C-DR-00-XX-5102 Rev P3; received 06/03/17 and other details such as Planning Statement; Design and Access Statement; Preliminary Ecological Appraisal; Ground Investigation; Heritage Statement; Landscape Details / Masterplan and Specifications; Outdoor Lighting Report; Environmental Policy Statement; Solid Waste Management Plan; Travel Plan; School Transport Assessment unless a non-material amendment is approved by the Local Planning Authority under the Town and Country Planning (Development Management Procedure) (England) Order 2015.

Reason : To clarify the permission and for the avoidance of doubt. CONDITIONS REQUIRING LOCAL PLANNING AUTHORITY WRITTEN APPROVAL

OR TO BE COMPLIED WITH BEFORE ANY DEVELOPMENT COMMENCES 3. No development shall take place until samples of the aluminium to be used in the

covering of the roof of the school have been submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in accordance with the samples so approved.

Reason : To ensure that the materials are appropriate to the appearance of the

locality and to ensure the satisfactory appearance of the completed development in accordance with Policy G3 of the South Northamptonshire Local Plan.

4. No development shall take place until samples of the bricks and curtain walling to be

used in the construction of the walls of the school have been submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in accordance with the samples so approved.

Reason : To ensure that the materials are appropriate to the appearance of the

locality and to ensure the satisfactory appearance of the completed development in accordance with Policy G3 of the South Northamptonshire Local Plan.

5. No development shall take place, including any works of demolition, until a

Construction Method Statement has been submitted to, and approved in writing by, the local planning authority. The approved Statement shall be adhered to throughout the construction period. The Statement shall provide for:

i) the parking of vehicles of site operatives and visitors ii) loading and unloading of plant and materials iii) storage of plant and materials used in constructing the development iv) the erection and maintenance of security hoarding including decorative displays

and facilities for public viewing, where appropriate v) wheel washing facilities vi) measures to control the emission of dust and dirt during construction vii) a scheme for recycling/disposing of waste resulting from demolition and

construction works

Reason : To protect the amenities of nearby residents and to comply with Policy G3

of the South Northamptonshire Local Plan. 6. No development shall take place until a detailed design of surface water drainage

scheme for the site based on sustainable drainage principles and an assessment of the hydrological and hydro geological context of the development should be submitted to and approved in writing by the local planning authority. The scheme shall subsequently be implemented in accordance with the approved details before the development is completed. The details of the scheme shall include:

i) Details (i.e. designs, diameters, invert and cover levels, gradients, dimensions and

so on) of all elements of the proposed drainage system, to include pipes, inspection chambers, outfalls/inlets and attenuation structures (if required). Details of the drainage system are to be accompanied by full and appropriately cross-referenced supporting calculations.

ii) BRE 365 infiltration test results to confirm such a method of surface water disposal is viable.

Reason: To reduce the risk of flooding both on and off site in accordance with the

NPPF, Saved Policy G3 of the South Northamptonshire Local Plan, and Policy BN7A of the West Northamptonshire Joint Core Strategy Local Plan 2014 by ensuring the satisfactory means of surface water attenuation and discharge from the site.

7. No development of any part of the development shall commence until a scheme for

the maintenance and upkeep of the surface water drainage system proposed for that part of the development on the site has been submitted to and approved in writing by the Local Planning Authority. The maintenance plan shall be carried out in full thereafter. This scheme shall include details of any drainage elements that will require replacement within the lifetime of the proposed development.

Reason: To reduce the risk of flooding both on and off site and to ensure the future

maintenance of drainage systems associated with the development and in accordance with the NPPF, Saved Policy G3 of the South Northamptonshire Local Plan, and Policy BN7A of the West Northamptonshire Joint Core Strategy Local Plan 2014 .

8. No part of the development shall take place until a comprehensive intrusive

investigation (in order to characterise the type, nature and extent of contamination present, the risks to receptors and to inform the remediation strategy proposals) has been documented as a report (undertaken by a competent person and in accordance with DEFRA and the Environment Agency's ‘Model Procedures for the Management of Land Contamination, CLR 11’) for that part of the development and submitted to and approved in writing by the Local Planning Authority. No part of the development shall take place unless the Local Planning Authority has given its written approval that it is satisfied that the risk from contamination has been adequately characterised as required by this condition.

Reason: To ensure that any ground and water contamination is adequately

addressed to ensure the safety of the development, the environment and to ensure

the site is suitable for the proposed use, to comply with Saved Policy G3 of the South Northamptonshire Local Plan.

9. If contamination is found by undertaking the work carried out under condition 8, prior

to the commencement of the development hereby permitted, a scheme of remediation and/or monitoring to ensure the site is suitable for its proposed use shall be prepared by a competent person and in accordance with DEFRA and the Environment Agency's ‘Model Procedures for the Management of Land Contamination, CLR 11’ and submitted to and approved in writing by the Local Planning Authority. No development shall take place until the Local Planning Authority has given its written approval of the scheme of remediation and/or monitoring required by this condition.

