November 2019
Notes of Flightpath Watch Ltd public meeting
Held on 29th October 2019 at Petts Wood Methodist Church
Unless otherwise explained within the document,
abbreviations used are listed and explained at the end of the document.
Robert Pattullo (FPW Ltd Chair) welcomed the
audience and thanked everyone for attending.
- Airport Monitoring Officer
(AMO)
- LBB has recently appointed an AMO. Her name is Ashley Kolo. She is a graduate intern working in the Communications Team. There are no details of the job description for this post.
- FPW had invited Ms Kolo to attend this meeting but had not received a response or acknowledgement. FPW will pursue this with LBB.
- The appointment of the AMO was a condition set by LBB when they granted the additional operating hours at BHA. It has taken LBB three years to make this appointment. This delay is one of a number of items being taken up by FPW with the Local Government Ombudsman.
- Members of the audience were encouraged to communicate with their local Councillors to keep them informed of their concerns about BHA. The main complaint is that LBB is not applying pressure on BHAL to keep the promises they made when they were granted extended operating hours. FPW has made repeated requests to meet the Leader of the Council, Colin Smith, but he has not taken up the invitation.
- Peter Morgan is the relevant Portfolio Holder on the Council with ultimate responsibility for BHAL and it is he who would have political responsibility through Officers as the residents’ representative. He has stated that he would be reviewing the conditions set by LBB when the extended hours were granted and a report is expected in June 2020.
- It is important that as many people as possible record their complaints about flights to BHA. This can be done through the BHA website https://yourairport.co.uk/noise-track/.
- London Airspace Management
Programme (LAMP)
- This is a recent NATS initiative, overseen by the CAA, to redesign the use of the airspace over London.
- FPW responded to the first phase of the consultation via LBB, as landlords of the airport, but our concerns were not passed on in their response to BHAL. At the next phase of consultation, FPW will respond directly to BHAL. It was noted that LBB themselves are responsible for flight paths lower than 2,500ft.
- It is recognised that LHR and LGW requirements will impact to some extent the flight paths available to BHAL but FPW feels that LBB could be stronger and stick to their promise to require flights not to overfly noise-sensitive residential areas.
- With AEF predictions of a 53% increase in passenger numbers leading to an increase in CO2 emissions of 1 million tonnes by 2050, there is concern that fuel efficiency will take precedence over residents’ concerns in determining flight paths.
- BHAL have appointed their former Managing Director, Will Curtis, to design their flight path proposals.
- It is important that as many people as possible respond to the next phase of consultations to show the weight of public opinion. FPW will advise when this will happen.
- There was a discussion about noise limits and how they are measured. Since the introduction of the extended operational hours at BHA, a new methodology was introduced, based on average measurements, which does not reflect the impact of the noise of individual planes. This was allowed by LBB in spite of evidence provided to LBB by a noise consultant, funded by FPW. This evidence was ignored by LBB.
- If BHAL does not breach the noise limits before June 2021, they will be allowed to exceed the current cap of 50,000 flight movements per annum.
- Monitoring of the number of flights, their noise levels and whether they carry fare-paying passengers (which is not allowed by the Lease) should be the responsibility of the AMO (see item 1).
- Independent Commission on
Aviation Noise (ICCAN)
- This was created because the CAA cannot be completely independent with regard to aircraft noise. Among others, one of their initial conclusions recognises that, whilst larger airports are Government-regulated, smaller local airports (like BHA) are supposed to be regulated by their local Council and are generally not subject to the same restrictions.
- FPW will maintain contact with ICCAN and is considering making them aware of the manipulation of the survey results at the time of BHAL’s campaign for the additional hours in 2015 (see item 4).
- There was a discussion about whether BHA has to continue as an airport. It could provide a substantial site for housing. The site is not well served by local transport infrastructure and BHAL would welcome enhancements, especially to the road network. The possibilities of introducing a link from Junction 4 of the M25 and of widening Shire Lane were discussed.
- Consultation of Bromley
residents in 2015
- Further to the point discussed at item 3.2, the audience was reminded that in 2015 LBB undertook a survey to assess public support for increasing the hours of operation at BHA. The survey results indicated that 79% of local residents were in favour of the proposed changes.
- At the time, FPW submitted a Freedom of Information Act request to LBB for the details of the responses. FPW’s analysis of the data showed that just 15 individual internet addresses provided 7,101 of the total online responses, representing 0.25% of the 6,071 individual internet addresses which responded, yet represented 25% of the total input. If the data had been cleaned of the “false” data, the survey would have shown that the weight of opinion among respondents would have been against the additional hours.
- BHAL did acknowledge the accuracy of FPW’s analysis and the Leader of the Council at the time, Stephen Carr, instructed the Council to disregard the results, but the vote still went in favour of BHAL.
- Even now the incorrect information is being distributed widely and is used in BHAL marketing documentation by BHAL and in its accounts (see item 6).
- Rental Income from BHAL to
LBB
- There are clauses in the Lease between BHAL and LBB that allow for LBB to receive 50% of the profit or notional profit of relevant development or redevelopment of new or refurbished buildings on the airport site, up to a maximum of £1.5m per annum. The profit means such sum as represents the difference between the premium paid for the lease and the aggregate of development expenditure. These clauses were intended to allow LBB to benefit financially from the development potential of the site.
- To date, in spite of many developments having taken place including one of significant size (the Rizon hangar), questions to the Council have revealed that LBB has not received any such income. A further written response to the questions is awaited.
- The rental income received by BHAL from these developments is paid to a company, the Biggin Hill Hangar Company Ltd (BHHCL), which was originally set up to build and commission a state-of-the-art hangar at BHA, but the company’s stated objective has change to that of “letting an aircraft hangar and aviation support centre”. The Rizon development was funded by cash injections from a Qatari enterprise which has a 10% interest in BHHCL. BHHCL is recorded as owing the funders in excess of £18m. No interest is being charged or accruing on the balance.
- It was also noted that BHAL
has recently received planning permission from LBB for a hangar of up to
5 acres in size, so there is significant potential for further income to
LBB, greatly in excess of what is currently being paid to them (~ £300k)
in annual rent. The audience was reminded that at the time of
applying for the additional hours, BHAL promised that, as well as 2,300
extra jobs and other pledges, LBB would receive £2.3m pa from the airport
by 2030. Three years on, there is no evidence of these pledges
being kept.
- London Centre for Aviation,
Technology and Enterprise (LoCATE)
- LoCATE is the case for growth prepared by BHAL. A copy of the brochure was shown to the audience. It is published by Farrell’s Advertising Agency, owned by Sir Terry Farrell.
- The document contains inaccurate claims that BHAL’s plans for the airport won the support of 79% of local residents. As discussed under item 4, FPW has proved that these claims are incorrect.
- A letter has been sent to the Chief Executive Officer of BHAL, David Winstanley, asking him to withdraw the claim from the document and publish a retraction. A reply is awaited, and if he does not agree to these requests, FPW is considering taking the matter up with the Advertising Standards Authority (ASA).
- Plea for Action
- Members of the audience were encouraged to join FPW, if they had not already done so, and to share the details discussed at the meeting with their friends and neighbours, to enlist their support too. Councillors are more likely to be influenced by a loud and consistent message from many residents in addition to the voice of FPW.
- Copies of recent letters sent to all Councillors on the current status of BHAL’s pledges and the fulfilment of LBB’s conditions are available on the FPW website.
- Other business
- Another issue which is being pursued relates to the Biggin Hill Airport Consultative Committee (BHACC), which does not fully comply with all Government guidelines for ACC operations. For example, the BHACC should have been informed in advance about the proposals for the 5 acre hangar but this did not happen.
- The audience agreed that FPW needs to make more use of social networking to spread its message. In turn, FPW made a plea for more help with the technical expertise needed to do this.
Robert Pattullo thanked the audience for attending
and said it had been a useful dialogue.
Abbreviations
AEF AMO BHA BHAL CAA |
Aviation Environment Federation Airport Monitoring Officer Biggin Hill Airport Biggin Hill Airport Ltd (the Management Company) Civil Aviation Authority |
FPW LBB LGW LHR NATS |
Flightpath Watch Ltd London Borough of Bromley London Gatwick Airport London Heathrow Airport National Air Traffic Services |
———————————————————————————————————————-June 2019
Dear Councillor
As you may be aware, Biggin Hill Airport is planning for further expansion, in spite of not having yet kept
most of the pledges it made in order to obtain a 24% increase in operating hours.
