[flyinfox]

planning@sstaffs.gov.uk
RE: 20/00893/OUT Wolverhampton Halfpenny Green Airport, Crab Lane, Bobbington DY7 5DY
I OBJECT to the above proposed development for the following reasons:

1. MCR have made no guarantee that they will invest in airport improvements once the housing development has been completed. There is no legally binding commitment that they, or any other company that may take on the development in future, will provide the promised airport improvements.
2. The Business case gives a false indication of the airfield’s revenue. MCR have deliberately diverted rental income from airfield related businesses to a separate company called Wolverhampton Airport Properties Ltd. These businesses would not be able to operate with out the airport so therefore must be considered airport revenue. This is a deliberate attempt to make the airport appear less profitable and inflate the expenditure required to justify the housing development.
3. The business case fails to consider the construction of “T” hangars to meet hangarage demand and increase revenue. This model is a proven idea that provides immediate return in investment and is in use at many other airfields in the UK. It enables the demand for hangarage to be met by allowing aircraft owners to buy individual hangars that are designed for single aircraft occupancy. The “T” hangar design enables very efficient use of land as they nest together back-to-back. They are 5m high and are very low cost in comparison to the proposed communal hangars. The “T” hangar model needs no investment by the airport as aircraft owners pay for construction. The airport then receives an immediate revenue from ground rent paid by aircraft owners. The majority of aircraft that use the airport will be suitable for this type of hangar and it is a preferred solution for the majority of aircraft owners and it offers greater security for their aircraft. It is estimated 100 more aircraft could be accommodated on the proposed housing site. Moving aircraft that are suited to this type of hangarage would free space in existing communal hangars so that additional larger multi engine aircraft could be accommodated.
4. The proposals are contrary to South Staffordshire Council core strategy policy 12, and policies EV13 and EV14 - [see note (1) below]
5. The proposals are contrary to the National Planning Policy Framework paragraphs 95, 104(f), 118(c), 133, 145(g) and 170(e) - [see note (2) below]
6. The proposals are contrary to section 4 of the government’s Aviation Policy Framework – [see note (3) below]
7. The proposals are contrary to restrictions requested by the Airport Operators Association – [see note (4) below]
8. The proposals are contrary to comments made to the Secretary of State by the All-Party Parliamentary Group on General Aviation – [see note (5) below]
9. The proposals are contrary to guidance issued to local planning authorities by the General Aviation Awareness Council “Introduction to Airfield Safeguarding for Local Planning Authorities” dated January 2015 – [see note (6) below]
10. The proposals are contrary to the recommendations of the Air League – [see note (7) below]
11. The proposals are contrary to national policy statements on airport safeguarding e.g. by expert planning consultants Lichfields and Landmark Chambers – [see note (8) below]

Notes
(1) SSC core strategy at policy 12 and policies EV13 and EV14 will [only] support proposals for development directly related to the general aviation role of the airport (which these proposals are not)
(2) NPPF planning guidance notes state [paragraphs]:
• [95] Planning decisions should promote public safety (which building houses within an airport safety zone does not)
• [104(f)] the government’s General Aviation Strategy: planning policies should recognise the importance of maintaining a national network of general aviation airfields, and their need to adapt and change over time – taking into account their economic value in serving business, leisure, training and emergency service needs, and the Government’s General Aviation Strategy (which SSC core policy 12 does)
• [118(c)] brownfield sites for development should be within settlements (which this site is not, as defined in SSC core strategy inset plan 43)
• [133] Fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open (which 112 houses in the Green belt would contravene)
• [145(g)] Re-development (of previously developed land) should not have a greater impact on the openness of the Green Belt than the existing development, and Re-development should not cause substantial harm to the openness of the Green Belt (which 112 open market and/or affordable houses does)
• [170(e)] Planning authorities should prevent new development proposals that carry a risk from unacceptable levels of air and noise pollution (the occupiers of 112 houses would be at unacceptable risk of air and noise hazards)
(3) The Aviation Policy Framework states that Local Planning Authorities should identify and protect general aviation sites from incompatible development proposals and:
(a) follow a balanced approach to secure the benefits of general aviation (which building houses within an airfield boundary does not) and
(b) should be the subject of local collaboration (including adjacent planning authorities)
(4) The Airport Operators Association has made a request to the government for restriction of building new houses near airports to limit the number of noise complaints
(5) The All-Party Parliamentary Group on General Aviation has written a letter to the Secretary of State for Housing, Communities and Local Government, Rt Hon Robert Jenrick MP dated 25 August 2020
[see https://generalaviationappg.uk/wp-conte ... inal-3.pdf ] which includes recommendations that:
• Airfields should be considered as infrastructure and/or “growth” zones in the current planning review and not “renewal” (which otherwise would leave this site vulnerable to inappropriate development)
• New NPPF provisions (para 104(f)) for general aviation should obligate local planning authorities to shape their policies to maintain the national network of airfields and the need for them to adapt and change over time (e.g. by refusing applications for development which is not aviation related)
(6) The General Aviation Awareness Council guidance is at https://www.gaac.org.uk/wp-content/uplo ... -Plans.pdf and includes recommendations for local plan policies to protect airports from inappropriate development (which SSC core strategy does at policy 12) and to follow NPPF guidance at para 104(f) in decision-making
(7) The Air League strongly welcomes the government’s recognition in its National Planning Policy Framework para 104(f) of general aviation airfields and the need for their strategic and local importance to be taken into account in planning decisions and development plan policies and recommends that government policy should recognise the need to protect existing airfields from residents in particular NIMBYs new to an area who seek to close them down including the argument that aircraft make noise
(8) Expert planning consultants are of the opinions that:
(a) Local planning authorities cannot allow new (August 2020) permitted development rights to apply within a 3km radius of existing airport boundaries
(b) LPAs must take into account the new NPPF para 104(f) in safeguarding airports (e.g. from inappropriately close or high buildings or from activities in or around buildings that could distract pilots or cause bird strikes)
(c) New NPPF paras 136-137 make criteria for “exceptional circumstances” to change Green Belt boundaries clear (which prevents the application site, which is a previously developed area in the Green Belt, from being classified as a “rural exception site”)
(d) Proposals for inappropriate development in the Green Belt should be refused

For the above reasons, it is my opinion that the proposed mixed use development, by including the enabling development of 112 dwellings, is inappropriate for the location and the application should be REFUSED.

