Response 727242427

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About you

A. What is your name?

Name (Required)
Andy Sinclair

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
Ticked Member of the commercial aviation industry
Military
Government and / or other regulators
Representative or national organisation or institute
Elected political representative

E. Are you affiliated with any organisation?

Please select one item
Ticked Yes
No
Affiliation
Gatwick Airport Ltd
Please select one item
Ticked Yes
No

F. Is there anything else that you would like us to know about you regarding this consultation?

Please enter any further details
Gatwick’s plans to accommodate future growth in traffic from the current runway infrastructure will need a robust and transparent framework for airspace change, in which airport and airlines, air traffic control, and communities affected by noise can collectively reach well informed views of the options. Gatwick aims for open dialogue with local stakeholders, and seeks a fair and equitable distribution of noise, and a fair balance between the benefits to passengers of growth in traffic and reductions in local noise and other environmental impacts. In the near term, airspace modernisation could help deliver improved flight efficiency and noise respite benefits to affected communities, in this context a balanced, well-articulated, efficient and effective airspace change process is critical in delivering environmental improvements.

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

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(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(name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)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 Considering the draft guidance overall, to what extent does it meet the following criteria?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
Ticked 1: the guidance is good and meets this criterion 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?
There has in the past been a reluctance to amend the airspace change process guidance which has meant, in a number of areas, the guidance has lagged behind industry developments and the evolution of regulatory policy. Given the guidance is designed to be web-based it has the potential to be updated more readily. With this in mind a plan for review of the process guidance should be put in place after an initial period and then for routine updates at set periods following its introduction. This could be timed to follow periodic reviews of related DfT Policy. GAL supports the Government’s objective of delegating consultation and decision-making to the appropriate local or regulatory level. However, GAL also encourages the Government to set out clear strategic guidance that can help reach conclusions at the airport level, and which avoids fostering endless unproductive debate. The changes in the guidance must be supported by the deployment of suitably qualified technical expertise in appropriate numbers within the regulator to mitigate risks to the management of the new process. Tier 1 airspace changes are, by definition, of national strategic importance. As such, they inevitably entail complex and far-reaching judgements which balance a range of potentially competing economic, environmental and operational factors. The Government must provide clear overarching policy guidance on how it would approach such changes, setting out the evidence it would use and how it would weigh such evidence. Without such policy guidance, there would be a risk that potentially beneficial strategic airspace changes could founder and lose momentum if they are not seen to be in alignment with a clearly stated Government policy in the national interest. Page 17 – While the draft guidance on the airspace change process understandably does not take into account ICCAN’s proposed role due to the awaited outcome of the DfT Airspace Policy Framework consultation the CAA should be mindful of the need to continue to make available to the aviation sector sufficient resources and policy leadership to enable airspace changes to be processed efficiently and effectively. Without this, there is a risk that attention within both newly established and existing organisations could be focused overly on the management of change, to the detriment of immediate requirements to contribute to airspace changes. Page 17 – The consultation is clear that the CAA will amend the CAP 1520 guidance as necessary once the outcome is known, but without consulting further. The current ambiguity of the role of ICCAN, for example the roles of ICCAN at page 17 may be interpreted as mandatory (ie ACP sponsors ‘shall’ or ‘must’ seek ICCAN advice on noise management techniques and accessibility of noise information or rather ‘may’ seek ICCAN support). This ambiguity of role and lack of defined wording reinforces the lack of clarity over ICCAN’s part to play in the process and this in turn may impact on the timings set out as part of the process for stages 3D and 4. The existing guidance (CAP725) includes more generally clarity on use of clear terminology in terms of ‘must’ (or in some cases shall), ‘should’ or ‘may’. GAL would welcome the definition and inclusion of this terminology in line with other aviation guidance.

