Biggin Hill Airport

We have compiled answers to some of the most common questions Bromley residents have asked about Biggin Hill Airport:

Controls

1. What control does Bromley Council have over the running of Biggin Hill Airport?

In 1994, the council granted Biggin Hill Airport Ltd a 125-year lease, giving the airport an owners interest. This commercial lease agreement both imposes obligations on the airport and grants them rights. It also restricts what the council can impose on, and expect of, the airport.

The airport is responsible for running its business and the council does not have a general regulatory role in dealing with the airport or aviation matters, with the regulatory responsibility ultimately with the Civil Aviation Authority. In essence this means that as Biggin Hill Airport Limited operates the airport as a recognised airport operator and complies with all relevant airport and aviation regulations, the council is obliged to let them undertake their operations as they see fit.

The council’s responsibilities and powers are limited to ensuring Biggin Hill Airport Ltd abides by the terms of the lease, the Noise Action Plan (NAP) and the Management Information Letter (MIL). By doing this, it can encourage and ensure the airport works to reduce the noise disturbance experienced by Bromley residents.

The council’s responsibility for ensuring these obligations are met are carried out through attendance at a range of committees – including the Airport Consultative Committee, Noise and Safety Sub-Committee and Safety and Noise Abatement Review Board (SANARB) – and through direct engagement including the role of Airport Monitoring Officer.

2. Are there any limits on the type or size of aircraft, or numbers of aircraft, that can use Biggin Hill Airport?

This was agreed when the lease was originally signed.  The lease for Biggin Hill Airport allows for up to 125,000 annual movements, where a movement is defined as a take-off or landing. There is no restriction on whether these movements are by business jets, light aircraft, helicopters or any other type of aircraft. During the first five years of the Noise Action Plan, the airport agreed to the council’s significantly reduced cap of 50,000 annual movements. There is a specific cap on movements from 06:30-07:00 and 22:00-23:00 on weekdays, when no more than 8 movements can take place in any single period.

While there are no additional limits on the number of business jets, light aircraft or any other type of aircraft that can use the airport, each aircraft using Biggin Hill Airport must meet the requirements of International Civil Aviation Organisation (ICAO) chapter 3 noise certification. In accordance with the NAP, if the aircraft is operating before 07:00, it must meet the requirement of ICAO Chapter 4 noise certification.

There are also limits in place on how much noise aircraft can make on average over the course of a working day at Biggin Hill Airport. Information about how Biggin Hill Airport performs in relation to these limits can be found in the airport consultative committee minutes on Biggin Hill Airport’s website.

3. What is the legal position in respect of 50,000 movements versus 125,000 movements?

The only legally binding cap on movements is the 125,000 flights limit in the main lease granted to Biggin Hill Airport Limited (BHAL). As part of the NAP, the council agreed to increase the operating hours and BHAL agreed that they would not exceed 50,000 flight movements during the first five years of the NAP.

4. Has there been more than 50,000 movements in any given year at Biggin Hill Airport since the noise action plan was introduced?

In 2016 and 2017, as stated in Biggin Hill Airport’s NAP Review, the airport recorded 50,891 and 50,060 movements. These numbers reflect a period of time before the extended hours had been implemented at the airport. As such, the hours could not have been suspended while the commitments of the NAP were reviewed. Since the airport’s extended hours were made operational in May 2017, the benchmark of 50,000 movements has not been passed in any single year. 

5. Who governs the flight of aircraft below 2500ft?

As with the rest of UK, within the Bromley Council area all airspace below 2500ft, outside of controlled airspace, is categorised as Class G airspace. Within this airspace, pilots fly using VFR (Visual Flight Rules). They must adhere to the Standardised European Rules of the Air, originally set by the European Union Aviation Safety Agency, and the Civil Aviation Authority's Rules of the Air 2015, but otherwise have the flexibility to fly as they would like, even in the vicinity of Biggin Hill Airport’s aerodrome traffic zone (in accordance with Rule 11 of the Rules of the Air Regulations 2015).  When landing or taking off from Biggin Hill Airport they must follow procedures stipulated by Biggin Hill Airport, such as its noise preferential routes. Bromley Council has no jurisdiction over the flightpath taken by any aircraft under 2500ft.

