Reubens take on RAF in dogfight over Northolt
 

Reubens take on RAF in dogfight over Northolt

BILLIONAIRE property moguls David and Simon Reuben have launched a legal challenge to halt the soaring number of civilian flights at RAF Northolt, the airport used by the Queen and prime minister. Oxford airport, owned by the brothers, together with Biggin Hill airport in Kent, want rules that apply to civilian airports imposed on Northolt, which operates to military standards.

The cap on civil aircraft flights at the airport in northwest London was lifted by 5,000 to 12,000 by the Ministry of Defence under plans to raise more money, and the airfield has become a favourite with business people who want to land close to the centre of London. Warren Buffett’s NetJets aviation business is a big operator at Northolt, where at least 70% of flights are now civilian. However, Oxford and Biggin Hill argue that the airport does not meet civil aviation standards and have won the right to a judicial review over refusal by the government and Civil Aviation Authority to consider imposing tougher standards. The case is due to be heard at the High Court in the autumn.

Forcing the CAA to send in inspectors could lead to the imposition of stringent conditions on the airport, including reclassifying and downgrading its runway so larger planes are not allowed to land, and even banning civilian flights until standards are met. The airport is bordered by the London to Oxford A40 road. Barrister John Steel QC, who is representing the claimants, said: “Oxford and Biggin Hill airports consider that the standards of safety for civil aviation use of RAF Northolt should be same as those required at all other UK civil airports.”

Northolt opened in 1915 and played a key role in the Battle of Britain, when it was home to the 303 Polish squadron. During the 2012 Olympics, it was a base for Typhoon fighter jets.

The MoD said: “RAF Northolt has an excellent safety record and complies with the Military Aviation Authority. It is the responsibility of civilian commercial aircraft operators to ensure the safety of their aircraft. As legal proceedings are ongoing, it would be inappropriate to comment further.”

The CAA did not comment.

Previous thread comment on Northolt status by HTB

Of course there is no financial incentive for the brothers to ban private aircraft from operating at Northolt.

:rolleyes:


By the way, is Northolt still closed on the weekends? It's been a few years since I've operated in London. Retired you know.

Very handy airfield to fly aeromedical repat flights into for hospitals in north-west and central London and the southern Home Counties. Allows for the shortest transfer times, in particular for the critically ill. Neither Heathrow or Gatwick readily allow and charge the earth for aeromed flights.

They've got a point, though. The MOD appear to regard Northolt as a cash cow but rely on exemptions from CAA safety regs to allow it to operate more cheaply than its civilian competitors. I don't think that's fair (even if the CAA regs are unnecessary).

It's not quite true to say that Northolt has exemptions from CAA regs. It is a military airfield so CAA regs simply do not apply, a subtle but important distinction.

True, but why should CAA regs not apply to civilian CAT?

It would appear that the holders of the AOC take responsibility for the use of the airfield.

It is surely up to the civilian Operators to `operate` to the appropriate Performance criteria applicable to their aircraft,and the airfield.
RAF aircraft do not normally operate to `Military Standards` unless specifically permitted.Those aircraft that have civilian counterparts operated to civilian performance criteria,and if one was not able to do so we would pre-position the aircraft at Brize or Heathrow.
Seems like a lot of `sour grapes`......

There isn't that much difference between the CAA's CAP168
http://www.caa.co.uk/docs/33/cap168.pdf
and the MAA's Manual of Aerodrome Design and Safeguarding (MADS)
http://www.maa.mod.uk/linkedfiles/regulation/mads.pdf

There are professional fire fighters, medical staff and air traffic controllers at RAF Northolt as well providing the same service as a civilian licenced airfield. I suspect the Reubens are about to lose a lot of money to legal bills! The MOD's policy of Income Generation (formally Wider Markets) is a Government backed initiative that sells of 'spare capacity' in Government owned assets - selling capacity at an airfield is exactly the same thing. Indeed, it wouldn't surprise me if it is more expensive to assure a Government Aerodrome to civilian licenced airfield in 'real money' terms.

LJ

Leon, Agreed.

Most military "airfields" these days have more than one military purpose. Putting a cost on running them is virtually impossible. Does unit A, which is part of a separate command get counted or not counted? Unit B is a lodger unit. Unit D is under part command and is only at the airfield until new infra is in place at X in 20xx. It's comparing apples with pears, Ahem! Northolt's advantage is its geographical location.

