Response 251044272

Back to Response listing

About you

A. What is your name?

Name (Required)
UKACCs (Liaison Group of UK Airports Consultative Committees)

C. Where do you live?

Please select one item
(Required)
East of England
East Midlands
West Midlands
North East
North West
Northern Ireland
Scotland
Ticked South East
South West
Wales
Yorkshire and the Humber

D. Are you answering this consultation as:

Please select one item
(Required)
Resident affected by aviation
Airline passenger
Member of the General Aviation community
Member of the commercial aviation industry
Military
Government and / or other regulators
Ticked Representative or national organisation or institute
Elected political representative

E. Are you affiliated with any organisation?

Please select one item
Ticked Yes
No

G. Do you consent for your response to be published?

Please select one item
(Required)
Ticked Yes, with personal identifying information (name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)
Yes, anonymised
No

General observations

1. Considering the draft guidance overall, to what extent does it meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How would you improve?
I set out below UKACCs’ response to the consultation on the draft airspace design guidance which highlights those matters of common concern to our member ACCs. Individual ACCs have been encouraged to also respond to the consultation direct with their Committee’s detailed comments on the draft guidance. As Rebecca Roberts-Hughes and Nic Stevenson heard at the UKACCs Annual Meeting, delegates welcomed the improved transparency and engagement opportunities of the new process and the enhanced role proposed for ACCs. However there are concerns about the cost and resource needed to undertake the process particularly as the scale of the process and the length of time it would take to complete, the Tier 1a process in particular, may not be appropriate for smaller airports. UKACCs believes that a “one size fits all approach” should not be adopted and steps need to be taken to ensure flexibility can be built into the process so that it can be tailored to suit local circumstances. It is essential that the process adopted is appropriate and proportionate for the scale of the proposed airspace change and the nature of the airport’s operation. UKACCs therefore suggests that at the Design Stage the approach to be taken should be agreed between all parties, including local authority/community representatives and ACCs. The way in which airspace is used and noise management/mitigation are complex subjects. As such it is important that airspace change sponsors in preparing the consultation material and communication plans provide clear advice and the information produced is written in plain English for the lay person to easily understand the proposals, the options and the potential impacts. It is important therefore that the process does not overlook the fact that the knowledge and experience of ACCs can help airspace change sponsors (the airport operator, NATS or other organisations) ensure consultation material is appropriate with the correct balance achieved in not over simplifying the detail of the proposals and impacts. UKACCs has also considered the issues that need to be taken into account at the design principles stage to ensure that potential impact for those communities under the new routes/flight paths are considered at an early stage in the process. UKACCs believes it important that the terrain under flight paths, centres of population, ambient noise levels, legacy routes and forms of respite to relieve the impact of overflight frequency are taken into account at the design principles stage. It has also been questioned whether there is a need to involve the Department for Communities and Local Government given the potential changes to planning law. Some ACCs have highlighted the potential role for committees in helping to ensure the airspace change sponsor has the evidence needed for submission to the CAA at the gateways sign off. This monitoring role throughout the various stages would help to satisfy the ACC’s various stakeholders that the airspace change sponsor has met all the requirements of the process agreed at the Design Stage. UKACCs hopes therefore that this potential role can be referenced in the final guidance document. UKACCs looks forward to having further engagement with your team particularly in helping to identify the specific role that you envisage ACCs could play in the process as well as building a better understanding of the various tier categories. I trust UKACCs’ comments can be taken into account.

Tier 1a: Stages 1 to 7

2. Considering Stage 1 (Define) of the process , to what extent does the draft guidance on that stage meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
UKACCs has considered the issues that need to be taken into account at the design principles stage to ensure that potential impact for those communities under the new routes/flight paths are considered at an early stage in the process. UKACCs believes it important that the terrain under flight paths, centres of population, ambient noise levels, legacy routes and forms of respite to relieve the impact of overflight frequency are taken into account at the design principles stage. It has also been questioned whether there is a need to involve the Department for Communities and Local Government given the potential changes to planning law.

3. Considering Stage 2 (Develop and assess) of the process, to what extent does the draft guidance on that stage meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
Some ACCs have highlighted the potential role for committees in helping to ensure the airspace change sponsor has the evidence needed for submission to the CAA at the gateways sign off. This monitoring role throughout the various stages would help to satisfy the ACC’s various stakeholders that the airspace change sponsor has met all the requirements of the process agreed at the Design Stage. UKACCs hopes therefore that this potential role can be referenced in the final guidance document.