6. Do helicopters have to follow the same rules as planes?

While there is no specific reference to helicopter operations within the operating criteria laid out in the third schedule of the lease, helicopters, like light aircraft and jet aircraft, are subject to the noise preferential routes and noise abatement procedures as set out in the lease, NAP and, in particular, appendix 3 of the MIL. Any breach of these procedures is reviewed by SANARB. In addition, helicopters should, if possible, raise to 1000ft before crossing the airport boundary.

7. What noise abatement procedures are in place to minimise the noise disturbance experienced by Bromley residents?

Noise sensitive areas (NSA) were established when Biggin Hill Airport agreed the NAP with Bromley Council. Their location is contained within Appendix 3 of the MIL. These NSAs are not ‘no fly zones’, though pilots should avoid them when it is safe to do so. The NSAs only apply to aircraft operating from Biggin Hill Airport, are capped at a height of 2000ft and can be entered if the pilot is under instruction from air traffic control or if the pilot in charge believes it is necessary for safe flying. Violations of these areas are monitored both automatically by WebTrak and via residents’ complaints through the noise monitoring and track keeping system. Breaches are reviewed by Biggin Hill Airport’s Safety and Noise Abatement Review Board (SANARB) and sanctions may be applied.

Biggin Hill Airport also operates noise preferential routes for northerly take-off from runway 03 and southerly take-off from runway 21. These procedures, which are published in UK AIP (Aeronautical Information Publication), are specific flight paths that set the route for aircraft to take from runway to joining main UK air traffic routes. They are designed to avoid built up areas where possible. Aircraft landing at Biggin Hill Airport follow an Instrument Landing System (ILS) to land on runway 21 and follow a circling approach flown under visual flight rules when landing on runway 03. A GPS-based approach to runway 03, which has the potential to remove a percentage of the traffic that currently follows the ILS over Chislehurst, Petts Wood and Orpington, has been submitted to the CAA and awaits approval.

Biggin Hill Airport has also placed limits on when training circuits can be flown. These are not permitted before 09:00 or after 17:00 on Saturdays, Sundays and on public holidays during British Summer Time.

Find out more about Biggin Hill Airport’s noise abatement policies.

8. Why is a 16-hour average of noise used to measure the noise created by Biggin Hill Airport?

At the time the NAP was created, the government’s Aviation Policy Framework set the, 57dB LAeq 16-hour contour as “the average level of daytime aircraft noise marking the approximate onset of significant community annoyance,” adding that: “Average noise exposure contours are a well-established measure of annoyance and are important to show historic trends in total noise around airports.”  It also adds “However, this does not mean that all people within this contour will experience significant adverse effects from aircraft noise. Nor does it mean that no-one outside of this contour will consider themselves annoyed by aircraft noise.” The APF also recommends that “average noise contours should not be the only measure used when airports seek to explain how locations under flight paths are affected by aircraft noise.” To this end Biggin Hill Airport also has a mobile noise monitor that can be deployed to take localised readings of noise.

9. Has this measurement altered and can Biggin Hill Airport alter its contours to reflect this?

Department for Transport policy is that 51 dB LAeq16 now represents the Lowest Observed Adverse Effect (LOAEL), the point at which it regards adverse effects begin to be seen on a community basis. Should the process move to a revision of the NAP, the council will ask Biggin Hill Airport to explore the setting of contours at this limit, as suggested in the January 2022 officers report, though this could not be unilaterally enforced by the council.

10. Are there rules about the noise generated on the ground in addition to those about flying aircraft?

Yes. Biggin Hill Airport has guidelines in place to control the amount of noise generated by aircraft on the ground. These guidelines include positioning of aircraft and length of time engines can be run for and complaints about ground noise should also be reported to the airport.