We are very concerned at noting that the Council is making no attempt at ensuring compliance and is not
exercising duty of care towards its residents. We are therefore writing to bring to your attention the fact
that pledges and conditions of approval appear to have been “forgotten” and to ask you, as councillor, to
intervene and rectify this untenable situation.
You are aware that in 2015 Biggin Hill Airport applied to Bromley Council as Landlord for an extension in
operating hours. The extended hours have been in operation since April 2017 and are now longer than
those at City Airport, Northolt Airport and Farnborough Airport, which obviously attracts here air traffic at
unsociable hours when other airports are closed. Please see the table below for comparison.
Northolt Airport Farnborough Airport City Airport Biggin Hill Airport
08.00 to 20.00 on
weekdays
08.00 to 15.00 on
Saturdays
12.00 to 19.00 on
Sundays
12.00 to 19.00 on
Bank Holidays
Total per week: 72.00
07.00 to 22.00 on
weekdays
08.00 to 20.00 on
Saturdays
08.00 to 20.00 on
Sundays
08.00 to 20.00 on
Bank Holidays
Total per week: 99.00
06.30 to 22.30 on
weekdays
06.30 to 13.00 on
Saturdays
12.30 to 22.30 on
Sundays
09.00 to 22.30 on
Bank Holidays
Total per week: 96.50
06.30 to 23.00 on
weekdays
08.00 to 22.00 on
Saturdays
08.00 to 22.00 on
Sundays
08.00 to 22.00 on
Bank Holidays
Total per week: 110.50
NB – The weekly totals in this table do not consider Bank Holidays, which are however included for information
Prior and during the application process, Biggin Hill Airport made 9 pledges to the Council and the
residents. Only the two least helpful ones (Pledge 2 and Pledge 8) have been kept, as noted below.
Pledge 1 – No increase in flights over 2010 levels
This was defined as a cap of 50,000 movements per year. However, the Council accepted a distorted
definition when it came to transcribe the cap into a formal agreement. It linked it to average noise
contours. Only if the number of flights is higher than 50,000 AND some average noise contours are
breached, the Airport would negotiate new parameters with the Council. Is this a cap? In fact, this
definition could cause the number of movements to escalate exponentially. An eminent acoustic expert
(Stephen Turner), who was a government advisor on aviation noise for fifteen years, was appointed by
Flightpath Watch. He stated that “if all the aircraft using LBHA were to become 3 dB less noisy, the
movements could be doubled and the same contour area achieved. It would seem that there was no
difference in impact, but it is highly likely that those living nearby would not perceive the noise reduction
from each individual movement but would notice the doubling of movements and be adversely affected by
it.”(ST Acoustics, Nov. 2015, 3.6).
The Council were provided with the report by ST Acoustics but decided to disregard it. The result is that
there is no 50,000 cap on movements.
Pledge 2 – No new runways – we don’t need them
In fact, the airport closed the smaller of its two runways but this was not beneficial to residents. Runway
R29/11, has now been converted into a parking area for Bombardier aircraft and the flying schools (the
main users of R29/11) have been incentivised to leave. The airport is now replacing light aircraft with large
aircraft. The noise and visual impact is greater for residents, on arrival but also on take-off, which requires
considerable more thrust.
For your information:
In 2016 there were 7,957 jet-charter movements
In 2018 there were 10,539 jet-charter movements (+32%).
Pledge 3 – No commercial airlines – we want to stick to business aviation
Some of you may remember that the Council took the Airport to court in 2000 to have certain clauses of
the Lease clarified in view of certain breaches by the Airport. The Judge at the Court of Appeal found for
the Council and excluded from Business Aviation both i) the sale of individual tickets – only chartering of jets
by one individual or company for its own business purposes being allowed, and ii) flights to holiday
destinations. However i) a request to the Council to monitor how tickets are sold on the large transatlantic
flights that now operate at the airport has been rejected and ii) we know that flights to and from holiday
destinations continue, as demonstrated by Flightradar 24, a well-known flight tracker website.
Pledge 4 – No expansion beyond the existing airport boundary
In September 2013, Regional Airlines, the parent of BHAL, bought the Milking Lane Farm, located at the
Northern end of the runway. During a question-time session at the Council, we asked for the map of the
“existing” boundary of the airport. Cllr Carr (a staunch airport supporter) stopped the officer who was
attempting to reply, from showing the map. It is fair to assume that the boundary of the airport has been
extended to incorporate the Milking Lane Farm.
In addition, the airport has asked for certain green-belt areas within the boundary to be excluded from the
green belt. Some areas were released in the new local plan, but very recently a new massive hangar of 5.2
acres has been approved by the Council on green-belt land that had not been released. Moreover, this
approval was granted in spite of the hangar not being built by Biggin Hill Airport Limited but by a tenant, a
factor that ought to have invalidated Permitted Development Rights and required the plans to be
presented to a planning committee. We are also aware that the Planning Officer initially contacted by the
Airport had rejected the application.
Pledge 5 – New noise monitoring equipment with full public access to the data, and new noise limits
enforced by the Council
In exchange for the considerable (24%) increase in operating hours, BHAL offered to implement a noise
monitoring and track-keeping system, accessible to the public. The system is now in operation but:
1. The noise limits accepted by Bromley Council are so wide and averaged over 16-hour periods that they
are virtually ‘un-breachable’. The Noise Monitoring part of the System is therefore worthless.
2. The track-keeping system does not appear to show the correct location of most flights. Residents who
have experienced a flight right overhead, find that the system records it some 500/600 metres away.
The airport is aware, as is the Council, but residents’ empirical observations are not listened to.
3. One of the conditions for approval of the new hours was that a council officer would be employed to
monitor compliance with the requested conditions – there is no sign that this officer is going to be
appointed.
Pledge 6 – New approach procedures keeping planes higher for longer
The intention was to keep aeroplanes above 3000 ft for longer before they started their descent. A trial
was announced in March 2015 but came to nothing. Now very large aircraft overfly residential areas North
of the airport at less than 2000 ft from the ground. Over the hospital and the Farnborough and Crofton
areas they are at less than 1000 ft from the ground.
The airport also promised a new route to the Southern end of the runway (R03) that would reduce the
impact on the communities to the North of the airport by some 30%. As at today’s date, there is no sign of
this new route being approved by the CAA, let alone implemented.
Pledge 7 – Preventing light aircraft flying over residential areas
Helicopters are classified as small aircraft in the MIL, the document that the Airport itself wrote and is now
attached to the Deed of Variation of the Lease. That document defines a small number of residential areas
that ought to be avoided by light aircraft but they are not. Helicopters are increasing in numbers and do
not respect the noise-sensitive areas listed in the MIL.
For your information:
In 2016 there were 2,677 helicopter movements
In 2018 there were 3,613 helicopter movements (+35%)
Moreover, with the relocation of the flying schools, training circuits by light aircraft have been replaced by
large aircraft, training or testing, circling over residential areas every three or four minutes, sometimes for
hours, at high speed and very low level. The effect is devastating for residents’ homes: these circuits are
extremely noisy, scary and downright dangerous. This practice was stopped for a period, but it appears to
have started again.
Pledge 8 – Annual Festival of Flight protected
The Festival of Flight is continuing, for now.
Pledge 9 – A new aviation training college
Given that this was advertised by the Airport, we all expected BHAL to build and run the aviation college.
However it now appears that it is going to be paid for by the tax-payer and run by Bromley College, with the
Airport only contributing aviation training.
In addition to the funds provided by the GLA, we note from one of the minutes of the Airport Consultative
Committee that Bromley Council has undertaken to contribute £1 million for the College. However, BHAL
has expressed the view that “this should be used on road improvements to make the site viable”. As we
know from a recent LoCate document “A Case for Growth”, road infrastructure is one of the airport’s main
requirements, so access to the college may not be the real objective of the Airport’s request for public
funding.
In the next letter (we are only planning one more), we will be analysing how the conditions imposed by the
Council (some overlapping the Airport’s pledges) have proved equally unsatisfactory.