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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion

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
Ticked 1: the guidance is good and meets this criterion 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 analytical tool proposed for airspace options appraisal is WebTAG, the Government’s generic transport appraisal framework. It is acknowledged that this has not been developed with airspace change in mind, although it does include a module for assessing the impact of aircraft noise. In order to provide clarity and confidence for the aviation sector and the communities affected by aircraft noise that WebTAG is indeed fit for the purpose of airspace change options appraisal, the Government should commission the CAA now, and ICCAN subsequently following its establishment, to develop guidance on the use of WebTAG specifically for airspace change. Such guidance might demonstrate best practice examples of how a previous airspace change could have been appraised using WebTAG. It could also demonstrate how in practice an appraisal of options could bring together evidence from a range of fields (safety assessment, operational efficiency, noise impacts, etc.), and present a balanced picture of qualitative, quantitative, monetised and non-monetised factors. To enable the principle of decision-making informed at the local level to be put into practice effectively, WebTAG will need to be configured to allow locally-based judgements and weighting to be incorporated into the process. In particular, the calculation of costs and benefits of concentration and dispersal will need to be able to take into account local circumstances as well as the desires of local communities.

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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion

5. Considering Stage 4 (Update and submit) 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion

6. Considering Stage 5 (Decide) 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
Ticked 1: the guidance is good and meets this criterion 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 2: the guidance mostly meets this criterion Ticked 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
Ticked 1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
The suggested criteria for Secretary of State call-in require further work to define better the triggers, taking into account factors such as location and other sensitivities. First, the focus on the net number of people affected by aircraft noise arising from a specific airspace change overlooks the potentially much larger numbers of people who may be newly exposed to significant levels of noise, offset by others who may be relieved of noise impacts. For example, an airspace change could result in 100,000 people being newly affected by noise and 91,000 relieved of significant noise impacts, resulting in a net impact of 9,000. In this case, a substantial airspace change affecting a very large population would not meet the criteria for political oversight and decision-making. Alternatively, this metric could encourage perverse behaviours which allow sponsors to break down airspace changes into smaller components in order to ensure change proposals fall below any set threshold. Netting off implies a comparable noise tolerance of each group, which may not in practice be a reasonable assumption. Some of those living with aircraft noise will have demonstrated through their home location decisions a tolerance of noise which is likely to be higher than for the population as a whole. Conversely, the newly affected population groups are likely to be self-selected more sensitive residents who chose to live in a relatively quiet location, compared to those who chose to live in a noisier area that has been noisier for many years. Second, the single measure of those affected, the daytime 54dB threshold, may miss some people significantly affected, and hence fail to be in line with Government noise policy to limit the number of people significantly affected. For example it may miss changes in night noise. Third, if a threshold were to be set, a net additional 10,000 people affected seems high. By way of reference, there were 11,300 people exposed to noise above Leq 54dB around Gatwick in 2015. It also appears high considering the Secretary of State’s role in determining planning applications for other noise-producing infrastructure, such as road or rail improvement schemes, whose effects may be very local in comparison. In refining the criteria for Tier 1 change, GAL would caution against adopting a UK Aeronautical Information Publication (AIP) change as a criterion to define Tier 1 change. AIPs are changed for a variety of reasons, from relatively minor tactical modifications to aircraft operation procedures up to and including changes necessary to implement major strategic airspace changes. The fact of AIP change in and of itself would not justify a Tier 1 categorisation. Conversely, though, a Tier 1 change would be very likely to be associated with one or more implementing AIPs changes. Finally, the Government could helpfully consider further the potential for differentiated approaches to assessing the different categories of Tier 1 changes: permanent planned changes, temporary changes for special events, and trials of changes which may become permanent. In order for the UK aviation sector to be able to achieve the sustainable growth potential outlined by the Government, then airspace modernisation needs to proceed at an efficient pace. Trials of novel airspace design, technology and concepts can contribute to airspace change by providing more rapid feedback and data to airspace change promoters on operational and noise impacts. These data in turn enable better informed policy decisions on the proposed change. These benefits of trialling airspace changes could be lost if the process of assessing trials of Tier 1 changes became so onerous as to deter the use of trialling, thereby slowing the overall pace of airspace modernisation.

