Response 117055434

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About you

A. What is your name?

Name (Required)
Pete Stratten

C. Where do you live?

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(Required)
East of England
Ticked East Midlands
West Midlands
North East
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
Ticked Representative or national organisation or institute
Elected political representative

E. Are you affiliated with any organisation?

Please select one item
Ticked Yes
No
Affiliation
General Aviation Alliance
Please select one item
Ticked Yes
No

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

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This is a hugely time consuming response format. As a consequence, we have instead submitted a free text response under 'General Observations'.

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(name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)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 Considering the draft guidance overall, to what extent does it meet the following criteria?

How would you improve?
1. A better ACP process was an implicit commitment of the Governments 2015 GA Strategy and is an agreed CAA action. Trust in the existing ACP process is low through insufficient transparency and a significant imbalance in addressing the needs of commercial and non-commercial stakeholders. We are encouraged that the CAA has developed a revised ACP process and that the need for clear guidance on developing and responding to proposed airspace changes is recognised, particularly as the revised process is inherently more complicated than the current process. 2. A recurring significant issue, also identified within the CAP 1389 consultation, is ACP sponsor inadequate or non-existent early engagement with stakeholders regarding design principles. As there is ample evidence that it is unusual for an ACP to be unchallenged, early engagement with affected stakeholders on design principles is essential to develop a cooperative relationship and efficient approach from the outset rather than a combative relationship and inefficient and costly activity later in the process. As routinely described to the CAA by our member organisations, the GA Alliance and its member organisations stand ready to participate in early engagement ACP design principles. The ACP process must be unequivocal about this important issue. Unfortunately the draft requirement within the consultation is ambiguous. 3. While emphasising early engagement with local stakeholders, the current text in CAP 1520 does not require early engagement by ACP sponsors with national organisations, eg GA Alliance member organisations, other than where traffic flows are to be changed below a specified height. We recognise why a sponsor would not need to engage with local communities where traffic flows below a specified height remain unchanged. However, transiting GA and air sport activity based beyond the local area is routinely impacted by airspace change regardless of height or whether or not the related traffic flows change. We propose that a requirement for early engagement with GA and air sport organisations on ACP design principles regardless of traffic flows and height is clearly expressed within the CAA’s guidance. 4. Welcome elements of the CAA’s revised ACP process that will benefit from clear guidance for stakeholders include; • Use of the single bespoke website forming an airspace change portal for anyone to view, comment on and access documents for every airspace change proposal • Recommended use by sponsor of an independent third-party facilitator to make early engagement with stakeholders on design principles more effective, and potentially also for formal consultation • Publication of airspace change consultation responses online as they are received • Public Evidence Session for some changes with greater impact (Level 1) allowing stakeholders to address the CAA decision-maker once a proposal has been submitted • Publication of a ‘minded to’ decision for public review for changes on which we believe there could be a risk of misinterpretation or misunderstanding of some of the evidence 5. It is important that the guidance should not assume the stakeholder using the guidance holds anything other than a very basic level of airspace technical, legal or national governance knowledge.