We hope you will understand that, after more than two years from the implementation of the extended
hours and many reminders to Council members and officers, residents are becoming increasingly frustrated
at the Council’s unwillingness to keep its promises to the affected residents. We trust you will agree that
this is not acceptable and that you will intervene to ask for the enforcement of all pledges and conditions.
Thank you very much for your attention.
Kind regards
Robert Pattullo
Chairman
Flightpath Watch Ltd
Dear Member
May 2019
Last year, members of Flightpath Watch argued with the Council for several months that, below
2500 feet, it had the powers to move training or testing circuits by aircraft to open countryside, so as
not to disturb densely populated residential areas, particularly during the weekend.
Training circuits by small aircraft have traditionally used Plan B and Plan C in the map below (taken
from the airport website https://www.bigginhillairport.com/wp-content/uploads/2012/04/BHAFlight-
Routes.pdf ). Plan C became obsolete when runway 29/11 was closed to the flying schools
and given to Bombardier for their own parking and other purposes.
The real problem however started when training by the small aircraft of the private flying schools
was replaced by training on the much larger aircraft now in use at the airport and by testing of all
types of large aircraft by the servicing companies now based at the airport (Bombardier for
example). Those incessant circuits overflying our homes at low level by very large aircraft, every 3
minutes for hours, became unbearable, scary at times and downright dangerous. After several
exchanges with the Council, such circuits appeared to stop. With the new Chief Executive Officer at
the airport, they have started again. The example below happened on Saturday 27th April and lasted
from 14.10 to 15.22 – Not a pleasant afternoon in the garden!
Planning laws give local authorities the power to design and control flying routes below 2500 ft by
imposing plannig conditions, mainly via section 106 of planning laws. Bromley incorrectly refutes
this.
Initially Council officers were convinced that all routes, even below 2500 ft, are controlled by the
CAA, which is not true. The CAA has confirmed repeatedly and unequivocally that below 2500 ft
(Class G), airspace is unregulated and not part of the CAA’s responsibilities. The use of airspace
below 2500 feet is regulated by the airport during opening hours and not regulated at all after the
airport is closed. We leave aside, for the purpose of this newsletter, the dangers that unregulated
airspace causes (terrorism, for instance) and focus on the Council’s responsibility.
Having had to accept that they had been incorrectly informed with regard to the design and control
of routes below 2500 feet, Bromley now states that operations at Biggin Hill Airport are determined
by a Lease, not by planning laws. This is again not completely correct. There are opportunities that
the Council could use to intervene and mitigate the misery of the residents affected. We have
written to the Aviation Environment Federation, of which Flightpath Watch is a member. They
replied: “…. More importantly, perhaps, is the attitude of the local authority […] irrespective of the
lease, this shouldn’t prevent Bromley from seeking additional opportunities to control activities
through the planning system. It does of course require a planning application but there have been
several over the years. This is how Farnborough operates – the s106 has a clause that requires
regular monitoring and reporting. It could be introduced at Biggin Hill but it would require both the
willingness indicated above and the opportunity.” (29.11.2018)
It is sad to see how Bromley has so little interest in protecting its residents. Now that the circuits
appear to have started again, we need to insist with the Council that it has to exercise duty of care.
MEMBERSHIP RENEWAL
As mentioned in our April Newsletter, the annual renewal fee is now due.
It is £10 for a year.
We hope you appreciate the amount of research and lobbying that our volunteers’ effect
on a regular basis. Their time and effort is totally free, but access to expert advice
through associations such as the Aviation Environment Federation is vital.
The only funding, we have is through membership fees and donations.
We count again on your support. The application form with details of how to pay is attached. THANK YOU
—————————————————————————————————————-
April 2019
Dear Member
Is this the quiet before the storm? Flightpath Watch has been keeping an eye on events at the airport and
two unravelling and possibly entwined items are cause for concern.
First, you may have seen in the local press that Will Curtis has resigned as the Airport Managing Director
(effective 31st March 2019) and has been replaced, with the enhanced title of CEO, by David Winstanley,
formerly chief operating officer of Birmingham Airport.
Second, it has been documented many times over the past 25 years that Mr Walters, the leaseholder of the
airport, has aspirations to run scheduled services. This aspiration was seconded by the previous Leader of
Bromley Council, Stephen Carr (as reported in the January 2013 minutes to the Airport Consultative
Committee), in spite of the Council having spent a considerable amount of taxpayers’ money to prove
through the High Courts that this is not admissible under the Lease. We trust that the new Leader of the
Council will be more respectful of undertakings, open or implied.
In 2015, Mark Bowen, legal officer and Director of Corporate Services at Bromley Council, wrote that, by
virtue of law s84 of the law of Property Act 1925, the Airport has the right to ask for a change to the Lease
after 25 years of signing (i.e. May this year). We know, from talking to individual councillors, that
scheduled flights would be the ultimate goal if the Lease were to change. Flightpath Watch has however
obtained a more accurate, albeit currently unofficial, legal opinion from the property partner of a major
London firm, which contradicts Mark Bowen’s interpretation because he had overlooked subsections s84
(11) and (11A) of the Act as amended in 1969. The effect of the 1969 amendment is to disapply s84 in the
case of restrictions in the use of any land as an aerodrome when such restrictions are for the benefit of
public authorities.
It is worth mentioning that this is the same Mark Bowen who accepted that the Airport’s unhelpful
definition of “cap on movements” be admitted to the Deed of Variation of the Lease. As explained in
previous letters (June 2018 being the latest on this topic), the Council made a cap of 50,000 flights a year a
condition of approval of the extended hours. However, the definition of the cap as transcribed in the
document forming part of the Deed of Variation states that the cap on movements is only applicable if
there is a breach to the very wide and averaged noise parameters (which are virtually un-breachable)
granted to the Airport. An eminent acoustic expert appointed by Flightpath Watch, who warned the Council
to no avail, stated that “if all the aircraft using LBHA were to become 3 dB less noisy, the movements could
be doubled and the same contour area achieved. It would seem that there was no difference in impact, but
it is highly likely that those living nearby would not perceive the noise reduction from each individual
movement but would notice the doubling of movements and be adversely affected by it.”(ST Acoustics, Nov.
2015, 3.6).
We are therefore very wary of how the Council’s legal officers may apply their interpretation of concepts
and laws.
We are now in 2019 and the Airport has appointed a new CEO from a national airport. It could be that the
Airport’s campaign for the extension of the hours (led by Will Curtis) has been discredited in so far as none
of the material promises made by the Airport has come true (see Flightpath Watch Newsletter dated
November 2018), and the Council is aware of it, or it could be that the Airport is indeed intending to
challenge the Lease again and apply for scheduled flights to be allowed. In any event, fresh blood in the
person of David Winstanley was probably needed to tackle the next challenge.
The question is, are we residents ready to oppose the next threat to our environment? We will keep you
informed as soon as we hear whether our concerns are justified.
Meanwhile, the extra charges during airport shoulder hours (early mornings and late evenings), which were
devised to discourage early and late air traffic, have been cancelled by the Airport.
Please keep reading our newsletters for more information and please renew your subscriptions (or
donations) when they become due in May. A reminder will be sent. It is your contributions that enable
Flightpath Watch to continue its research and obtain professional advice. Thank you.
Kind regards,
Flightpath Watch Ltd
—————————————————————————————————————–
November 2018
Dear Member
,
There was a good attendance at the Flightpath Watch Open Meeting held on
1st October 2018 and a lively discussion which is summarised below. There
was clear concern that further expansion at Biggin Hill Airport (BHA) presents a
threat to our environment and to our everyday lives.
Transport
Concern was expressed about the effect on the local roads infrastructure
resulting from increased activity at BHA and the extended hours. An increase
in traffic has already been evident in Shire Lane, Keston and in Farnborough
Village. The possibilities of widening of Shire Lane and / or the development of
a link road from the M25 were discussed and questions were raised about
where the funding for such projects would come from.
Scheduled Flights
In allowing the Lease to be modified to extend the operating hours at the
Airport, LBB has opened the door to the possibility of it being further changed
and the removal of the restriction on scheduled flights would be one area which
would greatly benefit Biggin Hill Airport Limited (BHAL). There was a
discussion about how much support there would be from LBB Councillors to
prevent any further changes to the Lease, particularly in relation to scheduled
flights. Because the whole borough is not impacted by development at the
Airport, it is difficult to get the necessary majority of opinion to prevent
it. Residents in those areas which are affected must convince the new Leader
of the Council that airport expansion is still a real issue for them.