7. Considering Stage 6 (Implement) 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion

8. Considering Stage 7 (Post-implementation review) 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
Para 264 describes the ‘Outcomes of the Post Implementation Review’. The recent GAL experience following the Route 4 PIR has shown that there is an additional outcome which was a conclusion that endorsed the outcome of the airspace change but that there were additional measures GAL might take in order to address issues that has arisen during the course of the airspace change. Additional guidance should be included in CAP 1520 to accommodate ‘CAA suggestions’ that go beyond the original ACP objectives on the basis of lessons learned from the ACP and PIR.

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?
GAL would propose that the CAP 1520 guidance should not be prescriptive; scenarios or examples of for evidence of the ‘two-way conversation’ with stakeholders to establish whether the sponsor has adequately engaged.

Tier 1a:Third-party facilitation

10. At various points in the process (starting with the development of design principles at Step 1b) the CAA suggests that voluntary use of a third-party facilitator could be useful. Should the CAA be more prescriptive as to how and when a facilitator could be used?

Please select one item
Yes
Ticked No
Don't know
Facilitator further detail
The GAL experience has reinforced the value of independent facilitation in support of a number of activities with communities and industry. The outcomes of work of the Gatwick Noise Management Board has been enhanced through the use of independent facilitation. Recent experience through the Gatwick Noise Management Board reinforces the use of this type of function should be at the discretion of the sponsor not prescribed by strict CAP1520 guidance rather suggested in line with current wording.

11. Are there any other places in the process at which you feel that a facilitator would be useful?

Facilitator - which places
No

Tier 1a: Categorisation of responses

12. In paragraphs 177 and C34-C36, and Table C2, we discuss the categorisation of consultation responses. The sponsor is required to sort consultation responses into two categories: i) those responses that have the potential to impact on the proposal because they include new information or ideas that the sponsor believes could lead to an adaptation in a lead design option or a new design option, and ii) those that do not. Is the CAA's explanation of the categorisation exercise and description of the categories sufficient?

Please select one item
Yes
Ticked No
Don't know
Categorisation - additional detail
The categorisation of responses as per the current proposals whilst appearing to offer a clear cut methodology for defining, sorting and taking action may be too rigid a process. Given it is likely that elements from many responses can fall into either category a more nuanced approach might be more appropriate. The process for categorising responses must remain transparent but should allow the sponsor to provide a more discerning means of sifting response content.

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
Yes
Ticked No
Don't know
OA - explain re proportionality
Appendix E - The DfT Airspace Policy Framework consultation acknowledged that the WebTAG/Green Book methodologies set out in the CAP 1520 as frameworks for assessing the costs and benefits of proposals had not been developed with airspace change in mind, although a module for assessing the impact of aircraft noise is included. In order to provide clarity and confidence for the aviation sector and the communities affected by aircraft noise that WebTAG is indeed fit for the purpose of airspace change options appraisal, the Government should commission the CAA now, and ICCAN subsequently following its establishment, to develop guidance on the use of WebTAG specifically for airspace change. Such guidance might demonstrate best practice examples of how a previous airspace change could have been appraised using WebTAG. It could also demonstrate how in practice an appraisal of options could bring together evidence from a range of fields (safety assessment, operational efficiency, noise impacts, etc.), and present a balanced picture of qualitative, quantitative, monetised and non-monetised factors. In particular this might usefully include how WebTAG might be configured to best enable locally-based judgements and weighting to be incorporated into the process. E1-E2 – GAL recognises the efficacy of an approach exploiting options appraisal supported by a robust cost benefit analysis which is evolved through the airspace change process. With the appropriately detailed frameworks this will enable a manifestly more transparent and consistent process through which alternative solutions may be considered. However, para E2 states: …’growth in traffic at airports, in particular in the London area, could result in competing bids for a given volume of airspace – or proposals to change the same volume of airspace in different ways.’ This would appear to propose an alternative purpose to the options appraisal and assessment framework. GAL would propose that unless this intent is explicit – in which case far more guidance and consultation will be necessary – the example be removed from the text at E2.

