Planning Threat to Panshanger Airfield - Guidance Material
Planning Threat to Panshanger Airfield - Guidance Material

 

This document sets out specific considerations that apply to the Welwyn and Hatfield Borough Council’s Emerging Core Strategy as it relates to the future of Panshanger Aerodrome.  As the Council’s strategy document is in response to the National Planning Policy Framework (NPPF) it is prudent to use the NPPF and other policies as defence against the proposal.   On this page we provide links to the relevant sections in the Council’s consultation document followed by references and arguments you may want to include in your consultation response. 

 

Please have a look at sections in the consultation document and then use the data provided to compose your response.  Sections below in italics are extracts from laws or regulations so copy them into your comments as you wish.  But please do not copy the rest of the text but write your own words to say what you think.

 

If you insert comment on the Council website it is best to draft your text in a document of your own and then paste them into the council website.  It is easier for you and comment tools do crash and will lose your work!  You will probably want to add things later so save your comments to the council website and submit them when you are all done.

 

The main page for the Strategy Consultation is here.

 

The section dealing with housing development is here.

 

And there are sections for infrastructure and sustainability

 

But we include specific links in each section that follows.

 

The Specific Proposal to allocate Panshanger Aerodrome for Housing

 

Section WGC4 of the Land For Housing Section of the Strategy proposes that Panshanger and the land immediately north of it should be assigned for 700 houses plus a site for gypsies and travellers You can link to the Panshanger page WGC4 using this link (you need to be logged on to add or edit comments). 

 

Please read the section on Panshanger then consider the headings below that you might want to use in your comments.  You will be able to set out your own reasons for wanting Panshanger to stay.  Make your own opening statement about why an aerodrome is important in this area.

 

NPPF Aviation Specific Requirement

 

The strongest and most important paragraph in the NPPF for aviation is in section 4 on Promoting Sustainable Transport.  On page 10 it says:

 

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.”

 

You may want to draw attention to this noting they have failed to comply with it but must do so.  Include a copy of para 33.

 

Clearly the Council has ignored this in suggesting that the thriving aerodrome should be closed to the detriment of many businesses, leisure activities and training operations that currently take place on the site. They have not actually recognised that an aerodrome has uses and is not derelict land but have ignored it as if it was a vacant site.

 

Point out the scarcity of aviation sport and leisure facilities in the South East and outer London in particular.   Ask them how they are going to provide alternative facilities and where.

 

By the planned closure they are also denying future opportunities for business links to and from other parts of the UK and the near continent by air.

 

NPPF Requirement for Sustainability

 

On Page 2 the NPPF quotes UN General Assembly Resolution 42/187 on sustainable development as

 

meeting the needs of the present without compromising the ability of future generations to meet their own needs”.

 

Point out that the Council have failed to take this into account and ask how they are going to do so.

 

The planned closure of the aerodrome will compromise future generations’ needs for the facilities currently enjoyed at this aerodrome; sport, recreation and leisure, employment opportunities and green open space.  Moreover the strategy does not recognise any of these characteristics in the existing land use.

 

The NPPF quotes 3 elements of sustainability on Page 2 and two are relevant to Panshanger:

 

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.

 

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.

 

Use the extracts above to discuss what the Council should do to comply.

 

The Strategy Sustainability Appraisal which can be downloaded here includes a number of statements about sporting facilities which are contradicted by the proposal to close Panshanger.  The key points of the Appraisal are highlighted below showing that the Strategy has ignored its own policy basis.  The consultants who produced this conclude by saying the proposed strategy will “have no negative effects” but that is incorrect:

 

10.21 The following Issues and Options Strategy Statement relates to this policy:

 

10.22 Community Services and Facilities: “We will seek to ensure that our communities are well served by a range of community services and facilities. We will, through the relevant DPDs, SPDs, master-plans and development briefs:

 

Guard against the loss of existing community facilities;

 

Allow for the expansion and / or enhancement of existing community facilities to assist continuing viability, where this may be an issue, particularly in areas where new development will increase the demand for facilities;

 

10.27 Policy CS6 aims to ensure communities can easily access a range of community services and facilities (including community centres and village halls, facilities for sport, leisure and play, shops, libraries, cultural facilities, etc.) by protecting and enhancing existing facilities and promoting new facilities where these are required.

 

10.28 Policy CS6 is expected to have significant positive effects on health (SA objective 1.2) as it seeks to ensure that communities can easily access a range of community services and facilities (which includes healthcare facilities) through a range of measures such as guarding against the loss of facilities, expansion and enhancement etc. The policy also includes additional measures specifically for sport and recreation, recognising these facilities as important for enabling people to live healthy and active lifestyles. It also seeks to upgrade sport and recreation facilities, provide new facilities and facilitate schemes to open up private or restricted facilities to the public.

 

10.29 No significant negative or uncertain effects are predicted from this policy.

 

You will recognise that this last statement on which the Council’s policy is based is quite false.