Helicopters
The increasing number of helicopters flying over this area is clearly causing
some concern, but BHAL is keen to attract more business and a helicopter link
to central London supports this. Helicopter flights are unlikely to decrease.
BHAL pledges
At the time of its request to extend the operating hours at the Airport, BHAL
made a number of pledges, many of which have yet to come to fruition and
some of which were not within its remit anyway. The discussion particularly
centred on aircraft-related noise. Flightpath Watch gave assurances that it
continues to keep pressure on LBB to ensure that BHAL keeps its side of the
bargain, but so far there has been little in the way of response from LBB.
Handling of complaints
Many people expressed frustration at how complaints to BHAL had been
handled. This is also a matter that Flightpath Watch has raised with LBB.
Support from LBB Councillors
With the exception of the local Councillors in Petts Wood, the reluctance of
other LBB Councillors to engage with residents on issues regarding the Airport
is a cause for concern. Although promised as part of BHAL’s campaign to win
the extended hours, a Monitoring Officer working at the Council has yet to be
appointed and there appears to be a definite bias in favour of BHAL in
decisions.
THE FLIGHTPATH WATCH COMMITTEE THANKS YOU FOR YOUR
CONTINUED SUPPORT.
Kind regards,
Flightpath Watch Ltd
June 2018
Dear Member
You will remember that Biggin Hill Airport made nine pledges to residents when it
launched its survey in support of extended operating hours. The new operating
hours were implemented on 1st May 2017. A year later, we think it useful to look
at how many of these pledges have been kept.
Pledge 1 – No increase in flights over 2010 levels
This was defined as a cap of 50,000 movements per year. However, the council accepted a distorted
definition of this cap, so that it is only valid for five years (presumably from the date of implementation of
the new hours on 1st May 2017, but this is not clear). After the first 5 years, the cap is linked to an average
noise metric that could effectively see the number of movements escalate exponentially since modern
aircraft are becoming relatively less noisy. An eminent acoustic expert appointed by Flightpath Watch
stated that “if all the aircraft using LBHA were to become 3 dB less noisy, the movements could be doubled
and the same contour area achieved. It would seem that there was no difference in impact, but it is highly
likely that those living nearby would not perceive the noise reduction from each individual movement but
would notice the doubling of movements and be adversely affected by it.”(ST Acoustics, Nov. 2015, 3.6). It is
also worth highlighting that the January 2018 minutes of the Airport Consultative Committee put the yearly
total for 2017 at 49,457 movements.
When questioned on this point (repeatedly) by a resident, Council’s solicitor Marc Bowen finally admitted
on 23rd June 2016 that: “I would acknowledge that the test will come if at a future date the Council needs to
‘enforce’ the provision”. In spite of having been warned about this weakness in both language and
methodology when defining and enforcing the cap, the Council proceeded to sign the Deed of Variation
approving the increase in operating hours without any amendment or clarification.
THE REALITY: we have a cap that cannot be enforced.
Pledge 2 – No new runways – we don’t need them
It actually transpired that the opposite was true: the airport did not even want the second of the two
runways it had. The smaller of the two, R29/11, has now been converted into a parking area for
Bombardier aircraft and the flying schools (the main users of R29/11) have been given six months to
relocate to other airports. After all the support the flying schools, their pilots and clients, gave BHAL at the
time of the survey, they must feel truly betrayed.
THE REALITY: the airport is increasingly replacing light aircraft with large aircraft. This will help maintain the
cap for a while longer, but the substitution is not advantageous to the local residents.
Pledge 3 – No commercial airlines – we want to stick to business aviation
There are two aspects to this statement:
A) If BHAL intends to keep to business aviation, will it stop flights to holiday destinations?
B) Is BHAL intending to renounce its aspiration for scheduled flights?
A) Whilst we believe that it is the airport’s intention to avoid the cheaper end of tourism, we know that
flights to holiday destinations (Sardinia, Cote D’Azur, Malaga, Alicante, Sevilla, ski resorts, etc) are
often advertised on the Empty-Leg sections of operators such as FlyVictor or PrivateFly. This
contravenes the Permitted User Clause in the Lease, as defined in 2000 at the Courts of Appeal. While
trying to unravel certain definitions of Business Aviation proposed by the Airport, the judge stated
(clause 122): “This is all the more so when one appreciates the true extent of the “Paris” point, that it
would enable BHAL for example to operate weekend or Christmas flights to Paris which clearly have no
likely business connection whatever”. After spending considerable time, energy and money to take the
Airport to the High Courts, the Council now seems inexplicably reluctant to enforce the judgement it
fought for.
B) In October 2014, at the same time as it was making the above pledge, the Airport made a submission
to the House of Commons Transport Committee (published in March 2015), on the subject of Small
Airports (written evidence number 30, item 4.7): “The London Borough of Bromley as Freeholder, will
need to approve the forthcoming application by the tenant (BHAL) to [increase the operating hours
and] allow passengers who paid a fare to have access to the airport on a quantified basis … “ BHAL
have now obtained the increase in hours. An application for the second part of the proposal, i.e. the
introduction of fee-paying passengers (prohibited by the Permitted User Clause of the Lease as defined
at the Court of Appeal in 2000) may follow. It is then just a small step to the introduction of
commercial/scheduled airlines.
THE REALITY: Flights to holiday destinations already operate at the airport, contrary to a High Court
judgement, and we fear that scheduled airlines will come next.
Pledge 4 – No expansion beyond the existing airport boundary
In September 2013, Regional Airlines, the parent of BHAL, bought the Milking Lane Farm, located at the
Northern end of the main (now the only) runway. During a question-time session at the Council, we asked
for the map indicating the “existing” boundary of the airport to be made available. A council officer was
prepared to show it but Councillor Carr, a staunch BHAL supporter, stopped him from doing so. We still do
not have an answer to our question but it is fair to assume that the boundary of the airport has been
extended to incorporate the Milking Lane Farm. In addition, the airport has asked for certain green-belt
areas within the boundary to be excluded from the green belt.
THE REALITY: The airport is likely to have already expanded beyond the original boundary and construction
may occur on green-belt areas if the Council authorises the Airport’s request.
Pledge 5 – New noise monitoring equipment with full public access to the data, and new noise limits
enforced by the Council
In exchange for the considerable (24%) increase in operating hours, BHAL offered to implement a noise
monitoring and track-keeping system, accessible by the public. The system is now in operation but:
1. The noise limits accepted by Bromley Council are so wide and averaged over 16-hour periods that they
are virtually ‘un-breachable’. The Noise Monitoring part of the System is therefore worthless.
2. The system also allows for track-keeping of aircraft (of which there are many breaches) however the
Airport has not made the correct tracks available on the system, so that it is difficult for the average
resident to know when an aeroplane is off track. The airport’s flying routes are however available on
its website and we have become familiar with them. Even when we are sure that there is a breach, the
airport either denies it or, more recently, refuses to answer by providing a general statement.
3. The track-keeping system does not appear to be calibrated correctly. Residents who have experienced
a flight right overhead, find that the system records it some 500/600 metres away. The airport has
been alerted but is refusing to acknowledge or address the point.
4. One of the conditions for approval of the hours was that a council officer would be employed to
supervise compliance with the requested conditions – there is no sign yet that this officer is going to
be appointed.
THE REALITY: The noise-monitoring and track-keeping system appears to be a tool for the airport to silence
residents rather than for the residents to be offered protection from malpractice.
Pledge 6 – New approach procedures keeping planes higher for longer
The intention was to keep aeroplanes above 3000 ft for longer before they started their descent. A trial
was announced in March 2015 but came to nothing. Now very large aircraft overfly the hospital and
residential communities around Crofton and Farnborough at less than 1500 ft.
The airport also promised a new route to the southern end of the runway (R03) that would reduce the
impact on the communities to the North of the airport by some 30%. Two years later, on 31st May 2018,
the CAA informed us that the proposal had finally reached them but no timing has been offered for its
approval. We are informed that the analysis of the proposal will take 16 weeks once started.
THE REALITY: Planes are NOT flying higher and, because of the size of aircraft now using Biggin Hill, the
impact on residents has increased considerably.