However I have little doubt that the government will f..k up the legalities and the tiny bit of cash Northolt makes will be lost. Those operating into Northolt will have to go elsewhere and everyone loses. Sorry; cynical tendencies coming out after 3 of Hook Nortons finest.

And don't forget many of these business jet flights are private flights. They aren't subject to the same rules that a scheduled passenger flight would be.

Until it became Newquay Cornwall Airport the CAA were more than happy for commercial flights to operate out of RAF St. Mawgan with its 'lesser' military standards:hmm:.

Aren't the Reubens happy with Oxford and Biggin Hill? As somebody said, seems like sour grapes.

Military/Government aerodromes do not fall into the CAA's ambit; it is as stated in the UK IAIP, the remit of the aerodrome operator and the [civil] aircraft operator/AOC holder to ensure that the aerodrome is fit for use and complies with their own statutory requirement. The regulations, set by the MAA are very closely aligned to those in CAP 168, but this does not meant that they are applied universally; budget restraints in most cases dictate what work can be done to replicate civil standards (and this will usually limit severely any capital expenditure projects).

This is from MoD Defence Infrastructure Organisation

INFORMATION NOTE

Subject: Military Aviation Authority Regulatory Publications (MRP)

Number: 08/11



Background:

1. The Military Aviation Authority Regulatory Publications (MRP) is the regulatory framework for all military aerodromes.Particular to airfield infrastructure, JSP 554 titled ‘Military Aviation Aerodromes Standards and Criteria’ has been replaced with the ‘Manual of Aerodrome Design and Safeguarding’ with effect from the 1 Aug 11.

2. A major change in the ‘Manual ofAerodrome Design and Safeguarding’ is the use of the permissive verb should, this allows regulated entities the opportunity to show acceptable means of compliance otherthan that specified. All such alternative means of compliance must have the prior approval of the MAA confirmed by receipt of a RegulatoryWaiver/Exemption.

3. MAA01: Military Aviation Authority Regulatory Policy is the overarching document and is to be used alongside the‘Manual of Aerodrome Design and Safeguarding’.



So the CAA had no input to use of RAF St Mawgan; Northolt, Brize Norton, or any of the others notified int the IAIP as being available (with consent of the Staish), viz:

Boscombe Down (MoD) Mildenhall (RAF)

Brize Norton (RAF) Northolt (RAF) - Refer to AD 1.3

Kinloss (RAF) Waddington (RAF)

Leuchars(RAF) Yeovilton (RNAS)

1.12.10 The civil use of Government aerodromes is, in addition to the limitations referred to above [para 1.12.1 - 1.12.9], subject to the appropriate charges being paid at the time. Use is also subject to the availability of appropriate Air Traffic Control and crash/rescue services as laid down by Ministry of Defence regulations.

Aeronautical information inrespect of these aerodromes may be obtained from RAF AIDU at Northolt.

1.12.13UK Military Aerodromes are not subject to the specific standards in EURegulation 216/2008 as amended by EU Regulation 1108/2009 (and is now 139/2014 - the equivalent, and eventual replacement of CAP168) and may not complywith the Annex 14 Volumes 1 and 2 of the ICAO Convention. Civil Operatorsrequiring further information should contact the particular aerodrome inquestion; that unit will provide the requisite information and support.

So I think that the proposed legal case might flounder as there is no regulatory need to comply with CAA requirements...as long as there is an acceptable means of compliance in place.

Mister B

I think there’sa bit of confusion here about what this is really about. The primary difference between the MASstandards and the CAA standards as applied to Northolt would be that ifstrictly applied, the licensed or declared runway distances at Northolt would benotably shorter than they are today. Northolt has effectively arrester beds in lieu of any decent RESA strips(Runway End Safety Areas). CAA rulesdictate you can’t use arrester beds instead of RESA, but you can certainly addthem at the end of a pre-existing RESA if you so wish (to stop an aircraftrunning into a building or dual carriageway etc.). Additionally, there are subtle differencesin RFF (fire and rescue capability) compliance, lighting, signage etc. which in comparison to the disparityin runway safety standards are minor.