 

Air Sports which include Sport and Recreational Aviation are recognised by Sport England and the LAA is a National Governing Body.

 

Panshanger is a sporting venue and facility – this is covered later on.

 

Please write comments supporting Panshanger as a facility for sport and leisure concluding with a statement that the area of the aerodrome should be retained and not used for housing .  You may want to suggest that it is easier to build houses elsewhere than it is to relocate an aerodrome.

 

 

NPPF Requirement for a Prosperous Economy

 

In paragraph 28 on page 9 the NPPF states that planning policies should support economic growth and the expansion of all types of businesses and

 

 “should promote the retention and development of local services, community facilities and sports venues”,

 

Clearly Panshanger aerodrome provides all these functions but the Sustainability Appraisal, the Housing Strategy and the Emerging Core Strategy all dismiss and ignore that. 

 

The Council, under their plans to close Panshanger aerodrome would prevent economic growth of the aerodrome and the businesses and activities it supports.  The town of Welwyn and the surrounding district would lose a community facility and sports venue.   London and the south east of England would lose a significant sports facility which is not easy to replace.  Because of the pressure on light aviation aerodromes in the south-east, Panshanger has “a special uniqueness to an area and cannot easily be replaced”.  See below for the specific meaning of this.

 

The aviation businesses currently in operation on the aerodrome should be encouraged by the council rather than destroyed.

 

Sport Facilities  - NPPF and Sport England Requirements

 

The Strategy does not note that Air Sports are recognised by Sport England which places a number of planning requirements on councils.  As Panshanger Aerodrome is a sports facility the Council are obliged by statute to take account of a number of issues which they appear to have failed to carry out. 

 

This policy clarification from Sport England is useful: 

 

Whilst the NPPF makes specific reference to sport, recreation and open space in a number of paragraphs, Sport England considers that all references within the NPPF to community and/or social infrastructure, land and facilities also includes these uses.

 

Sport England also tells us that where a facility has “a special uniqueness to an area and cannot easily be replaced” it should be protected.  Closing Panshanger Aerodrome would remove the aviation sports facilities available to local communities as well as removing an important national asset that particularly serves North London and it cannot be replaced as all other facilities in the south-east are at capacity.  There is an acute shortage of light aircraft parking in the South of England so this facility has particular regional as well as local importance.  It would be very difficult to relocate the facilities provided by Panshanger aerodrome.

 

Sport England is a statutory consultee on all planning applications for development affecting playing field land.  They have been advised of the consultation and will be responding.   It is Sport England’s policy to oppose any planning application which will result in the loss of “playing field land”.

 

The NPPF  on Page 18 paragraph 74 states:

 

74. Existing open space, sports and recreational buildings and land, including
playing fields, should not be built on unless:

 

  • An assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or
  • The loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or
  • The development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.

 

The Council has not taken these mandatory requirements into account nor identified alternative facilities.  They are obliged to do so and you should tell them they cannot zone this area for housing without following the policy including providing equivalent or better provision in the form of a new aerodrome. 

 

European Policy – An Agenda for a  Sustainable Future in General Aviation

 

You may also want to refer to the European Parliament Special Resolution of 3 Feb 09 on a Sustainable Future for General Aviation which is not mandatory for councils but which has received support and recognition from Department for Transport.  Useful extracts are:


The European Parliament having regard to the communication from the Commission of 11 January 2007 entitled "Agenda for Sustainable Future in General and Business Aviation:


13. Encourages Member States and regional and local authorities to invest in the modernisation and establishment of small and medium-sized airports, which are of major importance for General and Business Aviation;


14. Encourages the Member States to invest in specific infrastructure necessary for the operation and stationing of aircraft in the field of General and Business Aviation;


15. Encourages Member States,  as well as regional and local authorities, to involve all interested parties in consultation processes with a view to dedicating, where appropriate, potential or existing airports for use specifically by General and Business Aviation


32. Considers as essential the promotion of recreational and sport aviation, as well as of European aero clubs, which constitute an important source of professional skills for the entire aviation sector;


33. Calls on the Commission to take account of the important role that this aviation sector plays and can continue to play in the development of vocational training for pilots.


Aviation Policy Framework

 

The UK Aviation Policy Framework is still in draft but supports the infrastructure requirements which follow.  You may want to refer to it in your response but until it is adopted it has no legal force.  The most important section is:

 

Safeguarding


6.6 The NPPF makes clear that local planning authorities should “identify and protect where there is robust evidence, sites and routes which could be critical in developing infrastructure to widen choice”. This could apply to airport infrastructure.

 

Infrastructure Requirements – Section 13 and Policy CS-12

 

In Section 13 of its Emerging Core Strategy Document at para 13.1 the Council says that in order for communities to be successful, it is vital that they are well served by a range of infrastructure.  Paragraph 13.2 goes on to say that this infrastructure encompasses a wide range of services provided by both public and private sector agencies.   This must recognise the aviation infrastructure facility at Panshanger which is the only such facility in the Council’s area and is one of only 2 licensed  aerodromes in Hertfordshire.