Pledge 7 – Preventing light aircraft flying over residential areas
With the relocation of the flying schools to other small
airports, training circuits by light aircraft have reduced and
will continue to reduce. However, it appears that a new trend
has started, with large aircraft now using those circuits for
their training and maintenance testing. The effect is
devastating, as large aeroplanes have started to circle
repeatedly, at speed and at low level over the homes of many
residents, particularly in the sky over Keston and Hayes (see
image to the right).
THE REALITY: light aircraft will reduce in numbers but large aircraft flying and circling at low level are on the
increase.
Pledge 8 – Annual Festival of Flight protected
Festivals of Flights have indeed been organised every year over the past few years. The next will be on 18th
and 19th August 2018.
THE REALITY: This pledge is the only pledge being kept.
Pledge 9 – A new aviation training college
Given that this was advertised by the Airport, we all expected BHAL to build and run the aviation college. At
a recent public meeting in Green Street Green, an airport officer was still stating that “BHAL” would be
starting work in January/February 2019.
However, it is now known that:
A) the cost will be in the region of £12 million, mainly provided by the tax-payers via the GLA.
B) Bromley Council will provide at least £1 million, but it is revealing that, in the minutes of the January
2018 meeting of the Airport Consultative Committee, BHAL expressed the view that “this should be
used on road improvements to make the site viable”. As we know from a recent LoCate document “A
Case for Growth”, road infrastructure is one of the airport’s main requirements, so access to the
college may not be the main objective.
C) It is believed that Bromley would be restructuring and refurbishing the ex RAF officers’
accommodation (previously on a long lease to Formula One) and that those buildings would
accommodate the College. However, most courses would be run by Bromley College, which already
has large and well equipped premises on Hastings Road. This prompts the question of whether there
is need for more premises to be funded by the public purse.
D) In the minutes of the January 2018 meeting of the Airport Consultative Committee, the airport
expressed an interest in making use of the Formula One lands and buildings (ex RAF).
E) BHAL will provide aviation and engineering expertise.
THE REALITY: Bromley and London taxpayers will pay for the college and courses will mainly be run by
Bromley College. BHAL will add aviation and engineering expertise.
Kind regards
Flightpath Watch Ltd
April 2018
Dear Member
THIS IS A VERY IMPORTANT MESSAGE
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us using the information that you provided in order to maintain contact.
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communications
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Please help us to keep in touch. THANK YOU.
MEMBERSHIP
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yet, would you please send £10 by
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THANK YOU VERY MUCH FOR YOUR SUPPORT
THE APRIL NEWSLETTER
The local elections are soon approaching. Flightpath Watch Ltd is an apolitical group in the sense that we do
not promote any wide-ranging political policies and have members belonging to all political parties, however
we are of course keeping abreast of statements made by candidates, both at local and national level, on
matters that may affect our environment and the enjoyment of our homes. We cannot and do not want to
influence your choice on any local political matters but we list below our understanding of each candidate’s
position in the Biggin Hill ward, the most relevant, albeit not necessarily the most affected, when it comes to
development at the airport.
These are the candidates:
Julian Benington and Melanie Stevens, previous Conservative candidates but now standing as Independent,
have always been staunch supporters of development at the airport, against, it would appear, the wishes of
the people of Biggin Hill. During Flightpath Watch’s campaign against the extension of the operating hours,
which we correctly feared would have helped increase traffic of large aircraft and helicopters, 83% of the
residents of Biggin Hill who responded to our survey voted against the increase in hours, yet Julian Benington
and Melanie Stevens voted in favour. They also supported the current development of the St George’s Chapel
against wide local protest.
Linda Hewitt and Toby Sims, the new Conservative candidates, have expressed awareness that the airport
causes serious environmental issues and have criticised their own party for the treatment of the residents’
wishes on both matters of extension of the hours and the choice of the architectural design for the St
George’s Chapel. Controversially, they also stayed away from a debate organised by the Biggin Hill Residents
Association (which we understand has some 300 members), who have received a donation of £5000 a year
from the Airport since at least 2009 and often speak up in its favour. However, the Conservative candidates
have recently participated in a visit to the airport by the Leader of the House of Commons, Andrea Leadsom.
Karen Wheller and Paul Enock, representing the Green Party, have not openly pronounced themselves on
their stance on development at the airport in this instance but we are aware from our campaign against the
increase in the hours that they have spoken up against damage to the environment and sleep deprivation.
They are also aware of the plans for growth that the Airport have recently presented (this was also the topic
of our January and February newsletters).
Julian Granger and Emmett Jenner of UKIP have not mentioned the airport in their current campaign but
expressed themselves in favour of development on previous occasions.
Clive Gunby, representing Labour, has recently complained to the Biggin Hill News about the recent decision
by Biggin Hill airport to terminate the leases of its resident flying schools. His running partner is Tim Fisher.
Geoff Gossht of the Liberal Democrats sits on the General Committee of the Biggin Hill Residents Association.
It is also of interest that an employee of the airport, Colin Hitchins, is standing as a Conservative candidate in
Cray Valley West.
Whoever your preferred candidates, the points that are relevant to our cause and that you might want to
communicate to them (in other wards as well of course) are:
1. The airport has recently published its “Plan for Growth”, which includes more hangars and expansion of
roadways (please see our January and February newsletters)
2. The number of helicopters on their shuttle service from the airport to London has already significantly
increased and is likely to continue to do so as air traffic from larger aircraft continues to grow, taking the
place of the light aircraft of the flying schools and of private owners
3. The Piaggio Avanti continues to grate on residents’ ears. Given the very wide and averaged noise
measures allowed by Bromley Council, this aircraft is well within the limits, however there is a clause in
the Lease (Clause f on page 65) that allows the Council, should it receive a large number of complaints
from residents (which they already have) to ban unwanted aircraft. The Piaggio is supposed to have
been replaced by a new, less strident, model, therefore banning the old model from using Biggin Hill
should be feasible, particularly as a couple of airports in the US have already done so.
4. Bombardier have announced that their new aircraft Global
Express 7000 will now be using Biggin Hill. The picture
shows the Global Express 7000. With a wingspan of 32m
and a length of 34m, it is only marginally smaller than a
Boeing 737, which also visits the airport regularly in its
business version, the Boeing Business Jet, which is built in
the body of a commercial B737.
Although aircraft are becoming less noisy, the visual impact is obviously compensating for that. Also, we
cannot forget that Bromley Council have allowed a noise measure (the LAeq16h) that allows a doubling
of the number of aircraft at every 3db reduction in noise. We know from several experts that such a
minimal reduction in noise will hardly be noticed, while the doubling in numbers will have a considerable
impact on residents.
Considering that the cap in movements at 50,000 per annum accepted by Bromley Council is based on
the same measure, there is a serious danger that this cap is not going to be respected for long. We need
to continue to exercise pressure on the Council to keep the airport to the spirit rather than the letter of
their undertaking, which was not presented correctly to our councillors by the council officers.
Thank you
Flightpath Watch Ltd
March 2018
Dear Member
You may have noticed the recent announcement by Biggin Hill Airport to Bromley Council that the flying
schools have six months to relocate to other airports nearby (Redhill, Surrey and Damyns Hall Farm, Essex).
The move is supposed to ensure greater safety by reducing the mix of large and light aircraft, but the Falcon
Flying School, which has operated at Biggin Hill for 70 years, disputed this in an interview with the BBC
(http://www.bbc.co.uk/news/uk-england-london-43432123).
The other possible reason is that the landing fees for large aircraft can be 10 times larger than the landing
fees for light aircraft. Therefore the Airport’s aim may be to attract a larger number of business jets and
reduce the number of light aircraft. The extension of the operating hours that became effective in April
2017 marked the beginning of this important shift. Flightpath Watch had warned pilots of small aircraft
(strong supporters of the increase in operating hours) that they were promoting the end of their term at
Biggin Hill as well as causing damage to the local residents and environment. We derive no pleasure in
having been proved right.
In its message to the Council, the Airport envisages that aircraft movements will decline from around
50,000 movements per annum to about 30,000 movements per annum. Of course this may be only short
term as the gap may now be filled by large aircraft, such as the Global Express, the Gulfstream 650 and the
Falcon7X. The airport is also visited by Boeing 737 and Airbus 320, not to mention the small but irritating
(according to many comments by residents) Piaggio 180 Avanti.
