Response 454959128

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Introduction

1. Are you responding in an official capacity on behalf of an organisation?

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Yes
No
Bliss Aviation

2. What is your name?

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Graham Smith

4. Are you answering as:

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Resident affected by aviation
Airline passenger
Member of the General Aviation community
Member of the commercial aviation industry
Central or local government body including military
Elected political representative e.g. councillor or MP
National representative organisation e.g. trade association
Local organisation e.g. community action group
Other

5. Where do you live or where is your organisation based?

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East of England
East Midlands
West Midlands
North East
North West
Northern Ireland
Scotland
South East
South West
Wales
Yorkshire and the Humber

6. Is there anything else that you would like us to know in connection with your response?

General
Former commercial pilot, current instructor, Msc

7. Do you consent to your response being published?

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Yes, with personal identifying information (name, organisation, respondent category, location, additional information – please note your email address will NOT be published if you choose this option)
Yes, anonymised
No

8. CAP 1887 details the proposed criteria to be used to inform whether to accept the Airspace Change Masterplan, which is being created by the Airspace Change Organising Group (ACOG), an impartial team in NERL. Do you have any general comments you would like to share on the proposed criteria for assessing and accepting the Airspace Change Masterplan?

Noise should not be considered unless accompanied by actual measurements and comparisons. Current jet transports are very quiet, making less noise of shorter duration than petrol powered garden tools, mopeds, emergency vehicles, tractors, delivery vans and refuse collection vehicles.

9. Are the proposed criteria detailed in CAP 1887 the right criteria to enable acceptance?

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About right
Minor modifications needed
Significant modifications needed
Don’t know
The document is largely incomprehensible and gives no indication of the airspace changes proposed.

10. Chapter 3 of CAP 1887 details the policy considerations that are relevant to the Airspace Change Masterplan. Are there examples of where further policy may be required to guide trade-off decisions?

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Yes
No
Don't know
80. Is it thought that manufacturers and operators are using procedures that do not already minimize external noise and fuel consumption? Are aircraft SOP's within the remit of this document?

...growth which may adversely affect noise...(sense?) Add: ...require that noise impacts are measured and considered...

...not conflict with national security requirements... This is the biggest trade-off required, without which no change of consequence can happen. The phrase is a catch-all which can mean anything. Military operations are aggressively territorial, seeking as much airspace as possible regardless of it's planned use. While it is evident that military exercises require a large block of airspace, this should only be available for the duration of the exercise and released for general use when complete.

GA needs to accept trade-off's too. Is there any need for VFR flight above 10,000ft? Two exceptions would need consideration; gliding and para-dropping.

Consider the routes taken by commercial aircraft departing R06 EGPH destination EGSS and EGHH destination LEMG or EIDW. Consider the recommended VFR route St Catherines Point to LFRC.

11. Chapter 4 of CAP 1887 details the engagement expectations for the Airspace Change Organising Group (ACOG) to undertake. Do you have any comments on the engagement we are asking ACOG to undertake?

The need for all parties to accept that the boundaries of controlled airspace must be simple to depict, understand and identify. Standardisation of CA in the vicinity of airports would facilitate this. I have submitted a paper on this subject to GASCO and the CAA.