Tier 1a: Safety information

14. At each stage in the airspace change process that an options appraisal takes place, the sponsor will be required to submit a safety assessment. The sponsor will be required to provide a plain English summary of the safety assessment and the CAA will provide a plain English summary of its review (i.e. of the Letter of Acceptance, which forms the CAA’s review of the safety assessment) when it makes a decision. These documents will be available on the portal.   Do you have any views on specific information that should be included and/or excluded from the plain English summary of the sponsor’s safety assessment and the CAA’s review? 

Safety assessment
The safety assessment is an important element of the various aspects of analysis of an airspace change. Depending on the nature and rationale for change the importance of the safety assessment to those who might need a ‘plain English summary’ (i.e. non-technical stakeholders) will vary. The GAL view is that a summary of the safety assessment is all that would likely be necessary; sufficient to put a clear case and build confidence - from a safety perspective – for those non-technical stakeholders. Those stakeholders with an interest in the technical aspects of the safety assessment (i.e. industry stakeholders) should be sufficiently engaged and informed for plain English versions to be unnecessary.

Tier 1b: Temporary airspace changes

15. Considering Tier 1b changes, to what extent does the draft guidance on temporary airspace changes meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
Para 272-273 – The definition of a Tier 1b (Temporary Airspace Change) appears to exclude flypasts and public air displays. It also appears to define a 1b change as a scenario in which the classification, structure or routes of the actual airspace is altered. It may be prudent to include some of this text in the main body of the definition rather than the footnote. It may also be useful to include some clarification regarding recurring changes and whether the 90 days is cumulative over for example a rolling 12 month period. Para 274 – ‘…Tier 1b is used for specific events or operating conditions that require a temporary change, whereas Tier 1c is used for an operational trial of innovative airspace design or of the use of new technologies.’ This wording should be expanded to include ‘operational concepts’ which might be seen as distinct from design and technology.

Tier 1c: Operational airspace trials

16. Considering Tier 1c changes, to what extent does the draft guidance on operational airspace trials meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
Ticked 1: the guidance is good and meets this criterion 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 2: the guidance mostly meets this criterion Ticked 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
Ticked 1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
o How would you improve the draft guidance? The guidance is comprehensible and proportionate but there could be more clarity. It is clearer that there will be a review and certain of the stages do not have to be followed. However, the inclusion of a couple of scenarios that show examples of a change that do not require the full process and what has to be completed could provide more certainty and clarity. Para 287 – ‘The CAA will usually only agree to a live trial where it involves innovative airspace design or new technology.’ This wording should be expanded to include ‘operational concepts’ which might be seen as distinct from design and technology. GAL is of the view that trials in design, concepts and technology will be necessary over the period of developing our airspace plans in support of LAMP. Paragraph 290 – ‘The CAA requires the trial sponsor to:… collate, monitor and report to the CAA on the level and contents of any complaints associated with the trial throughout its period.’ This single bullet places on emphasis on noise without consideration of, or reference to, other metrics by which the success or otherwise of a trial might be measured. The inclusion of an additional bullet point which also refers to the monitoring of previously agreed data/metrics would be appropriate. Paragraph 291 – ‘If the basis of the complaints, and not just how many have been made, suggests that the trial is not resulting in the anticipated outcomes, the CAA will investigate urgently.’ The recent GAL experience during the Route 4 monitoring period makes clear that this is not a simple exercise and requires prior planning and firmly agreed ‘complaint criteria’ to ensure the capture of complaints in a way that can be distilled and shared as part of the regulatory oversight of any trial. However, the point places increased emphasis on noise without regard for other metrics which may also be required. A more generic paragraph would be more appropriate, for example: ‘If ongoing monitoring and analysis of trial data (including the basis of noise complaints rather than numbers made), suggests that the trial is not resulting in the anticipated outcomes, the CAA will investigate urgently.’