It is also worth mentioning that, on 19th December 2017, the Airport commented on a 23% increase in
departures in the last quarter of 2017 compared with the same quarter in 2016. Robert Walters, Business
Development Director, stated: “In addition to a surge in corporate aviation movements, this time of year is
also popular for pleasure travel, with flights out of London Biggin Hill heading to seasonal destinations
across Europe”. We of course know that tourism is NOT allowed in the Lease and will need to return to
remind Bromley Council of this.
And now some information related to Flightpath Watch itself. Thanks to the continuing interest and
support of its members, Flightpath Watch, now Flightpath Watch Ltd, is continuing to progress and develop
in order to be better positioned to pursue its aim to protect our environment from pollution from the sky.
Two specific events are noteworthy:
FLIGHTPATH WATCH IS NOW A MEMBER OF HACAN (http://hacan.org.uk/)
Most of you probably know that HACAN was founded in the 1970s to monitor expansion at Heathrow. The
group has grown over the years and is now well reputed and considered by both the CAA and the Ministry
for Transport. It was the only campaigning group in the South East of England to be heard by the Airports
Commission.
In 2016 HACAN incorporated the group fighting expansion at City Airport under the name HACAN EAST.
Flightpath Watch will not be incorporated into HACAN but operate as an associate member. Such
association will allow us to receive vital information on all aviation matters and also to have our area
represented in discussions about the impact of Heathrow on residential areas.
As we explained in our November Newsletter, our area is affected by the stacking of large aircraft circling at
low level before initiating their descent into Heathrow. Such stacking is particularly noisy and intrusive in
the early hours of the morning, sometimes from 4.30 am, when large jumbo jets from across the Atlantic
circle as low as 5000 feet. We believe that HACAN will help us to gain visibility in discussions about
flightpaths at Heathrow when so far we have had none.
FLIGHTPATH WATCH IS A MEMBER OF THE AVIATION ENVIRONMENT FEDERATION (AEF)
(https://www.aef.org.uk/)
AEF was founded in 1975 when aviation began to grow rapidly and is now the principal UK body
campaigning exclusively on the environmental impacts of the sector. As aviation is exempt from noise
nuisance legislation, AEF seeks to influence national policy.
Flightpath Watch has now access to all the research produced by the AEF and our representatives attend
its seminars regularly.
As mentioned in the most recent newsletters, our membership year will begin again in April, therefore
please see attached our membership form for 2018/2019. The membership annual fee remains at £10.
We hope you will continue to support our efforts to protect our living environment and mitigate the impact
of aviation noise and pollution in our area.
THANK YOU
Flightpath Watch Ltd
February 2018
Dear Member
You may recall that last month’s Newsletter addressed the first three of six two-pronged courses of
action by Biggin Hill Airport for its continuing growth. This month we will focus on the second three,
which deal mainly with infrastructure and the need for more Green-Belt land to be released for
development.
Facilitate lasting and sustainable
infrastructure for the region to enhance the
value of Biggin Hill Airport
7. Create better access to the M25 to
support new investment and growth in
South East London, Kent and Sussex
8. Extend the Bakerloo line to Hayes – this
will transform South East London’s
accessibility
Provide local policy and investment support 9. Align the policy environment to support
future investment and employment
growth at Biggin Hill Airport
10. Support the strategic realignment of
Green Belt to capitalise on the airport’s
growth potential within the airport’s
boundary
Retain Biggin Hill Airport SOLDC status to
optimise the value of improved surface access
and training for young people
11. Enhance the local road network to
provide better visitor and employee
access to the airport
12. Support the airport’s education and
training initiatives as well as its plans to
build an aviation college
INFRASTRUCTURE
A) The idea of a connection to the M25 (point 7) is
not new. The Airport first raised it some 15 years
ago. Those who thought that Biggin Hill Airport
would be satisfied with the new operating hours
for a number of years were clearly too optimistic.
As feared, the increase in hours is only the first
step.
There is a map in the Locate document (not a
clear map) that seems to indicate a straight route
South from the airport to just above Westerham.
Considering that this is likely to be at the expense
of the tax-payers, it is legitimate to ask how many
residents and businesses would benefit from this public expense. It is similarly legitimate to
ask whether the public should fund the infrastructure around another London airport when the
fierce competition among Biggin Hill, Northolt and Southend airports seems to indicate that
there is more supply than demand at present. Both Northolt and Southend are well located to
serve the need for private and business air traffic to London, with infrastructure already funded
and built.
B) The extension of the Bakerloo Line to Hayes (point 8) is favoured by the Airport over the wishes
of Bromley Council, which would rather have the DLR extended to Bromley North and South or
trams-link services to Crystal Palace. Cllr Colin Smith, now Leader of the Council in replacement
of Cllr Carr, stated in mid-2017 that the extension of the Bakerloo Line would take over the
National Rail lines and deny access to London Bridge, Cannon Street and Charing Cross, which
are far more useful stations to the residents of Hayes. This seems to be corroborated by
responses from Hayes residents to a general survey run by the Department for Transport. Sadiq
Khan is the main supporter of this venture, which is said to cost some £3bn. According to Cllr
Smith, the preferred DLR route to Bromley North would have been cheaper and more useful to
Bromley.
C) The improvement of the local road network (point
11) was raised in a document prepared for the
Airport by planning consultants Lichfields in 2014
(Lichfields, Letter to Bromley, March 2014 and to
the London Mayor, April 2014). It clearly stated
that this private airport, in order to succeed and
expand, needs public money to improve access. It
would be helpful to know which roads in
particular would be enlarged or added and
whether this work would be beneficial to the
community. The map provided in the Locate
document is attached, but it is not clear. The
description says:
1. Invest in the A233 to improve access to Bromley and Orpington town centres.
2. Upgrade road infrastructure and public transport to Vulcan Business Park.
3. Improve the road network to improve access to Fort Halstead.
4. Improve the road network to improve access to Croydon.
Meanwhile we understand that a new access point from Downe Road/New Hill Road to the
airport is being considered.
GREEN BELT
The text in this Locate document only refers to use of the green belt within the airport’s boundary
(point 10). The Council appeared to be very reticent to answer when the question of whether such
airport boundary is now including the farm land bought by the airport in 2014.
Even more concerning is the reference to the need for more green-belt land to be given (donated?)
to the airport in the already mentioned Lichfields’ report: ”There is very little available non-Green
Belt land on the Airport and non-Green Belt land is required to facilitate development …”
The document goes on to specify:
1. “Removing West Camp from the Green Belt will remove one layer of constraint and
potentially make the site more attractive for inward investment… Land with airside access
must be retained for future aviation use”.
2. East Camp – “BHAL therefore requests that … the area is removed from the Green Belt”.
3. “To enable future hangar development which has a requirement for airside access there is a
necessity to extend the boundary of South Camp northwards and remove this section of land
from the Green Belt”.
4. Terminal Area – “BHAL requests that proposed policy for this area allows for the
redevelopment of the terminal building and aviation development to the north of the
terminal building and that this land is also removed from the Green Belt”.
5. “The map also shows boundaries for West Camp, South Camp and East Camp. BHAL requests
that those boundaries are amended following completion of the on-going work between the
Airport and the Council”. (Lichfields, Letter to Bromley, 24 March 2014, Annex 4, pages
12/15).
It is ironic that, in the 1990s, when the Council was considering whether to retain the airport or
sell the land for development, residents supported the retention of the airport as a green and
open space. It will not be so open now … and we also have large, low flying aeroplanes to ruin
the peace.
PLEASE NOTE THAT THE RENEWAL OF THE MEMBERSHIP TO FLIGHTPATH WATCH WILL BE DUE IN
APRIL 2018. THE MEMBERSHIP FEE REMAINS AT £10. THANK YOU FOR YOUR CONTINUING
SUPPORT.
Kind regards,
Flightpath Watch
January 2018
Dear Member
Some of you might be already aware that Biggin Hill Airport has published, on its Locate website, a new study
entitled “The Case for Growth”. The link to the full document is https://locateatbigginhill.co.uk/wpcontent/
uploads/2017/10/LOCATE_BROCHURE_WEB.pdf.