 

In paragraph 13.3 of the Council’s Infrastructure Section:

 

Bullet point 1, lists transport infrastructure but fails to mention in this list the great asset of Panshanger aerodrome.
Bullet point 2 mentions sports, recreation and community facilities
Bullet point 3 mentions “Green Infrastructure”. 

 

The Infrastructure document ignores Panshanger Aerodrome which is relevant to all 3.  You will want to comment on these omissions and why Panshanger is important.

 

The NPPF  page 9 Paragraph 29 indicates the need for people to have a real choice about how to travel; and this should include by light aircraft. Paragraph 30 goes on to say that encouragement should be given to solutions which support reductions in congestion.  If a business person wishes to travel to other parts of the UK or the near continent, the best way is to use a light aircraft to avoid the congested roads, flying from a small aerodrome such as the one the council intends to close. The Council should be promoting the aerodrome as an asset, not closing it and this merits comment.

 

Also in para 13, the Council’s Policy CS 12 indicates support “for new or improved infrastructure, required to meet the levels of growth identified in this strategy”. Planned closure of the aerodrome would reduce the infrastructure to the detriment of the community.

 

The NPPF page 11 Paragraph 41 identifies the need to “identify and protect sites which could be critical in developing infrastructure to widen transport choice”. This provides a clear statement for the protection of aerodromes, such as that at Panshanger, as part of the transport infrastructure as the loss would reduce the transport choice to people in the area.

 

Protection of Critical Assets  - Section 12 & Policy CS 11

 

In Section 12 and Policy CS11of the Strategy, paragraph 12.2 refers to the green spaces, natural elements and the multi-functional uses of these spaces. The aerodrome at Panshanger is not just a series of aviation related businesses but also a large green open space that allows the sport of flying to take place and is also the habitat of many species of wild flora and fauna. Something not recognised by the Strategy.

 

Policy CS 11 on the same page covers protection of critical assets. It says the Council is committed to protecting and enhancing the borough’s natural and historic environment.  It goes further by stating that “any loss or damage to the value of these assets will be resisted and opportunities for enhancement will be supported”. This is diametrically opposite to the loss and damage that will be done if the aerodrome is allowed to be closed. According to this policy the aerodrome should be “protected and enhanced”.

 

Paragraph 12.11 states quite clearly that access to the sports pitches are essential for the creation of sustainable communities. The potential closure of the sporting facility of Panshanger aerodrome, along with all its wildlife and unspoilt green areas, would be in contradiction to this policy; the closure of the aerodrome should be removed from the plan.

 

Community Services and Facilities- Section 8 & Policy CS 6

 

In Section 8 of the Strategy  Policy CS-6 (scroll down to find it) says the council will:

 

guard against the loss of existing community facilities and will allow the expansion or enhancement of facilities. They will promote services that serve a wider area than the local neighbourhoods or villages.

 

The planned closure of Panshanger Aerodrome, which meets all of these requirements, would clearly go against that. 

 

Tell the Council that this proposal to close the aerodrome contradicts Policy CS-6.

 

The NPPF states on page 17 paragraph 70 that plans must:

 

Deliver the social, recreational and cultural facilities and services the community needs, planning policies and decisions should:

 

  • Plan positively for the provision and use of shared space, community facilities (such as … sports venues,…) and other local services to enhance the sustainability of communities …  
  • Guard against the unnecessary loss of valued facilities and services
  • Ensure that establishedfacilities and services are able to develop and modernise in a way that is sustainable, and retained for the benefit of the community; and 
  • Ensure an integrated approach to considering the location of housing, economic uses and community facilities and services.

 

As a valued service providing social, recreational and sporting facilities, Panshanger aerodrome should be encouraged rather than destroyed.

 

Please draw on this when commenting.

 

Settlement strategy – Section 6 & Policy CS 3

 

In Section 6 at the end of the Policy CS 3 box the Council states that:

 

 “Development which would …… result in a reduction of its services and facilities which would be to the detriment of the local community will be resisted”.

 

However the plan to close Panshanger would destroy the very services and facilities of Panshanger aerodrome it proposes to resist.

 

The NPPF on page 11 Paragraph 41 identifies the need to:

 

identify and protect” sites “which could be critical in developing infrastructure to widen transport choice”,

 

The proposed closure of Panshanger aerodrome contradicts the statement in the NPPF.

 

Please comment on both these contradictions

 

Well done for getting this far

 

If you are writing a letter please send it to:

 

Sue Tiley
Head of Planning Policy
Welwyn Hatfield Borough Council
Council Offices, The Campus
Welwyn Garden City
AL8 6AE

 

If you are sending her an email send it to planningpolicy@welhat.gov.uk

 

And if you have been commenting directly to the website remember to submit your views.  You can always log on again and edit them.

 

Thanks for your support for the sport of light aviation.

 

The Light Aircraft Association

14 December 2012