Tier 1: Spaceflights

17. On 21 February 2017 the Government published the Draft Spaceflight Bill. As the foreword to the draft Bill sets out, “This legislation will see the Department for Transport and the Department for Business, Energy and Industrial Strategy, the UK Space Agency, the Civil Aviation Authority and the Health and Safety Executive working together to regulate and oversee commercial spaceflight operations in the UK.” Do you have any views on whether this process could be used or adapted to suit future airspace change proposals to enable spaceflights, as anticipated in the Draft Spaceflight Bill?

Spaceflight
The Space Flight Bill includes references, under section 4 Range Control, to the need for airspace and the safe management of spaceflight in the context of airspace. In delivering airspace change to support spaceflight the DfT Airspace Policy Framework and UK CAP1520 are the appropriate means to provide the policy guidance and regulatory frame to guide any airspace changes necessary to support space flight. Airspace change to support space flight should be subject to the full airspace change process, including full consultation, as set out in CAP 1520 to ensure a complete understanding of impacts of these flights including any constraints that may be placed on the air traffic route network as a result; this is particularly relevant if upper air routes are to be closed for extended periods.

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:

Please select all that apply
Ticked Stage 1 Define
Ticked Stage 2 Develop and assess
Ticked Stage 3 Consult
Ticked Stage 4 Update and submit
Ticked Stage 5 Decide
Ticked Stage 6 Implement
Ticked Stage 7 Post-implementation review
None of these
Don’t know
Tier 2 reasons
The comprehensive process set out for Tier 1a airspace changes may not always be appropriate or proportionate to address a Tier 2 change, especially if related to a safety driven change. It is considered therefore that a more flexible approach should be applied. Whilst it may be appropriate to include stages 1-7 in developing a Tier 2 change this must necessarily be flexible and proportionate to the change under consideration. The CAA policy on appropriate change processes for Tier 2 airspace changes should also encourage existing industry best practice, such as the optimised engagement offered by mechanisms such as Gatwick’s Noise Management Board.

19. The CAA’s process for Tier 1a changes is scaled into ‘Levels’, based on the altitude-based priorities in the Government’s Air Navigation Guidance (i.e. where noise impacts are to be prioritised or considered alongside carbon emissions, a more demanding consultation is required). Could the future Tier 2 process also be scaled?

Please select one item
Ticked Yes
No
Don't know
Tier 2 - scaled reasons
Tier 2 changes could be scaled in a similar fashion. Perhaps a view taken about the airspace structure in which the changes take place might be considered. Changes to operations which remain within the ‘design tolerances’ of the existing structure but that will nevertheless change the impact of aviation noise could form part of a scaling process. Also as changes could be lateral (i.e. through changes to vectoring practices) or in the vertical plane this could form part of the scaling process. From past experience at Gatwick, changes due to altered vectoring practices in the Gatwick radar manoeuvring area (RMA) have made a clear difference to the distribution of noise. The complexity in this example is that the RMA was designed for the purpose of tactical vectoring and the change itself was driven by a CAA safety imperative to reduce the risk of unstable approaches. The DfT proposal regarding Tier 2 changes explicitly cites a number of exclusions including when there is an overriding need to maintain air safety. This should necessarily be included as it may be assumed that a safety driven change defined as a Tier 2 change may be treated more akin to a Tier 3 change in that it would be necessary to engage with, and inform, communities and stakeholders. However, consultation may be excluded from the process to introduce such a change for a number of reasons, not least of which might be the need to implement a safety related change as swiftly as possible.