In the document, the Airport lists 6 two-prong courses of action for its development:
Support business aviation nationally and
internationally – in the interests of exports and
global connectivity
1. Promote inward investment and export services
focused on business aviation
2. Align government aviation policy so that it
reflects the strategic importance of business
aviation
Factor the value of the aerospace industry into
strategic planning around the London and South-
East region
3. Provide government support for Biggin Hill as
London’s only specialist business airport
4. Reinforce Biggin Hill Airport’s designation as a
Strategic Outer London Development Centre in
the new London Plan
Acknowledge Biggin Hill Airport’s significance in the
new London Plan – and London’s infrastructure plan
5. Support South East London – the city’s “empty
quarter” – as a growth corridor
6. Re-balance investment in the road network to
support productivity and growth in South East
London
Facilitate lasting and sustainable infrastructure for
the region to enhance the value of Biggin Hill Airport
7. Create better access to the M25 to support new
investment and growth in South East London,
Kent and Sussex
8. Extend the Bakerloo line to Hayes – this will
transform South East London’s accessibility
Provide local policy and investment support … 9. Align the policy environment to support future
investment and employment growth at Biggin
Hill Airport
10. Support the strategic realignment of Green Belt
to capitalise on the airport’s growth potential
within the airport’s boundary
Retain Biggin Hill Airport SOLDC status to optimise
the value of improved surface access and training
for young people
11. Enhance the local road network to provide
better visitor and employee access to the airport
12. Support the airport’s education and training
initiatives as well as its plans to build an aviation
college
As a preamble to the recipients of the document (presumably politicians in the main but possibly also investors)
Biggin Hill Airport defines itself as a World Class Business Aviation Airport and states that its vision for growth was
supported by 79% out of 15,000 residents consulted (page 22). As Flightpath Watch established by means of an
extensive survey, 90% of the local population was in fact opposed to development at the airport and in particular
to the longer operating hours (longer than at all of City, Farnborough and Northolt airports).
We also demonstrated that the survey by Bromley Council was severely flawed, to the point that even the then
Leader of the Council, Cllr Carr, a staunch supporter of development at the airport, had to advise the Executive, at
a meeting held after the full Council meeting on 25 November 2015, to disregard the survey in their
considerations (unfortunately too late to change incorrectly based opinions).
Without wanting to halt good business for the airport, it is important that the truth about the extent of the local
support is told and that we remind our politicians of the above. We will be writing to all relevant political figures
to try and re-establish the correct balance and would ask you to do the same.
Moving on to the 6 courses of action indicated in the Airport’s report, we address the first three here and the
other three in our next Newsletter.
ONE This is generic in nature. Our only interest in the growth at the airport is in how this can
be accommodated within our living environment, which is more accurately described in
the following steps
TWO Biggin Hill claims to be London’s only specialist business airport. Recently news has
surfaced that business aviation is also being sought by Southend Airport, which offers
the same helicopter shuttle to London, and by Northolt Airport, where the Council
Leader is vehemently arguing to maintain commercial flights to Northolt Airport and
openly accuses Biggin Hill of underhand tactics to foment adverse public opinion in order
to move their commercial flights to Biggin Hill (Hillingdon People magazine, Jan/Feb
2018 edition, page 12 https://www.hillingdon.gov.uk/hillingdonpeople).
We cannot comment on such accusations, apart from being mindful of the surveys run in
Bromley and the fact that the majority of the population here is not supportive of an
increase in flights over us. It would be beneficial to our environment if not ALL business
flights flew to Biggin Hill, particularly as business aviation is “a fast growing market” and
“80% of aviation flights are for business purposes” (Locate, page 25).
As we all know, we have been offered a cap of 50,000 flights per year, but that cap has
not been properly recorded in the MIL, as all of the Council, our local MPs and the
Ombudsman have been made aware of by Flightpath Watch.
THREE Our residential areas are referred to as
the city’s “empty quarter” and defined
as a “growth corridor”. The graph on the
right, taken from page 27 of the Locate
document, shows where Biggin Hill
Airport is intending to change the nature
of our living environment (see area
marked in green) by asking the public
purse to increase infrastructure and
curtail our green belt.
Of course, air traffic cannot be limited to
the area marked in green as residents in most of Bromley and some adjacent boroughs
know well as they are already being affected by the increase in large aircraft and
helicopters.
We would also like to comment on the phrase “Re-balance investment in the road
network to support productivity and growth in South East London”. Considering that the
airport is the only business in the area (a private business) requiring greater access, it
seems unjustifiable to spend public resources to support very modest employment,
particularly as other airports in the South-East have already been provided public
funding for sufficient infrastructure to serve the current aviation needs. This is
demonstrated by the acrimonious competition between airports we have already
referred to (Hillingdon People magazine, Jan/Feb 2018, page 12).
These will be the subject of our next Newsletter.
To conclude, it appears that our need to be aware of events at the airport continues relentlessly. We have
therefore decided to continue our membership scheme.
The current year’s membership expires in April and we
will be circulating our renewal reminder in the next couple of months. The membership fee will remain at £10.
Thank you for your continuing support.
Flightpath Watch
November 2017
Dear Member
As you are probably aware, the sky over and around Biggin Hill airport is also affected by air
traffic directed to Heathrow airport. This is particularly noticeable in the early morning (as
early as 4.30 am) and is particularly disturbing because large aircraft circle over us at
decreasing altitudes (sometimes as low as 5000 feet) while waiting to be given permission
to land. It is not unprecedented to be subjected to a couple of jumbo jets circling four or
five times over us – the earlier they are, the more they need to circle because Heathrow
only has a limited number of night-time slots. Also, the closer they are to the busy time of 6
am, again the more they need to circle until they are allowed to land. Please see recent
screenshots below, taken from the Biggin Hill recording system but related to Heathrow
traffic.
All surveys and publicity by either government or press refer to residents living under the
final landing route. Whilst there is no denying that noise and sleep disturbance for such
residents is severe, as you can guess from the images above, this does not mean that our
area should be disregarded.
So much so that BHAL offered, as a condition for the approval of extended hours of
operation, to have the beacon located at Biggin Hill (the one responsible for attracting the
circling and stacking of aircraft over our area) relocated. Bromley Council listed this
condition as Condition 16 and declared it “satisfied”. It is however obvious that it was not in
the power of BHAL to offer this condition. Moreover, recent information seems to suggest
that there would be no material decrease in the circling and stacking by Heathrow air traffic
over us even if the beacon were to be removed from the airport’s grounds. Bromley Council
were clearly hasty in considering this condition satisfied.
There have been several surveys this year and Flightpath Watch has contributed to nearly all
of them, however most did not allow commentary that could be tailored to our area.
Now there is a survey by the CAA (this is a short one), which closes on 5th January 2018.
We would kindly ask you to take the time to click on the attached link
https://consultations.caa.co.uk/policy-development/aviation-noise-impacts/ and spend a
few minutes filling in the questionnaire. Again, the survey is not related to our area but
there are a few occasions when tailored commentary can be made by clicking on the
“Other” button. For instance:
Question 4 – if you click “Other” you can make the point that, as well as big jumbo jets
headed for Heathrow, we are also affected by large aircraft of a size equivalent to a B737
(Gulfstream 650, Falcon 7X, Global Express 6000, as well as B737) flying below 2500 ft to
and from Biggin Hill.
Question 5 – In addition to selecting three causes of concern, there is a box called “Other”,
where the point can be made that, coming from the experience of a Noise Action Plan
recently introduced at Biggin Hill, it has become apparent that noise is considered as an
average and that this deviates from the reality of how residents experience noise. Any noise
limit based on averages gives rise to an exponential increase in number of flights (which we
would notice) for every small decrease in decibels (which we would not notice). By way of
explanation, you may remember that some of the money generously donated to Flightpath
Watch was used to employ a very well reputed Aviation and Acoustic Consultant (who was
also employed to advise the Government). He stated that: “If all aircraft using BHAL were 3
dB less noisy, the movements could be doubled and the same contour area achieved […] It
is highly likely that those living nearby would not perceive the noise reduction but would
notice the doubling of movements and be adversely affected by it.” (ST report, 3.16)
Question 7 – You can click as many options as you consider appropriate but do not forget to
click on “Other” and make the point that there is need for an independent body, which is
capable of taking into consideration noise generated by an accumulation of both local air
traffic, large jumbo jets circling at 7000 ft (sometimes as low as 5000 ft) from 4.30 in the
morning as well as an increasing number of helicopters. As we are not under the final
landing stages into Heathrow, we are not considered in their “noise contours” but
experience serious disturbance nonetheless.
