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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: developing strategies for surface access infrastructure to support strategies for the growth of airports; and 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? Definitions? 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.   See our other blogs in this series: National Planning Policy Framework review: what to expect? Draft revised National Planning Policy Framework: a change in narrative NPPF consultation proposals – what could they mean for town centres? NPPF consultations – what could they mean for designers? Draft NPPF: heritage policy is conserved… Draft NPPF: business as usual? Draft NPPF: more emphasis on healthy and safe communities Lichfields will publish further analysis of the consultation on the draft revised NPPF and its implications. Click here to subscribe for updates. Image credit: Commission Air / Alamy Stock Photo  

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The UK Aviation Strategy: new aviation White Paper set for take-off
Following two Government consultations earlier in the year on aviation, the Department for Transport has begun plans to develop a new UK Aviation Strategy to, help shape the future of the aviation industry to 2050 and beyond. Where the previous two 2017 aviation consultations dealt with a National Policy Statement for a new north-west runway at Heathrow Airport and a review of the future of airspace management, this national strategy will seek to review the challenges facing aviation as well as opportunities – to set out a long-term direction for aviation policy and how the Government can support the future growth of the industry.   There is a long and complex history of UK aviation policy, focused primarily on the need (or not) for additional runway capacity. It’s been four years since Government published the extant national policy – the Aviation Policy Framework 2013 – which set out the principles the Airports Commission (which came to a close in 2015) took into account when assessing the need for new runway capacity. The predecessor of the Aviation Policy Framework was the White Paper, the Future of Air Transport 2003. This set out the need for all UK airports to consider their own position and role via an airport master plan – at the time it also gave support for a new runway at Heathrow Airport. The 1985 Airports Policy White Paper took a more conservative view, recommending the need to review capacity provision and until that time stating that the focus should be on making best use of existing capacity.   This proposed new aviation strategy moves beyond the runway and capacity debate, with an overriding aim of putting the customer at the centre of aviation policy - ‘to achieve a safe, secure and sustainable aviation sector that meets the needs of consumers and of a global outward-looking Britain[1]’, whilst still seeking to ‘make best use of existing capacity at all airports around the country[2]’. At a recent Aviation Club UK[3] event[4], the Secretary of State for Transport, Chris Grayling, spoke of the emerging strategy and reinforced the importance of aviation in a post-Brexit environment, confirming that it remains central to the Government’s plans for the UK.  With a long term view in mind, the focus of this new strategy will be to boost economic growth, regional connectivity and skills to prepare the industry for the next three decades and beyond.   The first step in preparing this emerging policy is a call for evidence by Government. The consultation document ‘Beyond the horizon: the future of UK aviation – call for evidence on a new strategy’, was published on 21st July 2017 and closes 13th October 2017. The Government has identified six themes it considers important to take the aviation industry forward and is now seeking views on the approach to take and the issues that it has identified. The six themes are: Customer service Safety and security Growing global connectivity Encouraging competitive markets Supporting growth while tackling environmental impacts Embracing innovation and technology, and building a skilled workforce Government has said that following this call for evidence, consultations on each of the six themes will run throughout 2017 and 2018; publication of the final aviation strategy will be by the end of 2018. Future Lichfields blogs will consider the various elements contained in these proposed publications and their implications, so please subscribe for future updates.   The areas we’re most interested to hear more on from Government include: the mechanisms proposed to safeguard existing airport operations; the role of regional connectivity; preserving the general aviation network; and the need to demonstrate the contribution and the need for adequate surface access.   Who should be interested in this initial call for evidence? The Government wants to hear from airlines, airports, the aerospace sector, freight customers, passengers and the public about how Government can support the industry. Given the long-term view of this emerging policy and its focus on boosting economic growth, connectivity and skills, it will be important for everyone who the industry serves, and those who are affected by it, to have their say. The consultation period for this first stage of review ends on 13th October. Please do get in touch if you would like to know more about the objectives of the call for evidence and the questions posed by Government, and would like our assistance with preparing a submission.   [1] Beyond the horizon: the future of UK aviation – call for evidence on a new strategy, page 20. [2] Beyond the horizon: the future of UK aviation – call for evidence on a new strategy, page 22. [3] Tabitha Knowles is a member of the Aviation Club UK. [4] Aviation Club UK meeting, held 12th July 2017.  

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