4. Considering Stage 3 (Consult) of the process, to what extent does the draft guidance on that stage meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
The way in which airspace is used and noise management/mitigation are complex subjects. As such it is important that airspace change sponsors in preparing the consultation material and communication plans provide clear advice and the information produced is written in plain English for the lay person to easily understand the proposals, the options and the potential impacts. It is important therefore that the process does not overlook the fact that the knowledge and experience of ACCs can help airspace change sponsors (the airport operator, NATS or other organisations) ensure consultation material is appropriate with the correct balance achieved in not over simplifying the detail of the proposals and impacts. Some ACCs have highlighted the potential role for committees in helping to ensure the airspace change sponsor has the evidence needed for submission to the CAA at the gateways sign off. This monitoring role throughout the various stages would help to satisfy the ACC’s various stakeholders that the airspace change sponsor has met all the requirements of the process agreed at the Design Stage. UKACCs hopes therefore that this potential role can be referenced in the final guidance document.

Tier 1a: Evidence of engagement

9. At certain stages in the process (starting with the development of design principles at Step 1b) the CAA will look for evidence of a two-way conversation to see that the sponsor has adequately engaged stakeholders. In paragraph C9 the CAA describes the evidence that we will look for as "detail of what sponsors have been told by their audiences; how they responded to this feedback; and how it has affected the proposals they are bringing forward".    Has the CAA adequately detailed what we would expect to see to know that a two-way conversation has taken place?

Please select one item
Ticked Yes
No
Don't know
What else to show two way conversation?
The way in which airspace is used and noise management/mitigation are complex subjects. As such it is important that airspace change sponsors in preparing the consultation material and communication plans provide clear advice and the information produced is written in plain English for the lay person to easily understand the proposals, the options and the potential impacts. It is important therefore that the process does not overlook the fact that the knowledge and experience of ACCs can help airspace change sponsors (the airport operator, NATS or other organisations) ensure consultation material is appropriate with the correct balance achieved in not over simplifying the detail of the proposals and impacts. Some ACCs have highlighted the potential role for committees in helping to ensure the airspace change sponsor has the evidence needed for submission to the CAA at the gateways sign off. This monitoring role throughout the various stages would help to satisfy the ACC’s various stakeholders that the airspace change sponsor has met all the requirements of the process agreed at the Design Stage. UKACCs hopes therefore that this potential role can be referenced in the final guidance document.

Tier 1a: Options appraisal

13. In paragraph E25 and E34 the CAA states that methodologies for the various aspects of the options appraisal should be agreed between the CAA and the sponsor at an early stage in the process, on a case-by-case basis. This provides flexibility for different local circumstances. Does this approach strike the right balance between proportionality and consistency?

Please select one item
Ticked Yes
No
Don't know
OA - explain re proportionality
UKACCs welcomed the improved transparency and engagement opportunities of the new process and the enhanced role proposed for ACCs. However there are concerns about the cost and resource needed to undertake the process particularly as the scale of the process and the length of time it would take to complete, the Tier 1a process in particular, may not be appropriate for smaller airports. UKACCs believes that a “one size fits all approach” should not be adopted and steps need to be taken to ensure flexibility can be built into the process so that it can be tailored to suit local circumstances. It is essential that the process adopted is appropriate and proportionate for the scale of the proposed airspace change and the nature of the airport’s operation. UKACCs therefore suggests that at the Design Stage the approach to be taken should be agreed between all parties, including local authority/community representatives and ACCs.

Tier 2: Permanent and planned redistribution

18. The Government proposals talk about a Tier 2 change as one which is likely to alter traffic patterns below 7,000 feet over a populated area and which therefore could have a potential noise impact for those on the ground. The key requirement is that the air navigation service provider must demonstrate that it has assessed the noise impact of the proposed change and engaged with affected communities as appropriate. Which stages of the Tier 1a airspace change process do you think are necessary for a proposal categorised as a Tier 2 change? Please select all those which apply:

Tier 2 reasons
UKACCs welcomed the improved transparency and engagement opportunities of the new process and the enhanced role proposed for ACCs. However there are concerns about the cost and resource needed to undertake the process particularly as the scale of the process and the length of time it would take to complete may not be appropriate for smaller airports. UKACCs believes that a “one size fits all approach” should not be adopted and steps need to be taken to ensure flexibility can be built into the process so that it can be tailored to suit local circumstances. It is essential that the process adopted is appropriate and proportionate for the scale of the proposed airspace change and the nature of the airport’s operation. UKACCs therefore suggests that at the Design Stage the approach to be taken should be agreed between all parties, including local authority/community representatives and ACCs.

Tier 3: Other changes to air operations affecting noise impacts

21. To what extent does the draft best practice guidance on Tier 3 changes (other changes that may have a noise impact) meet the following criteria?

How to improve
UKACCs believes that a “one size fits all approach” should not be adopted and steps need to be taken to ensure flexibility can be built into the process so that it can be tailored to suit local circumstances. It is essential that the process adopted is appropriate and proportionate for the scale of the proposed airspace change and the nature of the airport’s operation.