Question 8 – here the point can be made again in “Other” that all the authorities listed in
the offered selection are self-motivated and that an independent body is needed to ensure
objectivity.
Question 9 – this asks about “anything else”. Here we have the opportunity of stating that
Biggin Hill air traffic is below 2500ft and that no authority other than Bromley Council is
responsible for routes and noise. We know that Bromley Council is too busy and, in
fairness, inexperienced, to monitor the airport in any meaningful way. For your
information, we have already raised this point with an officer at the CAA. The point has
been acknowledged but put on the back-burner. It would help if this issue were to be
reinforced by your comments to this survey.
Thank you.
Kindest regards,
Flightpath Watch
October 2017
Dear Member
We have been made aware that responses to complaints made to BHAL by residents are
failing to address the issues raised adequately. Thank you to those who have passed on
examples to us and apologies about not responding to everybody individually. We have
however noted certain trends in both complaints and responses.
The main issues appear to be:
HELICOPTERS NOT RESPECTING NOISE SENSITIVE AREAS
DEPARTURES OFF TRACK BY BOTH LARGE AND LIGHT AIRCRAFT
CIRCUITS OVER RESIDENTIAL AND NOISE SENSITIVE AREAS
If other issues (such as ground running) present reasons for concern, please let us know.
You may remember that many of the conditions imposed by the Council are ineffective or
irrelevant. The only defence mechanism offered to residents is the use of the airport’s Noise
Monitoring and Track Keeping system.
We made the point in the past that Noise Monitoring is irrelevant, because of the very wide
and averaged-out noise parameters granted by the Council to the Airport. We therefore
suggested focusing on track-keeping, of which there are many infringements. Mr Curtis has
now started to reply: “You will be pleased to know that all aircraft movements are monitored
by the airport Noise Monitoring and Track Keeping System. Those that do not comply with
our required track limits are automatically logged for further action and consideration of a
penalty, therefore you do not need to raise complaints concerning track keeping, and can rest
assured that all these will be dealt with SANARB.” There is however no way of verifying
which aircraft is being reported to SANARB nor whether penalties are being issued.
Meanwhile, infringements continue, which seems to indicate that monitoring of the Track
Keeping system by the Airport is inadequate or that SANARB lacks effectiveness in stopping
aircraft from creating unnecessary disturbance.
In the MIL (Management Information Letter), a document produced by the Airport and
incorporated into the Deed of Variation that granted the Airport a 24% increase in operating
hours, it is stated that certain Noise Sensitive Areas would be established and that both light
aircraft and helicopters using a visual approach (VFR, or Visual Flying Rules) would avoid
such areas. The map of such Noise Sensitive areas is shown below.
When complaints have been made about aircraft flying over Noise Sensitive areas, they have
received a standard response from BHAL as follows: “Having reviewed the radar data, I can
confirm the aircraft you reported followed a standard VFR departure. The aircraft was
following standard procedures, therefore no further action will be taken.” Yet the MIL
requires aircraft using VFR to avoid Noise Sensitive Areas!”
At the Executive Meeting of 15th June 2016, the Executive undertook to appoint a Monitoring
Officer. No such officer has been appointed, therefore please continue to address
Andrew.rogers@bromley.gov.uk. In fact, as some complaints refer to infringements of a
legal document (the MIL), and in particular Section 21, it might be helpful to alert the Senior
Solicitor at susan.fraser@bromley.gov.uk. With regards to helicopters, section 21 of the MIL
states: “The vast majority of helicopters operate under VFR and are therefore treated as light
aircraft and will follow light aircraft routes. Helicopters will therefore be subject to all the
restrictions placed upon light aircraft.”
We have also been informed that Dr Robert Hadley, Chairman of the Bromley Residents
Association Federation, sits on SANARB as the residents’ representative. Therefore it might
be beneficial to alert him about any unsatisfactory reply received from the airport. Please email
him at the e-mail address published on the Council’s website robert.hadley@bt
internet.com.
Residents’ mitigation requests have been consistently rejected by the Council but the Track
Keeping system and the MIL are official commitments by the airport, so we are within our
rights to inform the Council of our concerns.
Flightpath Watch will send a statement to the Council summarising the issues we have been
made aware of, but it would be beneficial if the Council and Dr Hadley were also to hear of
your concerns directly.
Thank you for your continuing attention and support.
Flightpath Watch
August 2017
Dear Member
You may remember that in our July edition we circulated the routes currently in use at Biggin Hill
airport for the larger aircraft. The map is repeated below for ease of reference.
In this edition, we want to show you the routes used by lighter aircraft. Please see picture below or
click on https://www.bigginhillairport.com/wp-content/uploads/2012/04/BHA-Flight-Routes.pdf for
a clearer image.
Plan A shows all the departure routes for light aircraft. Plan B shows the circuits used for the
training of pilots. Plan C is no longer in constant use since the airport closed the smaller of their two
runways (the one going from West to East) in order to provide aircraft parking for Bombardier’s
activities.
Light aircraft is now openly encouraged by the airport to use Redhill for training purposes in order
not to interfere with the larger aircraft increasingly using the airport, however the circuits described
in Plan B still appear to be in use. Unfortunately, recent experiences suggest that Plan B is now also
used to test large aeroplanes or train pilots on business jets. These have been seen to circle six or
seven times in close succession, at speed and just over 1000 feet, with the circuit now extended over
Keston, Hayes, Crofton and, needless to say, the hospital. Those who have witnessed the effect this
creates over their homes and gardens will no doubt confirm that it is startling and even frightening.
The most frequent culprit is the Cessna Citation 510 jet (see example below) but circling at low level
by the very large Global Express and the medium-size Lear Jet is also occurring. Occasionally two
aeroplanes circle together, providing no respite for about an hour. Sometimes, the “lesson” begins
again a short while later, for another hour.
We have been told by the CAA that below 2500 feet the routes used by the airport are the
responsibility of the local authority. The Council has already been alerted by at least a couple of
residents that such circuits should not take place over densely populated residential areas and a
major hospital, for safety as well as noise reasons, but no information about the action the Council
intends to take (if any) has yet been received. It is important that you notify the Council as the
responsible party if you happen to witness any more of these exercises. Please contact your local
councillors and Andrew Rogers at Andrew.rogers@bromley.gov.uk if these circuits continue to be
used by jets and other large aircraft.
Kind regards
Flightpath Watch
July 2017
Dear Member
We thank all of those who attended the Flightpath Watch Annual General meeting last month and
showed their continuing interest and support.
The main topics were:
1. The majority of the promises and undertakings made by the airport have not been kept and
the Council has not done its duty in upholding those promises.
2. In particular, the main undertaking to keep the number of movements below 50,000 a year
has been worded in such a manner that it now does not represent a cap at all. The number
of movements has now been linked to a noise measure that in fact allows for an exponential
multiplication of movements over and above the promised 50,000 and, worse, has taken
away the ability of the Council to intervene. We wonder how many councillors are aware of
this, considering that even the Leader is still under the impression that there is a cap.
3. The Noise Monitoring and Track Keeping (NMTK) system is now operational. Unfortunately,
the noise allowance is so wide and based on averages that complaining about noise is futile.
Track keeping is more worthwhile, since there are many examples of breaches, some
acknowledged by the Airport. It is therefore worth using the system to complain. The
access page is on the airport’s website on the bottom right corner (see screenshot). The
steps to access it are self-explanatory but remember that there is a 45 minutes delay, so you
need to make a note of the flight and check it out later.
4. When complaining about aircraft track keeping, it is worth noting the published flying routes
for the larger planes (we will talk about the smaller planes in the next newsletter). These are
shown below. If you note that an aircraft deviates from these routes, please do use the
complaint system and let the airport know.
There is much more, but we do not want to overburden you with too many issues, so we will
reserve a few for the next newsletters.
If you are disappointed by the Council’s handling of the promises made and not kept
(particularly the issue of numbers of movements), please let your councillors know.
Kind regards
Flightpath Watch