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The purpose of this stakeholder engagement exercise was for the CAA to understand your views on our new draft Airspace Modernisation Strategy which will replace our 2011 Future Airspace Strategy (FAS).

The Government has tasked the CAA with preparing and maintaining a co-ordinated strategy and plan for the use of UK airspace for air navigation up to 2040, including for the modernisation of the use of such airspace. The Airspace Modernisation Strategy responds to that requirement and forms part of the Government’s new arrangements to take forward the delivery of the airspace modernisation programme. The strategy sets out the ends, ways and means of modernising airspace.

We invited feedback on the draft Airspace Modernisation Strategy – including its approach and the initiatives it set out as the primary ways to deliver modernisation.

We had 263 formal responses to the consultation, which we have published where we have permission to do so. Residents affected by aviation made up the majority of respondents. Of the 152 residents who responded, 74 (49%) used identical or very similar text, and mostly answered no to all questions.

Overall, 39% of respondents said that they agreed or mostly agreed with the approach as set out in the draft strategy (question 1), 5% did not answer. Residents affected by aviation were most likely to answer ‘no’, with 83% disagreeing. Members of the General Aviation community mostly agreed with the overall approach, with 90% saying they agreed or mostly agreed.

The second question asked if we had identified the right existing Government policies. Overall, 41% of respondents said that they agreed or mostly agreed compared to 50% who disagreed (9% did not answer).

Question 3 asked if respondents agreed with the 14 initiatives. Members of the General Aviation community had the strongest percentage in favour at 94%. Commercial aviation industry and national representatives were around 75% in favour. Seventy-nine per cent of residents affected by aviation disagreed. Overall, 41% of respondents said that they agreed or mostly agreed with the initiatives; 7% did not answer.

Question 4 asked if there were any gaps in the strategy and only invited free-text answers with no multiple-choice options.

Question 5 asked if respondents agreed with our approach of asking those organisations tasked with delivering the initiatives to set out deployment plans to identify the means (resources) necessary? Seventy-one per cent of members of the General Aviation community agreed with this approach. Commercial aviation industry and national representatives were 58% and 68% in favour respectively. Seventy-four per cent of residents affected by aviation disagreed with our suggested approach. Overall, 37% of respondents said that they agreed, and 12% did not answer.

Question 6 asked if respondents agreed with our approach set out in the draft governance structure which was developed by the Department for Transport, CAA and NATS working together. For this question the commercial aviation industry was the group with the largest percentage in favour at 74%. Seventy-one per cent of members of the General Aviation community were in favour, agreeing or mostly agreeing, whereas 80% of residents disagreed. Overall, 35% of respondents said that they agreed, and 8% did not answer.

Free text boxes on each question allowed respondents to give their reasoning and explain how the draft Airspace Modernisation Strategy could be improved.

The draft objective for modernisation and the proposed governance structure received the most attention. In terms of the draft objective for airspace modernisation:

• residents affected by aviation were more likely to suggest that the focus should be on noise reduction and other environmental and health issues, rather than growth
• members of the General Aviation community were more likely to express concerns that airspace may become constrained, more complex or would be difficult to influence
• other respondents urged that the objective would need to carefully consider the trade-offs between a range of different issues.

In relation to governance issues raised, we recorded four different sentiments:

• residents affected by aviation and government bodies (i.e. local authorities or parish councils) were more likely to suggest that community groups should be involved in the governance structure
• the General Aviation community was more likely to suggest that they should be more involved in the governance structure
• the commercial aviation industry and national representative organisations were more likely to suggest that industry should be involved at the top of the governance structure.
• a mix of different stakeholders with different reasons wanted the Government and/or the CAA to hold industry to account more in delivery.

Funding and resourcing issues were mainly raised by the commercial aviation industry, the majority either suggesting that the Government should fund the modernisation programme or that those that were funding it should be more involved in the governance structure.

Smaller organisations were concerned that they would not have the resources to participate fully or influence change. Some suggested that the CAA needed to increase its resourcing.

Often raised in relation to the governance structure was the issue of vested interests, and the need for independent oversight or independent programme management.

In terms of technology, the specific points raised were mostly in relation to satellite-based navigation, drones and electronic conspicuity. Commercial aviation industry generally advocated the use of technology to improve efficiency, whereas residents were concerned about the concentration of flightpaths that could occur or had resulted from previous trials.

We have gone into more detail as to what respondents said and our responses to specific issues in our stakeholder engagement response document CAP 1710 Outcome of CAA stakeholder engagement on draft airspace modernisation strategy.

Some of the feedback received related to areas that we could not materially change in the strategy, for example relating to existing government policy or a dissatisfaction with the CAA or aviation industry in general.

However, the following areas, which attracted the most attention, have been updated:

• the CAA and Department for Transport have redrafted the joint objective for airspace modernisation
• the Airspace Modernisation Strategy includes new sections on the governance structure with more detail on the CAA and Department for Transport’s role as co-sponsors, the Delivery Coordination Function and clarification of the governance architecture (CAP 1711b Governance Annex to CAP 1711)
• the Initiatives have been expanded to ensure air traffic management improvements have been captured, and a number of clarifications have been made in response to specific feedback
• the requirements for a design masterplan have been modified and stated in more detail.

