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Draft NPPF: implications for aviation?

Draft NPPF: implications for aviation?

Tabitha Knowles 13 Mar 2018
Hidden amongst all the draft National Planning Policy Framework’s (NPPF) housing headlines are new policies on aviation.
My colleagues have already published a blog on the proposed changes to the document as a whole (see our Lichfields’ blog); this blog delves into all things aviation.
National aviation policy currently comprises the ‘Aviation Policy Framework 2013’ – soon to be replaced by the impending national Aviation Strategy and new policy framework for the sector (see my previous blog for details). A draft Airports National Policy Statement was consulted on last year and is currently undergoing Parliamentary scrutiny.
Within England and Wales, the current NPPF sets out policy on aviation, dealing with aviation safety and surface access provision to support strategies for growth of airports. Local planning authorities are to have regard to relevant National Policy Statements, the Aviation Policy Framework and the NPPF when preparing their local plan policies.
Current versus draft
Within the draft NPPF, aviation policy is largely unchanged (albeit with a change to paragraph references, as for the rest of the document). In particular:
Paragraph 115a deals with telecommunications development and the need for consultation with relevant bodies, if located within a statutory aerodrome safeguarding zone (currently in paragraph 45).
Paragraph 200h addresses the need to take account of aviation safety with respect to reclaiming worked land and the aftercare of mineral sites (currently within paragraph 143) .
Para 201b deals with aviation safety relating to planning applications for mineral extraction (currently within paragraph 144).
Both the current and draft NPPF reference Circular 01/03: Safeguarding aerodromes, technical sites and military explosives storage areas, to safeguard such sites.
Key change
The key change in the draft NPPF relates to current paragraphs 31 and 33 and promoting sustainable transport – now in draft paragraph 105(e) and (f).
Currently, paragraph 31 relates to the promotion of sustainable transport and requires local authorities to ‘work with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development, including large scale facilities such as rail freight interchanges, roadside facilities for motorists or transport investment necessary to support strategies for the growth of ports, airports or other major generators of travel demand…’. 
Paragraph 33 states that when planning for airports or airfields, plans should take account of an airport or airfield’s growth and role in serving business, leisure, training and emergency service needs, and that plans should also take account of other relevant policy such as the current Aviation Policy Framework and national policy statements.
These polices are all about:
  1. developing strategies for surface access infrastructure to support strategies for the growth of airports; and
  2. the need to consider the growth and role of an airport or airfield.
Of note, paragraph 33 refers to ‘airports’ and ‘airfields’ but the NPPF does not define either, nor does it provide clarification on the difference between the two.
So how are these policies proposed to be changed?
Draft paragraph 105(e) requires planning polices to ‘provide for any large scale facilities, and the infrastructure to support their operation and growth, taking into account any relevant national policy statements and whether such development is likely to be a nationally significant infrastructure project…’. Examples are provided of large scale facilities which include airports.
Draft paragraph 105(f) states that planning policies should ‘recognise the importance of maintaining a national network of general aviation facilities – taking into account their economic value in serving business, leisure, training and emergency service needs, and the Government’s General Aviation Strategy’.
Do these proposed policy tweaks go in the right direction, or far enough for the industry?
The new draft policy makes a clear distinction between ‘large scale facilities’ and ‘general aviation facilities’ but does not define them; these are the only aviation categories referenced. Aviation infrastructure in reality is not limited to being one or the other. There is still no definition of ‘airport’, and the term ‘airfield’ does not feature any longer either.
Infrastructure to support an airport’s operation and growth
For large scale facilities, the draft policies require that not only should there be policies in place for the airport itself, but there should also be policies for infrastructure that would support the airport’s operation and growth – and not just transport investments as per the current policy. Infrastructure supporting an airport’s operation and growth could include a wide range of developments and land uses, such as warehousing, distribution and logistics facilities, energy centres, education centres, office space and hotels.
The draft NPPF acknowledges that airports are not standalone entities and that they can be regional and national economic accelerators, catalysing and driving business development. As aviation-oriented businesses increasingly choose to locate at airports and along transportation corridors radiating from them, an ‘aerotropolis’ emerges; cities are being built around airports, instead of the reverse. As a consequence, aviation involves the delivery - directly and indirectly - of many different forms of development and land uses. There is an important relationship between ‘city’ and ‘airport’, connecting airports to local economic needs and wider opportunities for growth.
But would this policy approach apply to smaller airports? And at what point does a facility become ‘large-scale’?
Demonstrating economic value – for general aviation only?
The draft policy gives focus to identifying the ‘economic value’ (compared to the current ‘growth and role’ terminology) in serving business, leisure, training and emergency service needs. The need to consider the economic value of aviation is consistent with emerging thinking on the new Aviation Strategy and its focus on boosting economic growth, connectivity and skills. But this draft NPPF policy refers to general aviation facilities only.
Does this mean that the same considerations – demonstrating economic value - are not required of airports operating as providers of public transport for large numbers of passengers? Business aviation with its strong support for economic development is given no specific recognition; perhaps it should be?
Maintaining a national network of general aviation facilities
Continuing support for the maintenance of a national network of general aviation facilities is strongly supported by the General Aviation Awareness Council (GAAC).
To maintain a network, first it has to be understood what the network is, how it functions (in terms of current capacity and its ability to meet future demand) and its value (both social and economic) at a local and national level – and this must then be clearly and consistently conveyed to the appropriate planning authorities.
The final version of the NPPF, to be published ‘before the summer’, would be better for dealing with these uncertainties – in particular clarity on whether these policies would apply to a select few or to the sector as a whole.  

Image credit: Commission Air / Alamy Stock Photo