Could Airport KKOP Restrictions Affect an Extra Villa Floor in Bali?

A three-storey house across the road can make another floor seem like an ordinary design decision. Around Bali’s operational I Gusti Ngurah Rai Airport (DPS), however, the neighbouring roof tells you very little about the aviation limit applicable to your parcel. Its terrain level, exact position relative to the runway and approved design may all differ from yours.

Indonesia calls the protected area around an aerodrome the Kawasan Keselamatan Operasi Penerbangan, or KKOP. Aviation Law No. 1 of 2009 addresses buildings and other obstacles within this area, supported by aerodrome safety regulations. Those controls are concerned with potential obstructions to aircraft operations. They cannot be distilled into a single storey count for every site in Kedonganan, Tuban or Jimbaran.

An additional villa floor raises two separate questions: which official protective surface applies at the plot’s horizontal coordinates, and how high the proposed structure will reach in a compatible elevation reference. Neither a permit for an earlier version of the house nor an estimate of the distance to the terminal settles both questions. The decision guide below identifies the next piece of evidence to obtain; it does not issue building clearance.

A villa drawing might give the roof height above the ground-floor slab. An airport obstacle assessment needs a different measurement: the elevation reached by the structure in a vertical reference system compatible with the applicable KKOP surface. A surveyor must identify both the horizontal coordinates and the elevation datum, while the architect identifies the points that could reach highest into the protected airspace. A number measured from an arbitrary site datum is not yet an airport-comparable elevation.

Consider an illustrative calculation, with no Bali measurements involved. Two proposed structures are each 8 m high above their respective ground points. Site A has a ground elevation of 5 m, giving a highest point of 13 m. Site B starts at 22 m and reaches 30 m. All these figures use one hypothetical vertical reference. They are teaching numbers, not measurements of Bali plots or KKOP height limits. Neither project can be declared permissible from the calculation alone: the two sets of coordinates might be governed by different safety surfaces.

Terrain makes the question more involved than simply adding two figures. On a sloping property, the ground at the entrance may be lower than the ground below another wing. An upper terrace, parapet, water tank or antenna may be taller than the nominal roofline. The competent assessor needs to know which fixed structures and equipment count for the proposal, and the designer should be able to give the relevant top-point elevations. A single average ground level can conceal a critical corner of the building. Where the footprint is irregular, the maximum above-ground measurement and the maximum absolute elevation may even occur at different points.

The boundary survey matters for the same reason. 'Jimbaran villa' is a description, not a surveyed polygon. A dropped map pin does not establish where the edges of the parcel, the proposed extensions and their highest points lie relative to the actual runway and mapped safety sectors. Ask a qualified local surveyor for coordinates tied to a declared coordinate reference system, with a source, date and link to the land identification. The architect can then match the survey to the proposed drawings. For a purchaser, this work is particularly relevant before a non-refundable deposit is committed on the assumption that an extra level will be possible.

The elevation data should also be auditable. A spot height taken from a phone app, an unlabelled contour drawing and a roof-level figure in a different vertical datum cannot be combined as though they share an origin. If the official aerodrome document specifies its own elevation reference, the relationship to the site survey must be established by an appropriately qualified professional. The aim is a defensible comparison, not an online estimate to the nearest centimetre.

Construction can introduce a separate obstacle question. Rooftop plant, tanks and aerials belong in the discussion of the permanent highest point where the authority considers them relevant. A tower crane or temporary lifting operation may need its own assessment or operating conditions, depending on the applicable rules and the authority’s instructions. Once the parcel position and design elevations are documented, the numbers can be assessed against the relevant current KKOP surface. Until that surface is reliably identified, 'available headroom' is not a result anyone should rely upon.

Being 'near the airport' does not tell an architect which restriction to apply. Article 206 of Indonesia’s Aviation Law No. 1 of 2009 distinguishes several KKOP areas, including approach and take-off, transitional, inner horizontal, conical and outer horizontal areas. Their geometry is related to aerodrome operations. A parcel’s place within that geometry must be established before a relevant obstacle-height comparison can be made; driving distance from the passenger terminal is not the determining variable.

For one villa the issue may involve a surface associated with a runway approach; another parcel in the same named neighbourhood may relate to a different mapped sector or a boundary that needs clarification. Ground elevation then changes the actual top elevation of the proposed building. A useful map must therefore come with an identifiable issuing authority, date or version, legend, horizontal coordinates and a stated vertical reference where heights are to be compared. A screenshot sent by an agent can help locate a question, but not answer it conclusively.

The Ministry of Transportation lists KM 93 Tahun 2021, the master-plan decision for I Gusti Ngurah Rai Airport, as in force. That registry entry is important, but it is not itself a readable, plot-level obstacle-height surface. The relevant annexes, any later operative changes and the correct technical reference need to be identified for the particular proposal. The current aerodrome framework includes PM 95 Tahun 2021 (CASR Part 139) and the technical manual PR 21 Tahun 2023 (MOS Volume I). PM 55 Tahun 2023, a regulation on airport-location procedures, expressly revoked KM 44 Tahun 2005 in the ministry’s legal register. The former rule making SNI 03-7112-2005 mandatory must not be recycled as if it remained an independently operative height schedule.

Indonesia’s Satu Data portal also lists a KKOP spatial dataset with resources described as GeoJSON, CSV and other geospatial formats. Its existence should not be confused with a verified elevation model for every villa parcel at DPS. The published catalogue alone does not demonstrate that a particular resource covers Ngurah Rai, carries an applicable elevation limit, uses a compatible datum or has the necessary legal status. The appropriate starting point is the applicable official airport documentation, not a colour-coded public map without a traceable basis.