Complaints

11. How can I report aircraft causing a noise disturbance or flying dangerously?

As part of the airport’s Noise Action Plan (NAP), which was agreed with the council in 2015, Biggin Hill Airport installed noise monitoring equipment including the WebTrak noise monitoring and track keeping system. This shows aircraft flying near and using Biggin Hill Airport. Residents can use this system, which works on a 25-minute delay, to find out more about any aircraft they consider to have caused a noise disturbance and also to report it directly to the airport so that the incident can be logged and investigated. The council is represented on committees that have oversight of the complaints procedure to ensure residents’ complaints are treated fairly and appropriate actions are taken.

Should residents wish to use another method to raise an enquiry with Biggin Hill Airport, they can also contact them directly.

While Biggin Hill Airport should be the first contact for complaints about aircraft using the airport, residents can also raise issues with the council’s airport monitoring officer using the complaint form or by emailing airport.monitoring@bromley.gov.uk.

12. Is Webtrak accurate?

After hearing the concerns of residents, the council asked Biggin Hill Airport to further investigate the accuracy of WebTrak. Following that investigation, the weight of evidence that the council has been presented with does not suggest there are any significant inaccuracies in the Webtrak system.

It is also worth noting that the Civil Aviation Authority, in their report on Biggin Hill Airport’s NAP review that was commissioned by the council, describe it as an “industry standard noise monitoring and track keeping system”. They go on to say that: “The WebTrak interface and integrated complaints handling functionality mentioned in para 3.2 of the NAP review is welcomed and something that is routinely used at large commercial airports.”

The council is aware that the airport is examining the issue of some flights not appearing on the public-facing WebTrak software. These flights are registered and tracked by the airport’s ANOMS software that also automatically registers infringements of NSAs and exceedance of TVLs.

13. Is the northern noise monitor correctly positioned?

While the monitor is to the west of the line of the runway, it is within the boundaries suitable for such a monitor. The noise violation limit and noise contours were set based on the monitor in position. The siting of both noise monitors was approved by the council’s aviation acoustic expert when it was originally installed.

Explanations of technical words

14. What is the NAP and what does it say?

The Noise Action Plan (NAP) comprises a series of commitments made by Biggin Hill Airport when Bromley Council agreed to extend its operating hours. The NAP was appended to the lease through the Deed of Variation in 2016, making it a legal document.

15. What is the MIL?

The Management Information Letter (MIL) was created alongside the NAP as a way of explaining how the commitments of the NAP would be enacted. It was also appended to the lease through the Deed of Variation in 2016, making it a legal document.

16. What are Noise Preferential Routes (NPRs) and does Biggin Hill Airport have them?

Noise Preferential Routes are specific routes that should be taken to avoid overflight of built-up areas. Biggin Hill Airport has Noise Preferential Routes for its take-offs from both Runway 03 and Runway 21.

17. What are Track Violation Limits (TVLs)?

TVLs demarcate the area around the NPRs at Biggin Hill Airport that give a margin of error for the flight path. TVLs were introduced at paragraph 4.37 of the NAP. If an aircraft remains with the TVL corridor, it is considered to have followed the NPR. If an aircraft’s flightpath exceeds the TVL, the reason for doing so should be examined and sanctions applied if appropriate.

18. Is there an agreed Noise Preferential Route for circuit flying defined in the lease?

No. In the UK AIP, pilots are given instructions for areas to avoid while flying circuits. This instruction should be followed. If pilots enter an NSA while conducting circuit training it should be investigated by Biggin Hill Airport. If an applicable reason, such an Air Traffic Control instruction or safety concerns, is not given sanctions may be applied.

Noise Action Plan review

19. What decision did the council make about the Biggin Hill Airport NAP review in January 2022?

At the Executive meeting on 12 January 2022, the council decided to ask Biggin Hill Airport to provide an updated review of their Noise Action Plan to include further evidence with regards to commitments made in the NAP, including timelines with regards to resolving any outstanding issues. The deadline for delivery of this review was 30 June 2022.

20. Why was the NAP review necessary?

There is a commitment within the NAP to review it every five years. The summer of 2021 was five years after the signing of the Deed of Variation that appended the NAP to the lease.