The point hereis that an MOD funded/underwritten aerodrome has all of a sudden become 70-80%a civilian airport in terms of throughput, taking business from Farnborough,Biggin, Oxford, Luton etc. whilst not having to meet the same standards andincurring the same compliance costs. All those commercially/privately owned airports which do have to complywith civil standards are slightly miffed at the additional competition (or the safety authorities) turning a blindeye to the lack of compliance. Whatthey are after is simply a level playing field on standards. Northolt is completely unique – it’s theonly ‘military’ airport in the UK which has near on 80% civilian traffic – if it wassay 25% civil, people might not be getting so hot and bothered about it. May be the only military airport in Europe like that?

It’s not aboutthe cost, Northolt access is generally more expensive than those otherairports, albeit the costs of running the airport should dictate that it wouldbe appropriate to charge a lot more per civil landing than they do, otherwisethey arguably fall foul to further accusations of unfair competition in so much thataccess by those civil flights are still being underwritten in part by government coffers - our taxpayers money.
Civil slot capacityat Northolt was increased last April by a significant amount without any formal publicenquiry, the MOD would argue that wasn’t necessary, despite the fact that iteffects the same people living close to the Heathrow activity.

The CAA will saythat despite the runway distances being listed in the AIP today being strictlyspeaking (as per CAP168) incorrect, the operators going into Northolt should take it uponthemselves to ignore those ‘declared’ distances and work out for themselveswhat they should really be – but nobody would ever do that, all pilots acceptthe AIP published numbers as gospel and will not drill down any further – it’s an officialcivil aeronautical publication. Uniquely, Northolt is the only military airport with data in the UKAIP - therefore it is a 'special case'. Yet it doesn’t comply with thestandard civil requirements.
Were the CAAtold in a court of law to enforce CAA standards as per the CAP168 onto Northolt in order toassume the correct role as protector of civil aviation safety standards within the UK (as is their role under the Airports Act),in light of the 80% civil usage of Northolt, then it is likely that the useable (declared)runway length would be shortened and a number of aircraft with poor runwayperformance may be limited on what they can take in or out of there, or in somecases, may not be able to use it at all. If the Landing Distance Available (LDA) was down to say 1300m or so, then theimpact would be very significant – only the lightest jets or those with thebest landing performance would be happily continuing access at Northolt. Could end up being predominently King Air territory only in worse case.

So, much as itsounds like ‘sour grapes’, it has everything to do with safety standards and alevel playing field in the sector, fairness of competition. Thetrigger point for getting peer airport’s shackles up was when they arbitrarily increasedthat capacity for business aviation last year without any major consultation. Yes it’s good to make good use of governmentassets but not when artificially pretending you have a longer useable runwaythan you really have – under the same rules applied to all other civilaerodromes.
Shall be interesting to see what happens.

Surely the Aerodrome Manual is the de facto source of information? I know that RAF Northolt has one of the first Defence Aerodrome Manuals (on the open internet) and I seem to remember seeing the arrester beds with pictures under the RESA section.

Also, I've flown into civil aerodromes with obstacles within the approach/take off surfaces and the CAA have issued an exemption (as described in their Aerodrome Manual) for them. The aerodrome still being licenced with this exemption.

LJ

PS 2013 Aerodrome Manual herehttp://www.raf.mod.uk/rafnortholt/ra...0ED096A2DC.pdf look at page 3-3 (although I always thought a RESA was a Runway End Safety Area!).

There may be confusion in some minds, understandably as there are several related publication that could influence the provision of infrastructure and services. These include the references in my post # 13; military publications; CAP 168; EASA regulations 139/2014 (and its legislative predecessors). Add to that the ANO - CAP 393. The OP contains a link to a previous post by me relating to a CAA inspection of Northolt in 2008, at the request of the MoD to ascertain where, if any, differences to CAA licensing standards existed. There were many (I carried out that inspection and produced a lengthy report - which I will not publish here). There is a synopsis in my post via the link of some fundamental differences.

To help in understanding who is supposed to do what, here are some more snippets (full documentation via the CAA website):

Air Navigation: The Order and the Regulations

CAP 393

Use of Government aerodromes

210 With the concurrence of the Secretary of Stateand subject to such conditions as it thinks fit, the CAA may notify any Government aerodrome as an aerodrome available for the take-off and landing of aircraft flying on flights for the purpose of:

(a) the commercial air transport of passengers;

(b) the public transport of passengers; or

(c) instruction in flying,

or of any classes of such aircraft.