The updated Airspace Modernisation Strategy has now been published as required by the Secretary of State by the end of 2018: CAP 1711 Airspace Modernisation Strategy

For more information or clarification on the Airspace Modernisation Strategy please contact airspacemodernisation@caa.co.uk.  

We proposed that the requirement for the recording of a Flight Information Service (FIS), currently mandatory within CAP 797, but recommended within CAP 670 are harmonised and that both documents make the requirement mandatory. 

We asked about the impact of this change and proposed that all units offering a FIS service ensure they are providing recording facilities within a reasonable time scale. 

We proposed that so called ‘Custom PC based’ solutions where recording software is employed on a standard desktop computer are permitted as a temporary measure, and that such systems could be used as an interim solution for up to 5 years, by which point an appropriately approved recording system should be installed.

We received 13 responses to our consultation.  8 from FIS units impacted and 5 from other stakeholders.  The majority of responses were in favour of the proposal, many appreciating the safety benefits such a requirement would bring, many identifying specific examples where the provision of recording has provided critical evidence or would have been beneficial if installed at the time.  A number of responses suggested that such recording should already be mandatory.  The addition of the availability of an audio recording when investigating an accident or incident brings significant evidence and reduces the reliance on evidence from memory.  Many responses appreciated the additional protection this brings for FISO staff.

Specific feedback included:

• Concern that the requirement for minimum specifications would add additional cost.  The CAA believe that a set of minimum specifications is critical to ensure interoperability when playing back recordings and ensures that the recording recovery team can interpret recording files.  Additionally a minimum set of requirements also ensures the credence of recordings which is a critical factor in the protection and retention of evidence.
• Another response highlighted the additional cost of recording land lines due to the technical complexities and differences in recording differing telephone systems.
• One response highlighted the requirement for a safety case and the burden this places on units that will have to produce it.
• A number of units expressed concern regarding the immediate cost of such a system and the continued maintenance cost of such equipment, along with the additional costs due to the requirement to ensure equipment is appropriately accommodated and powered.

Following feedback we are maintaining our proposed approach, in light of some specific elements of the feedback we have made some minor modifications to the proposal and are investigating ways in which we can reduce the burden on individual units who have to install equipment.

As proposed in the consultation, The CAA will not require a full solution to be installed immediately, and for an interim period a PC based solution will be permitted.  Our research has shown that such a system can be purchased at a cost of between £600 and £1000 with little requirement for ongoing maintenance.  This system can be used for up to 5 years before a full system is required.  We believe this is a compromise that will allow time for units to establish funding for equipment whilst maintaining momentum behind the adoption of recording.  It also addresses units that have already made the investment in a PC based system and ensures a reasonable duration of use is achieved from such systems.  This time scale also considers the approaching introduction of the ATM-IR, which is likely to mandate recording of FIS.

The CAA understands that maintenance costs can be kept low and that some manufacturers offer maintenance packages as low as £400 per year.  Whilst the requirement will add some additional costs we believe the ongoing costs that would be passed onto the flying public are acceptable and that the safety benefits of mandating recording outweigh the financial impact.  As discussed within the original consultation, we are aware that a significant majority of FIS units already record radio transmissions.

We have reviewed the requirement for the recording of telephone systems and will modify this requirement to be highly recommended to reflect the considerable costs that could be incurred by having to record a wide range of different systems including VOIP (Voice Over Internet Protocol). 

Overall following feedback we believe the introduction of recording for FIS and the harmonisation of requirements as discussed in the consultation is beneficial for all.

What happens next?

Our intention, following this consultation is to update the relevant documentation to clarify this requirement.  As originally indicated, it is our intention to require all FIS units to provide recording services through appropriate recording equipment within 1 year, this includes the use of a custom PC based recorder, provided it is configured as required by the consultation document.  Finally, within 5 years recording should be provided through the use of appropriately approved systems (as specified within CAP 670).

Please Note:

Please note that the introduction of Regulation 2017/373 (ATM-IR)  may have an impact on the equipment requirements in future.  The CAA will provide updates on the rule making process as it progresses.  Any units making a purchase of equipment are recommended to discuss their requirements with the CAA so the latest information can be considered.

For comments from industry on the following main proposals:

• A general price increase of 2.6% across all Schemes of Charges in 2018/19;
• Proposals of specific charges to cover our costs in four areas where we are undertaking new activities, being

1. Cyber Programme
2. Unmanned Aircraft Systems (UAS)
3. Markets and Competition Work

• Proposals for revised charge concessions in respect of air displays held for charitable purposes and further clarification regarding multiple events.

This document includes the comments received and the outcome: CAA Response

We are grateful for those submissions received and after CAA Board discussion, we propose to implement all proposals made subject to three amendments.

• Markets and Competition Work – reduced funding requirements
• Air Display Charges – additional concessions
• Declared Training Organisations – charges now contained within the Personnel Licensing Scheme

Please see the CAA Response Document for details.