9 DECEMBER 2019
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Last week BTN highlighted the recent and controversial reopening of RAF Northolt. ‘Controversial’ because the airport accepted commercial flights on 11 November following a £23m runway renovation without carrying out the necessary regulatory assessments and without consulting local residents – conditions many other commercial airports would have to meet.
It is no secret a number of privately-owned and commercially-operated airports have aired concerns about the lack of a level playing field at RAF Northolt in the context of its primary current use as a business aviation operation, not as a military airport.
Competition is generally a good thing and welcomed when all play by the same rules, but this is not the case here.
In 2013, the government abandoned its previous commitment to cap commercial flights to 7,000 a year at RAF Northolt and raised it to 12,000 a year. At this point, the alternative London business aviation airports sat up and identified that MAA (Military Aviation Authority) rules were different from the CAA’s (or EASA’s) and the promulgation of all the safety-related data relating to its use was either incomplete, out-of-date or not readily available for civil users to inspect and assess.
A subsequent judicial review found the CAA had the power to impose conditions on RAF Northolt as far as its civilian operations were concerned. Ministry of Defence (MoD) documents released as part of that process revealed significant safety concerns, particularly around flight path obstacles. Yet, to date, neither removal of the obstacles nor the recommended shortening of the runway, nor other measures have been seen to happen.
The government claims to be sticking to its self-imposed cap of 12,000 commercial flights a year. However, the closure of the runway for renovation in 2018 left many worried that RAF Northolt intended to expand commercial flights once again, and compete for business. The government could easily change its mind, as it did in 2013.
These concerns have been largely justified. London City Airport is now running commercial flights at RAF Northolt, through its Premier Passenger Service, targeting luxury flyers and is marketing Northolt as “London’s VIP Airport”. But there is an accountability deficit. A recent poll conducted by the Regional Business and Airports Association (RABA) showed 68% of local residents were not even aware the runway was reopening.
Northolt is the only military or government owned airport in the UK to be notified within the UK’s Aeronautical Information Circulars (AIP) – the civilian licensed or EASA-Certificated airport’s ‘data directory’, if you wish.
The implication is that it fully meets UK civil certification standards or EU EASA rules.
That is not the case. Indeed, it is an exceptional case.
Full airfield survey data for obstacles including a typical Type A obstacle chart are not readily available, nor are they up-to-date – everyone else has to update theirs annually. The consequences of this are that both UK-registered and predominantly non-UK registered civil aircraft, many carrying paying passengers, are utilising Northolt (with far more such aircraft versus the military usage) without fully assessing all the performance limitation criteria one would normally be expected to consider.
Furnished with the full, ‘un-redacted’ airfield data, in accordance with normal civil airport certification rules, there is no doubt a number of current civilian users would probably reassess their capabilities in and out of the airfield.
None of this would really be an issue were the volume of civil traffic far less than the military usage, but the facts are Northolt is promoted proactively as a commercial option for business aviation, as a government-funded and operated airport, in competition with others that are fully privately funded. In 2017 for example, there were more than 10,000 commercial flights against 3,600 military. Recent figures since the airport’s reopening suggest this trend is continuing.
For RABA, an organisation that represents 35 smaller commercial airports across the UK, the Northolt story represents the ‘thin end of the wedge’. The MoD’s JSP360 policy is encouraging RAF stations up and down the country to seek civil-aviation activity to offset cuts in defence spending, with little thought to the commercial consequences for privately-owned entities nearby or the impact on the overall network of airfield infrastructure available to UK aviation as a whole in the UK.
The policy also ignores much more innovative solutions that are capable of meeting the MoD's objectives to a far greater degree and without any adverse impacts on operational readiness, flexibility and irreducible capacity.
What RABA members and other civil airport peers would expect from here on is that if RAF Northolt continues to be used and promoted as a commercial alternative for London, and still be notified in the UK AIP, then let it comply fully with exactly the same rules as the rest of us. Basically, have it properly certified for civilian use or if not, then stop promoting it for use as a commercially-available airport and remove it from the civil AIP.
With this in mind, RABA will be seeking an early meeting with relevant government departments once a new administration is in place to set out a revised and much more economically- and operationally-efficient regime that is of significant benefit both to the MoD and its members. And, most importantly, that also addresses the current situation where state-funded assets are being used to compete on unfair terms with privately-owned and financed infrastructure.
Basil O’Fee – Secretariat, Regional and Business Airports Group
BTN notes that the insurance issue raised in our article 2 December has not been answered.
SPECIAL NOTE: Over the past several years BTN has championed a campaign to allow scheduled domestic flights into Northolt. The London regional access problem has now been partially resolved, with slots being found initially for Inverness and this year also Guernsey and Newquay. Jersey and the Isle of Man still lack access. With these exceptions, BTN commends itself for its success in respect of the provinces.
All comments are filtered to exclude any excesses but the Editor does not have to agree with what is being said. 100 words maximum
Simon Grigor, Harrow
"A recent poll conducted by the Regional Business and Airports Association (RABA) showed 68% of local residents were not even aware the runway was reopening." Well, I bet a very similar number didn't even know the runway was closed! I live less than two miles off the end of the runway and local friends (some of whom live - considerably - nearer) I spoke to last week, to tell them to look out for all the Presidential traffic connected to the Trump visit (four C-17s; four CH-47s; two VH-60s) and not a single one had noticed that it had been shut! Given the huge unlikelihood of a government of any party increasing the Defence budget, I think it's sensible for the RAF to look for commercial opportunities like this. And, as I've said before in commenting here about Northolt, any moves to turn the airfield into a housing estate must be resisted - the seriously creaking local infrastructure (roads, schools, healthcare) would finally fracture altogether.