Reason: To ensure that any ground and water contamination is adequately

addressed to ensure the safety of the development, the environment and to ensure the site is suitable for the proposed use, to comply with Saved Policy G3 of the South Northamptonshire Local Plan.

10. If remedial works have been identified in condition 9, the development shall not be

occupied until the remedial works have been carried out in accordance with the scheme approved under condition 9. A verification report that demonstrates the effectiveness of the remediation carried out must be submitted to and approved in writing by the Local Planning Authority.

Reason: To ensure that any ground and water contamination is adequately

addressed to ensure the safety of the development, the environment and to ensure the site is suitable for the proposed use, to comply with Saved Policy G3 of the South Northamptonshire Local Plan.

11. If, during development, contamination not previously identified is found to be present

at the site, no further development shall be carried out until full details of a remediation strategy detailing how the unsuspected contamination shall be dealt with has been submitted to and approved in writing by the Local Planning Authority. Thereafter the remediation strategy shall be carried out in accordance with the approved details.

Reason: To ensure that any ground and water contamination is identified and

adequately addressed to ensure the safety of the development, the environment and to ensure the site is suitable for the proposed use, to comply with Saved Policy G3 of the South Northamptonshire Local Plan.

12. No development shall take place until the applicant (or their agents or successors in

title) has submitted to and had approved in writing by the local planning authority a programme of archaeological work consisting of a written scheme of investigation (to include trial trenching) and a timetable for that work. The development shall thereafter proceed in accordance with the approved written scheme of investigation and timetable.

Reason: To secure the provision of archaeological investigation and the subsequent

recording of the remains, to comply with Government advice in the National Planning

Policy Framework (NPPF) (Section 12). CONDITIONS REQUIRING LOCAL PLANNING AUTHORITY WRITTEN APPROVAL

OR TO BE COMPLIED WITH BY DEVELOPER BEFORE SPECIFIC CONSTRUCTION WORKS TAKE PLACE

13. Within 6 months of the completion of the archaeological work in accordance with the

written scheme of investigation approved pursuant to condition 12 above the applicant (or their agents or successors in title) shall submit to the local planning authority for its written approval an archaeological report comprising a post-excavation assessment and analysis, preparation of site archive and completion of an archive report together with details of the store at which this is to be deposited

Reason: To secure the provision of archaeological investigation and the subsequent

recording of the remains, to comply with Government advice in the National Planning Policy Framework (NPPF) (Section 12).

14. Notwithstanding the details of the lighting assessment and layout plan no

development shall take place until details of the external lighting/security lighting/floodlighting, including the design, position, orientation and any screening of the lighting has been submitted to and approved in writing by the Local Planning Authority. The lighting shall be installed and operated in accordance with the approved scheme at all times thereafter.

Reason : To protect the amenities of nearby residents and to comply with Policy G3

of the South Northamptonshire Local Plan. 15. (a) Within 12 months of the first occupation of the school by students either:

(i) full details of the design and delivery timescale of a new main access junction to serve the base shall be submitted to and approved in writing by the Local Planning Authority; OR (ii) a re-survey of the existing site access junction shall be undertaken and an assessment (based on the results of the re-survey) of the need and design of a new or amended main access junction to serve the base, shall be submitted to and approved in writing by the Local Planning Authority.

(b) If a new main access junction to serve the base is approved under (i) these

works shall be implemented and delivered in accordance with the approved scheme and timescale approved under (i).

(c) If revised access works are deemed to be necessary (following receipt of the

assessment by the Local Planning Authority submitted under (ii)) then within 12 months of notification by the Local Planning Authority to the Applicant/Developer of these works being required (or other timescale as agreed in writing with the Local Planning Authority), full details of the design and delivery timescale of revised access works shall be submitted to and approved in writing by the Local Planning Authority and the access works shall be implemented and delivered in accordance with the approved scheme and timescale.

Reason: In the interests of highway safety. CONDITIONS TO BE COMPLIED WITH AT ALL TIMES 16. No drainage system for the infiltration of surface water drainage into the ground from

the car parks and roads on the Full Development is permitted other than with the express written consent of the Local Planning Authority, which may be given for those parts of the site where it has been demonstrated that there is no resultant unacceptable risk to controlled waters. Should such a drainage system be proposed then these details should be first submitted to and approved in writing by the Local Planning Authority prior to the commencement of such works and shall be carried out in accordance with the approval details.

Reason: To prevent contamination of groundwater and in accordance with Saved

Policy G3 of the South Northamptonshire Local Plan. 17. The development hereby permitted shall be carried out in accordance with the

recommendations set out in Report No. 26 - Preliminary Ecological Appraisal of the RAF Croughton EIC Programme – EMH School by Mott MacDonald Limited dated 20th February 2017 unless otherwise agreed in writing by the Local Planning Authority.

Reason : To protect habitats and/or species of importance to nature conservation

from significant harm in accordance with the Government's aim to achieve sustainable development as set out in the National Planning Policy Framework.