There is a further distinction between interpreting a map and obtaining an official position. The survey and overlay can identify what the designer believes applies. If a safety-surface boundary is uncertain, or the relevant issuing instrument cannot be established, an aviation authority needs to resolve that uncertainty. A technically plausible sketch does not grant permission for an added storey.

These are gaps in the evidence behind a height claim, not automatic findings that an existing building is unlawful.

An owner near Ngurah Rai can now identify a more specific route than a generic airport contact. Kantor Otoritas Bandar Udara Wilayah IV I Gusti Ngurah Rai — Denpasar publishes a public-service standards decision on its official website. Annex XIII of the linked 2024 decision covers Penerbitan Rekomendasi Batasan Ketinggian Bangunan, Benda Tumbuh dan Benda Bergerak pada KKOP: recommendations about height restrictions for buildings, growing objects and moving objects within the protected area. The annex identifies the application addressee, a technical review process and the signatory. It is a regional administrative standard, although its continued applicability to the precise proposal should be checked when applying.

Under that published standard, the request for a proposed building goes to the Head of Airport Authority Region IV. The listed attachments are identification for the applicant or person responsible for the building, a business licence for companies, a site-location plan, and proposed-building drawings showing shape and dimensions. The document does not impose a business registration number (NIB) on every private homeowner. For an extension, it is also sensible to supply the existing PBG drawings and mark precisely what will change. That additional design material is practical preparation, not a claim that the annex expressly requires each item.

The stated review route involves an initial KKOP assessment, followed by information on the applicable non-tax state payment (PNBP) and confirmation of the field measurement. Surveyors then inspect and measure the site; the technical findings support a formal letter signed by the Head of Region IV. The annex specifies 14 days from application for the recommendation, but the text dates from 2024 and its publication on the authority’s site does not guarantee that every 2026 application will finish in that period. Ask the office to confirm the currently applicable timing rules and fee basis. An older citation to a government tariff instrument is not enough to quote a current price.

There is a distinction between the annex's listed application documents and what a specialist may need for a sound height assessment. A drawing of the plot without traceable coordinates or a roof level without a compatible elevation datum is an inadequate basis for assessing the actual obstacle. Have the surveyor and architect prepare a surveyed polygon, ground elevations, existing and proposed sections, and the highest relevant rooftop points. The authority can confirm the formal submission format and whether temporary construction equipment needs its own consideration.

A focused enquiry can read: 'Which current KKOP map and elevation reference apply to these coordinates near I Gusti Ngurah Rai?' Next: 'Does this private villa extension fall within the Annex XIII height-recommendation service, and what additional survey or drawings are needed?' Finally: 'How should a temporary crane be assessed?' For procedural enquiries, Region IV’s PPID lists info@otoritasbandara.info and +62 361 9351710. A reply simply identifying a map or referral is not the same as the signed height recommendation. The latter should identify the proposal, reference the assessed height and set out any conditions. No response is not an approval.

Even once a recommendation is obtained, the owner needs to preserve the exact drawing revision on which it relied. Raising a parapet, installing equipment on the roof or moving the extension across a sloped parcel can change the assessment. The PBG approval path must still address the actual revised building. Until the relevant written aviation position is in hand, an additional floor is a potential design option—not an entitlement that can safely be priced into a non-refundable purchase or construction commitment.

PBG stands for Persetujuan Bangunan Gedung, Indonesia’s building approval. Government SIMBG guidance expressly treats construction, alteration and extension as activities covered by this approval framework; applications involve technical building documentation and the competent local government services. Airport KKOP rules address a different safety question: does the proposed structure, at its actual location and highest elevation, meet the restrictions protecting aircraft operations? A project near Ngurah Rai can need evidence on both fronts.

It would be wrong to assume that an existing PBG never involved aviation checks. The original approved file could contain a relevant height recommendation or other official supporting decision. If so, the question becomes whether that decision is genuine, applicable to this parcel and still matches the design now being considered. The approved drawings may describe a two-storey villa, while the sales brochure depicts a third-floor terrace and a raised roof tank. Calling both images 'the same property' does not make them the same permitted proposal.

Equally, a PBG cannot be borrowed from the house next door. Its owner’s approved footprint, ground elevations, submitted rooftop equipment and underlying aviation assessment may be entirely different. There is no sound basis for judging whether that neighbouring villa is lawful from its appearance alone. For your own extension, the old file should be compared point by point with the latest sections and site survey. Any revised building approval must follow the applicable SIMBG and local authority route, while the aviation question must be resolved under the operative KKOP arrangements.

A clear working file therefore contains two strands of evidence: the building design and its PBG status, and the aviation basis supporting the proposed top elevation. They may be handled through linked administrative steps in some cases, but the existence of one document should not be taken as proof that the other issue has been resolved. A consultant’s statement, a screenshot of a map or a previous permit with different drawings cannot bridge that evidential gap.

This distinction matters most before money changes hands. A buyer acquiring a parcel specifically to build another floor should not treat the extra saleable or usable area as secured merely because the current villa is occupied and has paperwork. The purchase or design commitment can be made conditional on satisfactory written findings, with the consequences of a lower permitted height understood in advance. Construction itself requires the approvals applicable to the final proposed structure. This article cannot give a parcel-specific legal height where no verified official surface and site decision have been established.