[Flyingfemme]

Excellent work, flyinfox.

[Aerials]

flyinfox, what a wonderfully detailed piece of work that is, it must have taken many hours of research to compile.

I have a fondness for Ha'penny Green and wish to see it remain open for as long as we have flying machines. Thank you very much for your work and I hope it has a very great influence on the planners at SCC to say no to this type of 'development'.

[CloudHound]

What about unintended consequences?

Successfully petitioning the LPA to find against the applicant and deny them their PP won't be the end. An appeal to the Planning Inspectorate follows which can be like a game of poker in terns of stake money.

And what if eventually we win ( who we is let's pass for the moment) what does the land owner do.

Blight is the effect on going concerns when the people who own the land don't want it used for what it's used. At best the place struggles on with no investment and then what?

I still see some aspiration in the Master Plan which has yet to appear on here. Could there be a mixed use future symbiotically beneficial to all?

[Paul_Sengupta]

And what if eventually we win ( who we is let's pass for the moment) what does the land owner do.

Then he sells it to a consortium of pilots for £35 and a packet of crisps and we keep it going as an airfield.

Same with Old Sarum...

[Lefty]

..
The NDB ident remains ‘WBA’

I wonder if that at Iqaluit (if it's still there) is still 'FRO'

Yes everything is still FB. The airfield is CYFB, the ILS is I-FB and the VOR is YFB. The NDB has been renamed YFY.

[Nige321]

Relax - Gavin's on the case...

https://www.gavinwilliamson.org/news/gavin-objects-halfpenny-green-airport-development?fbclid=IwAR1s_QsPgkyvHNrRkXdkThnBIMOKKkbfIVtt8CHY3FbR8ejGr0soinfw6k8

Gavin Williamson, MP for South Staffordshire, has objected to proposals of 112 dwellings on the site of Halfpenny Green Airport in Bobbington.

MCR Property Group, who own the airfield, originally submitted plans for development on the site in 2019. Plans have now been resubmitted, which include the erection of three new hangar buildings, replacing existing retail buildings as well as refurbishing airport infrastructure.

Gavin has written to South Staffordshire District Council to highlight the concerns of local residents. Constituents have referred to the detrimental effect on the environment, rising noise and traffic levels and pressures on local services.

The airfield has daily air traffic throughout the day, which holds historic importance for users and local residents who use the facilities on offer.

Commenting on the plans, Gavin said: “This is the second time that these plans have been put forward and there still seems to be no regard for the current residents of Bobbington. Due to the lack of public transport, there will be increased car usage on the narrow roads, many of them are unlit.

Development on this scale will undoubtedly ruin the very nature of the airport and take away the unique feel. I will continue to work with local residents and the Parish Council to stand up for the interests of the residents of South Staffordshire.”

To make any comments in relation to the planning application, visit the South Staffordshire District Council planning portal. Application Number is 20/00893/OUT.

[gregorp]

According to AOPAUK magazine (page 12) received today, MCR have put Halfpenny Green up for private sale at £7.5m. Pilots club together?

[Paul_Sengupta]

When it goes down to the "normal" airfield price of about £800k-£1.2m then I'll chip in a grand.

Obviously as part owner I'd expect free landings!

[Sooty25]

Obviously as part owner I'd expect free landings!

If you held shares in Tescos, would you expect a free loaf of bread?

[Charliesixtysix]

When it goes down to the "normal" airfield price of about £800k-£1.2m then I'll chip in a grand.

Obviously as part owner I'd expect free landings!

I’m sure you are joking Paul, but market price is market price.

It only needs a ‘club’ of between eight and ten shareholders to put up that kind of money to make it work...or sixteen to twenty at half that investment....or.... etc.etc.

Unless, or until, the GA community puts serious money into land ownership when the opportunity arises, the benefit of owner-occupier security of tenure will rarely be enjoyed, and ultimately airfields will disappear to other users who are prepared to spend the cash.

[flybymike]

According to AOPAUK magazine (page 12) received today, MCR have put Halfpenny Green up for private sale at £7.5m. Pilots club together?

No less than 26 airfields currently listed as at risk according to that article.
Many of them fairly substantial concerns.

[johnm]

The fundamaental problem goes back to an error, never fixed, which had airfields designated "brownfield sites" when the intention was for existing developed curtilage to be brownfield.

The way forward is to lobby MPs and Ministers to get airfields designated as brownfield correctly and also be established for industrial development not housing development. The economic case is sound and everybody wins IMHO. I have written to Grant Shapps with this and to my MP. I'm not holding my breath, sadly.

[skydriller]

The way forward is to lobby MPs and Ministers to get airfields designated as brownfield correctly and also be established for industrial development not housing development.

Isnt that the problem? Most airfields being built on are actually a big green space, often a large grass field with lots of wildlife on it, with possibly a small number of buildings and sometimes a strip of tarmac/concrete. Its not like they are putting houses on the likes of Heathrow...

[allout]

The fundamaental problem goes back to an error, never fixed, which had airfields designated "brownfield sites" when the intention was for existing developed curtilage to be brownfield.
.............., sadly.

I never believed this to be an error.