Response 765114351

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About you

A. What is your name?

Name (Required)
bill pilkington

C. Where do you live?

Please select one item
(Required)
East of England
East Midlands
West Midlands
North East
Ticked North West
Northern Ireland
Scotland
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
Representative or national organisation or institute
Ticked Elected political representative

E. Are you affiliated with any organisation?

Please select one item
Ticked Yes
No
Affiliation
Mottram St Andrew Parish Council
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(name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)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 Considering the draft guidance overall, to what extent does it meet the following criteria?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
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
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?
The overall guidance is good but could be improved if the comments contained in my response were used to make the document more transparent and informative for all those who would be affected by any airspace change proposal.

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 Considering Stage 1 (Define) of the process , to what extent does the draft guidance on that stage meet the following criteria?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
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
I understand that the Night Noise Policy Review for Manchester Airport has been deferred until June 2018 and therefore any air space change proposals before this date can not be seen to be proportionate.

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
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

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
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
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

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
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

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
Yes
Ticked No
Don't know
What else to show two way conversation?
By introducing a Formal Record of stakeholder views would assure stakeholders that their views or objections are being taken into account by the change sponsor, giving the CAA evidence that two way conversations have taken place.

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
No
Ticked Don't know
Facilitator further detail
If the sponsor is submitting all the views of the stakeholder and the CAA is monitoring the portal, it should be apparent at various stages when there is a breakdown in communication between parties. However as every proposed air space change is different, all parties should feel confident that this facility is available to them as and when needed.

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

Facilitator - which places
At the Define and Options Appraisal stages it would be beneficial if the CAA Guidance for this could encourage the sponsor to engage a Third Party facilitator.

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
Ticked Yes
No
Don't know
Categorisation - additional detail
An appropriate level of scrutiny should be applied to the consultation responses.

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
Even though the CAA is not the owner of the Options Appraisal, the guidance does allow the CAA to monitor the change sponsor. This ensures that all relevant options have been explored, not just the most cost effective one., that the stakeholder views and objections are given equal consideration by the change sponsor and that there has been no bias by the change sponsor i the process. It also provides the opportunity for a greater degree of challenge to the sponsors plans. The guidance stated that a Third Party facilitator could be used here. Stakeholders need to feel more confident that the facilitator is neutral and independent, a requirement stated ion the draft guidance, as the CAA has decided not to adopt the Helios recommendation of an Oversight Committee.

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
Provided that the Safety Assessment summary only covers what is relevant to both the sponsor and stakeholder and is not overly complicated for the stakeholder to understand.

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
The CAA would need to ensure continuous recorded engagement with the impacted stakeholders if there is any delay to the process. It may be necessary to apply a time limit.

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 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
Stakeholders that may encounter the greatest impact , should be engaged at the earliest opportunity, to promote trust and transparency. Unfortunately this appears has not always been the case.

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
These operations are likely to be sometime in the future but no doubt the process could be adapted to accommodate spaceflight operations.

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
It is understood from the guidance that vectoring is gradually being reduced due to the accuracy of Performance Based Navigation systems (PBN), resulting in very little deviation from the published flight paths. Any Planned and Permanent Redistribution (PBR) of air traffic patterns below 7,000 feet could have a greater detrimental impact 90% of the time for those communities exposed to a route of traffic concentration, resulting in increased noise, with no respite. In all probability, flow rates are likely to increase due to the accuracy of PBN. The Government is committed to mitigating noise impacts where possible and it would therefore be appropriate to use the Tier 1 assessment for a Tier 2 change, giving impacted stakeholders time to understand the changes, via an effective level of engagement and an appropriate consultation.

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
AS noise impact and pollution reduce above 7,000 feet, a scaled assessment process would be appropriate as fewer people on the ground would be affected by aircraft above this level. If aircraft movements are below 7,000 feet where arrivals or departures are over the sea, this process could possibly be scaled back depending upon local circumstances.

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

Tier 2 - other comments
Sponsors should be asked to provide a traffic forecast, which would act as a base document for assessing potential noise impact.

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
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

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
Ticked Yes
No
Don't know
CAA action on Tier 3 further detail
By publicly drawing attention to this situation, may encourage the sponsor to take a step back and consider a wider range of solutions for those stakeholders affected by noise. It may also put pressure on the airport to resume an effective two way dialogue. The CAA could possibly strongly recommend in the guidance that a Third Party facilitator would be available to all parties.

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
Greater communication and early engagement of communities is required, especially where there is noticeable movement in the distribution of flights or an increase in traffic volumes over a period of time. Up to date information should be made readily available, explaining predicted traffic forecasts. Airport communication teams engaging with local communities more frequently, either by open meetings, workshops or emailing local community representatives.

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
Yes
Ticked No
Don't know
Tier 3 mitigation - reasons for Q24 answer
The definition is fairly explanatory. The main requirement is for transparency, communication and early engagement especially for the incremental changing of traffic volumes, particularly if this is for purely commercial reasons.