UK IAIP (CAP 32)

AD1.1

1.12 Use of Government aerodromes

1.12.2 It is the Ministry of Defence policy to encourage the use of active Government aerodromes by United Kingdom civil aircraft on inland flights, provided this is consistent with defence requirements and local interests. Those aerodromes available to civil aircraft are listed in AD 1.3, but permission to use any government aerodrome must be obtained from the operating authority at the aerodrome concerned before take-off (in this connection filing of a flight plan does not constitute prior permission). Unless there are special circumstances, permission will not normally be given for flights outside normal working hours of the aerodrome concerned.


From Northolt’s IAIP entry: EGWU AD 2.20 LOCAL TRAFFIC REGULATIONS

(a) Northolt is a Government Aerodrome regulated by the Ministry of Defence. No guarantee can begiven that this airfield meets the requirements of ICAO Annex 14 Volume I andII. Operators are to satisfy themselves that they have met all the requirements of the UK Air Navigation Order 2005 and JAR-OPS (See AD 1.1.1 para 12 and AD1.4 para 1.3).

Some of the references are outdated (ANO 2005, JAR-OPS, even though extracted from the current versions of source documents). My bold (highlight seems to have failed)


Mister B

As the airfield has to be there regardless of whether it has 1, 10 or 1000 military and/or civil movements per day, then perhaps we should be thankful that the irreducible spare contributes to the coffers of the MOD and offsets some of the taxpayers bill!!

And here in lies the stupidity of the recent "RESA" changes. Of course the full length of the runway is useable, it is just that some fool has decided to change "safety" regulations. As an example the changes meant that Gibraltar was no longer capable of accepting the Nimrod (before it went out of service) because they had artificially shortened their runway length to comply with the new regulations. An aircraft that operated from an RAF runway perfectly safely for 30+ years could no longer operate from that self same piece of concrete because the threshold markings had been moved further down the runway. It does beg the question: are civil pilots now so bad that they cannot land safely on a designated strip of concrete unless it is 4 miles long and with another 2 miles of run-off area at either end? :E

RP

The requirement for RESA may apper to you to be stupid, but it does demonstrate the different levels of acceptable risk between civil and military safety mentality.

The RESA has been a civil requirement for many years, and its current (or soon to be) form is probably the most flexible it has been.

Definition from the EASA regulation 139/2014:

‘Runway end safety area (RESA)’ means an area symmetrical about the extended runway centre line and adjacent to the end of the strip primarily intended to reducethe risk of damage to an aeroplane undershooting or overrunning the runway.

It is there for good reasons: Mangalore 22 May 2010, B738 overran runway end, 158 killed, 7 serious injuries, 1 minor injuries; one of several reports of similar severity resulting from inadequate RESA that have crossed my desk in the past four years.

Here is the EASA requirement (which pretty much accords with ICAO Annex 14 and CAP 168); note the addition for provision of an arresting system to allow flexibility in reducing the RESA length:

CS ADR-DSN.C.215 Dimensions of runway end safety areas

(a) Length of RESA

A runway end safety areashould extend from the end of a runway strip to a distance of at least 90 mwhere:

(1) the code number is 3 or 4; and

(2) thecode number is 1 or 2 and the runway is an instrument one

If an arresting system is installed,the above length may be reduced, based on the design specifications of thesystem, subject to acceptance by the State.


(b) Notwithstanding the provisions in (a)above, the length of the runway end safety area may be reduced where an arresting system is installed, based on the design specifications of the system.

A runway end safety area should, as far as practicable, extend from the end of a runway strip to a distance of at least:

(a) 240 m where the code number is 3 or 4; and or a reduced length when an arresting system is installed;

(b) 120 m where the code number is 1 or 2 and the runway is an instrument one; or a reduced length when an arresting system is installed; and

(c) 30m where the code number is 1 or 2 and the runway is a non-instrument one

Width of RESA

The width of a runway end safety area should be at least twice that ofthe associated runway.


Your first observation is valid, though...

Mister B

The annual survey at MoD airfields (done by a privatised portion of the PSA before it became Defence Estates) have been using CAP168 design criteria and reporting under CAP232. So that would say to me that the MoD airfields are probably designed to the civvy standards anyway?

By the way, HTB, is the Aerodrome Manual the master documentor the AIP? I'd be grateful for your opinion.

LJ

HTB, lots of 'shoulds' and not many 'shalls'. :)