20. Are there any other comments that you would like to make about the CAA’s potential Tier 2 process?

Tier 2 - other comments
GAL welcomes the CAA’s approach to consult formally on draft guidance for a Tier 2 airspace change process once the outcome of the Government’s consultation is known. In light of this GAL has the following brief comments on Tier 2 change: Whilst supporting the requirement for a more robust process and better definition of consultation processes for changes of this type, GAL’s view is that a consequence of this enhanced guidance is likely to be to slow the process of delivering noise management initiatives at the local level, even where consultation is channelled through an effective Noise Management Board type governance process. Although Tier 2 appears targeted at air traffic management and operational changes, the example used of a Manual of Air Traffic Services Part 2 change is too imprecise an example to define Tier 2 changes. It could also imply that changes are only those related to an ANSP, which we believe is not the case. It should be recognised that in addition to the sustainable growth objective for airspace modernisation, set out by the Government, there are also airspace/operational changes that are required in order to align with international and UK safety and interoperability protocols. These changes may be manifested through changes by the ANSP and perhaps to MATS Pt 2. Exceptions to the Tier 2 process in relation to regulator driven changes should be exempt from Tier 2 and perhaps be better captured by the Tier 3 scenario detailed in the consultation.

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?

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
GAL supports the definition of Tier 3 in principle, as part of an overall strategy of greater transparency and engagement with local communities, and thereby enhancing public confidence that an appropriate balance between economic benefit and noise impact has been struck. It could be helpful for Tier 3 to be described as changes in usage of airspace as a result of differing patterns of operational demand, which may have implications for local communities, rather than as planned changes in airspace design or operational procedures. However, there is an inference, through the guidance, that Tier 3 is subject to consultation by virtue of its inclusion as part of the tiered definitions. The guidance should therefore be clearer in reflecting Tier 3 as an information and engagement process rather than as part of a consultation process leading to decision making. Examples may assist with clarity between tiers, including defining Tier 3. Consideration should be given to a decision making process which would define the tier of change at a sufficiently early stage. It should be recognised that those opposed to a particular change may seek to frustrate it by challenging the categorisation of change between Tier 3 and 2, e.g. by seeking to press for formal consultation as a Tier 2 change rather than simply information provision and engagement under Tier 3. To avoid the scope for nugatory airspace change proposals, the CAA should be able to provide, on request, a ruling as to the category of airspace change, Tier 2 or 3, to guide subsequent information sharing and/or consultation on change.

22. Where industry does not follow the CAA’s guidance in respect of Tier 3 changes, or where there is a clear breakdown of trust between an airport and its stakeholders, is it appropriate for the CAA to publicly draw attention to this?

Please select one item
Yes
Ticked No
Don't know

23. Considering the list of potential information proposed, would you suggest any additions which would help stakeholders, including communities, understand the impacts of Tier 3 changes and enhance transparency?

Additional information on Tier 3 impacts
There is a need for airports to ensure that their local communities have sufficient information to understand the nature and causes of these types of change. The outcome sought should be to increase information transparency and to provide information more accessible to the layperson. Improvements in the availability of live data and the platforms through which live data can be shared form part of the suite of options to enhance transparency. However, to provide a complete picture comparators relating to noise improvements, which include measures such as changes in noise contours should also form part of that suite. There are also more detailed and technical data sets which could be included but it is unlikely that all but the most technically astute stakeholders would derive use from such information. The information available to stakeholders seems an issue that could be developed through ICCAN. The list of potential information to offer stakeholders better insights into Tier 3 type changes and improve understanding all-round should not be prescribed or mandatory, only generic offering ideas and options. In addition the list of information, and the language used in the draft, seems to focus on identifying through which stakeholders the change has been driven to allow direct contact with the stakeholder. In the majority of circumstances engagement on noise issues is better channelled through the airport’s mechanisms for engagement with industry and local stakeholders.

24. In relation to mitigating the impacts of Tier 3 changes, our draft guidance says that the focus should be on exploring the options for mitigating the change through two-way dialogue, because of the local and often incremental nature of Tier 3 changes. Does the guidance need to give more detail?

Please select one item
Ticked Yes
No
Don't know
Tier 3 mitigation - reasons for Q24 answer
The Tier 3 guidance on exploring the options for mitigating the change through two-way dialogue, because of the local and often incremental nature of Tier 3 changes, should be carefully considered. As previously mentioned guidance should be clear in reflecting Tier 3 as an information and engagement process rather than as part of a consultation process leading to unrealistic expectations about what the process might deliver in terms of mitigation. Often airports are not in a position to interdict or halt evolving trends or reverse trends which in most situations is not possible.