Government planning policy is being amended in a way that will force local authorities to approve applications to build houses on our airfields. We are indebted to John Broad for spotting this and raising the alarm.

The Office of the Deputy Prime Minister (OPDM) has recently revised the Planning Policy Guidelines 3 (PPG3), issuing Planning Policy Statement 3 (PPS3) and including a small change that directly affects us as aviators. The definition of ‘Brownfield’ in PPS3 Housing, Annex A, has been rewritten to define airfields, and all the land within the curtilage (the surrounding area), as Brownfield instead of Greenfield. As there is an emphasis on Brownfield development at present, and much formerly-industrial brownfield land is contaminated (unlike airfields), you will see that this change presents a severe threat to airfields. Indeed, the recently successful defence of Bicester Airfield used the exclusion of airfields from Brownfield, together with preservation orders on the buildings, to ensure the relocation of a planned development.

The ODPM appears not to have consulted aviation interests nor drawn attention to the change, which is hidden in a footnote to an Annex to the PPS3 statement. You may want to write to the ODPM to express your opposition to this change. Political pressure is always helpful in these matters and you may also want to write to your MP. Contact details are at the end of this note together with relevant extracts of the old and new policy documents and links to the source documents.

If you would like you to make representations to the OPDM to oppose this change in the definition of Brownfield in PPS3, here are some points you might like to make:

* The few remaining airfields in the UK are under threat from councils and developers and this clause has been effective in protecting these amenities

* Because it would increase the value of the land, the effect of this change would be to close all airfields used for recreational and sport purposes

* These airfields are not eyesores left over from an industrial past, which need cleaning up

* Many of these airfields are grass rather than paved, and much of the land which is not runways or taxiways is used for agriculture – development of them will be tantamount to development of the greenbelt

* Airfields are attractive to developers because they are uncontaminated and therefore much easier and cheaper to develop, with a consequent increase in profit margin

* The focus of brownfield development should not be on predominantly rural facilities such as these, but on the contaminated remnants of industry which desperately need cleaning up

* Most small airfields provide a sport and recreational amenity that should be preserved.

To make your representation, you should write to Alex Lessware:
by email: pps3consultation@odpm.gsi.gov.uk
by fax: 020 7944 3949
or by post:

You can obtain contact details for your MP from this link:
http://www.locata.co.uk/commons/

Extracts and Links:

The current PPG3, Annex C defines the area to be considered brownfield thus:

The curtilage is defined as the area of land attached to a building. All of the land within the curtilage of the site (as defined above) will also be defined as previously-developed.

However, this does not mean that the whole area of the curtilage should therefore be redeveloped. For example, where the footprint of a building only occupies a proportion of a site of which the remainder is open land (such as at an airfield or a hospital) the whole site should not normally be developed to the boundary of the curtilage

This wording is significant and was used to stop the whole of the former RAF Bicester airfield from being considered brownfield and zoned for housing, thus saving it from closure. With the proposed amendment, the airfield would have been lost. The new definition in PPS3 Annex A says:

The definition of curtilage is subject to the interpretation of the Courts and regard should be had to case law. All of the land within the curtilage of the developed land will also be defined as previously-developed.

Note that the exclusion for airfields has gone and the whole land area is now brownfield and councils will be obliged to approve applications to develop.