21. Does the NAP need to be revised?

Within the NAP at point 4.32 it states that one of the benefits of these reviews is that it “will allow the benefits of emerging technology to be evaluated and incorporated in the NAP if thought to be beneficial.” Similarly, the MIL, which explains how the NAP is to be applied, states that “opportunities to minimise the environmental impact of airport activities will be considered at each review.” Therefore, it is envisaged that after each review a revised NAP will be agreed between the council and BHAL. Without a revision of the NAP any improvements are not legally binding.

22. Was the Noise Action Plan Review a new proposal from Biggin Hill Airport?

No, the Noise Action Plan Review is not a new proposal. When the NAP was agreed by Bromley Council, it contained the commitment that it would be reviewed every five years.

The Deed of Variation, which appended the NAP to the lease Biggin Hill Airport holds with the council, was signed in the summer of 2016. As such, the review was due in the summer of 2021.

23. Why have all the commitments of the Noise Action Plan not been enforced?

Some of the commitments made within the Noise Action Plan are not the sole responsibility of Biggin Hill Airport to achieve. The new route to Runway 03 requires the approval of the Civil Aviation Authority following a defined CAA process. Though the VOR DME beacon is hosted on Biggin Hill Airport land, it is owned and operated by National Air Traffic Services and as such is their responsibility to decommission.

24. Was there a public consultation about the NAP review?

In considering its response to the NAP review, the council took into account the feedback received from residents and residents’ groups, both since the signing of the NAP and directly in relation to the review. The council also sought expert opinion from independent acoustics experts RSK Acoustics, the Civil Aviation Authority (CAA) and external legal counsel.

In the five years of the NAP, the council has sat on committees where residents’ concerns have been discussed, liaised with residents about these concerns and raised issues with the airport that has led to change. This continues irrespective of the NAP review.

While preparing the Officer’s Report of January 2022, the council also received a report from residents’ group Flightpath Watch, detailing their views on numerous issues. The council undertook a thorough and diligent review of the Flightpath Watch report, including taking independent advice from legal counsel, as also requested by Flightpath Watch.

Members of the public can continue to share their views and concerns with the council by emailing airport.monitoring@bromley.gov.uk.

25. Why did the council not share Flightpath Watch’s report with the CAA prior to the January 2022 meeting?

The council contacted the CAA and other independent experts to help inform its opinion about the airport’s NAP review. The council received Flightpath Watch’s report after the terms for the report by the CAA had been agreed. As such, this document was not available for those consultants. The council has however consulted independent legal counsel about the issues raised in the Flightpath Watch report.

26. Did Biggin Hill Airport meet the 30 June 2022 deadline?

Biggin Hill Airport provided a further document addressing the areas raised by the CAA report, as highlighted in the recommendations of the January 2022 officer’s report, by the 30 June 2022 deadline. This document was published alongside the October 22 officer’s report.

27. What was expected in the autumn of 2022?

In January 2022, it was decided by the Executive Committee that a further report would be presented to the Executive in autumn 2022 detailing progress against the recommendations identified the officer report presented to the Executive in January 2022 and any next steps to be taken.

28. What has happened?

During the summer the council was informed by the CAA that they estimate they will make a decision on Runway 03 by Q3/Q4 of 2022. Given the significance of Runway 03, officers are recommending that final decision on the reviews is taken after CAA makes its decision. See report to the Executive dated 19 October 2022.

Council actions

29. How does the council monitor the promises made by Biggin Hill Airport Ltd?

The council monitors these promises through involvement with the Airport Consultative Committee, Noise and Safety Sub-Committee and Safety and Noise Abatement Review Board (SANARB), and through direct engagement, particularly through the Airport Monitoring Officer.

30. Can the council object to airport developments?

The council seeks to protect the interests of residents across the borough and those living under the flightpath, so it can and will raise objections to developments that threaten these interests. However, as landlord, the council cannot unreasonably withhold or delay consent for any permitted development in accordance with the lease user clause. Such developments are ones that are directly relevant to the running of an airport.

31. Is the council legally entitled to rescind the extended operating hours if BHAL do not meet certain conditions imposed at that time?

In theory, yes. But if there are breaches of the lease then the council, in its capacity as BHAL’s landlord, has to follow a process before rescinding, for example, allow the tenant to amend, ameliorate or make good. If there is no agreement, then this will lead to arbitration. As is laid out in the officer’s report of January 2022 about the Noise Action Plan review, the council sought external legal opinion about reported breaches of the lease in December 2021. At that time the council’s legal advice, which was included in the January 2022 officer’s report, was that it would not be appropriate to rescind the longer hours or the lease.

32. Does the Council oversee the complaints procedure to ensure it is carried out effectively?

Yes, the council has representatives on the Biggin Hill Airport Consultative Committee, Noise and Safety sub-Committee and Safety and Noise Abatement Review Board, all of whom have a role to play in monitoring the complaints procedure.

33. How much communication does the airport monitoring officer have with Biggin Hill Airport and with residents?

To effectively carry out the responsibilities of the role, it is likely the airport monitoring officer (AMO) will have more communication with BHAL than any individual Bromley resident or body. However, the AMO has more overall communication with residents than with BHAL. The AMO communicates on an almost daily basis with residents, responding to the enquiries received regarding the airport. Residents also require the AMO to communicate with the airport on their behalf, necessitating further communication in that direction. The AMO also sits on three Airport-related committees as part of the role.

34. Why did the council approve the airport’s plans for a new hotel?

As the hotel will primarily and predominantly serve users of the airport, though some custom may come from elsewhere, the hotel development is regarded to have airport-related use. As such, it sits within the boundaries of the lease’s permitted user clause. As the landlord, the council could not unreasonably withhold consent for the new hotel as it is considered permitted development in accordance with lease user clause.

35. Does the council measure and monitor the level of air pollution around the airport?

The council does not currently measure air pollution around the airport. Air quality data modelled in 2020 placed areas to the north west of the borough in an Air Quality Management Area. Biggin Hill remained outside that area. You can find more about Bromley’s approach to air pollution in the Air Quality Action Plan 2020-2025.

Applications

36. What is happening with the new approach to Runway 03?

The council is very aware of residents’ concerns about the length of time it has taken for this NAP commitment to be delivered.

In an effort to help residents and bring about a timely conclusion to this Airspace Change Proposal (ACP), the Chief Executive of the London Borough of Bromley wrote to the Chief Executive of the Civil Aviation Authority (CAA), for guidance on how the ACP is progressing and an indication of when a decision might be given.

The CAA stated that they estimate a decision will be made by end of Q3/start of Q4 2022.

The Leader and Chief Executive of the London Borough of Bromley have also written to Bromley MPs to urge them to contact the appropriate Minister about this issue to ensure focus is kept on the proposal.

37. What action will the council take if the new approach to Runway 03 is not approved?

The council is not in a position to speculate about a decision that has not yet been made. As this new approach is so important to local residents, and the CAA has suggested that a decision is imminent, the officers report of October 2022 is recommending that a further report be brought to the Executive in January 2023 when the decision should have been made and a more complete picture of the NAP review will be available.

38. Is the permitted user clause being discussed as part of the Noise Action Plan review?

No, the permitted user clause is an entirely separate issue to the Noise Action Plan review.

39. Has any further representation been made to the council about the permitted user clause?

The council has not received an application / request under the lease about altering the permitted user clause since the executive made its decision not to alter the clause in May 2021.

40. Has any representation been made to the council about airport expansion?

The airport has not approached the council with any plan for expansion.

Further information

• BHAL’s original proposal document (PDF - 5.08 MB)
• March 2015 Executive report
• November 2015 Executive report
• Executive and Resources PDS Committee 5 January 2016 agenda
• June 2016 Executive agenda 
• Council questions and replies up to and including March 2018 (PDF - 770.97 KB)
• Refusal of application for permission for Judicial Review (PDF - 224.78 KB)