Response 242918235

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About you

A. What is your name?

Name (Required)
GATCOM (GATWICK AIRPORT CONSULTATIVE COMMITTEE

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

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

Please enter any further details
GATCOM is the statutory advisory body for Gatwick Airport constituted under the provisions of the Civil Aviation Act 1982. GATCOM brings together a broad and varied range of interests from the local authorities, local community and environmental groups to the aviation industry, passengers and business interests. There are differing views amongst our membership about the detailed nature of the proposed process but the Committee has agreed its response to the consultation which is set out below. I would advise that the environmental and communities groups’ representative serving on GATCOM did not agree with every aspect of GATCOM’s response below and confirmed that local community groups would submit their own response to the consultation.

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(name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)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 Considering the draft guidance overall, to what extent does it meet the following criteria?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
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
General observations
In GATCOM’s response to the CAA’s earlier consultation on the principles for a new process, the early engagement with a range of stakeholders, including local community interests, in the process was very much supported but also highlighted that the proposed process would be more time-consuming. GATCOM is pleased to note the references in the draft Guidance to the role of airport consultative committees in the new process which is welcomed. GATCOM is also pleased to note that while the draft Guidance sets out a very comprehensive and more inclusive approach to seeking permanent airspace changes under Tier 1a, there is a much shortened process for seeking temporary changes and airspace trials. The need to engage with a wide range of interested parties, including local parish councils and community groups, throughout the process will however mean that seeking permanent changes to the notified airspace design will take at least two years to implement changes. It is important therefore that throughout the process parties continue to engage and that opportunities are taken to ensure that estate agents are kept informed of possible changes to airspace affecting properties in their area. GATCOM also welcomes the opportunity to comment on the principles for Tier 2 airspace changes (changes to air traffic control operational procedures or the planned redistribution of air traffic), should the Government decide to proceed with introducing that new category of airspace change. It is often those types of airspace changes that require a more speedy solution to address local problems suffered by communities. It is felt that the comprehensive process set out for Tier 1a airspace changes may not always be appropriate or proportionate to address a local problem. It is considered therefore that a more flexible approach should be applied. A “one size” approach is not always appropriate to address local circumstances. GATCOM therefore advocates the principle of adopting a more flexible process with the approach being agreed between all parties at the start of the process so that local circumstances are always at the heart of the process and taken into account and local solutions found in the most expeditious way possible. Whilst the importance of having a transparent and inclusive process for all types of airspace change is recognised, careful consideration must also be given to ensure that the costs are managed and proportionate. GATCOM is aware that airlines are concerned that the cost of the airspace change will ultimately fall to the airlines through charges by both the airport and the CAA in addition to the cost of amending their on board navigation systems which in turn is likely to be passed to the consumer through increased ticket prices. Allowing a flexible approach will therefore help to manage the cost of running the process.

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
The GATCOM Chairman and Secretariat was present at the Annual Meeting of UKACCs on 8 June, when the CAA gave an overview of the proposed new guidance and indicated that it would welcome airport consultative committees’ specific views on two aspects of the new guidance – the questions that might be used to structure the conversation at the Define Stage and the engagement evidence the CAA needed to validate for a sponsor to pass the Gateway. The GATCOM Steering Group has considered both these aspects. In respect of questions that might be used to structure the conversation in designing the principles it was felt that in addition to the CAA’s suggested questions of: • Noise and carbon emissions must both be considered between 4,000 and 7,000ft; should one of these be prioritised within that height of airspace for this change? • Are there noise sensitive buildings that should be avoided, (i.e. hospitals, care homes, schools, higher education establishments)? • How should the minimisation of overflight, or of night noise, or the difference between multiple respite routes and single routes be traded off against one another? • If multiple routes are considered in order to provide respite, what might constitute a sufficient period of respite? • How should the needs of passengers be considered alongside the needs of communities at different times of day? • Are there areas in which efficiency (shorter or faster routes) take precedence and areas in which other factors should take precedence? • Are there any areas of tranquility or biodiversity which should be noted? it is also important to identify at the design principles stage whether a proposed change would result in the overflight of new areas and ways in which that could be avoided? Attention needs to be given to the legacy issue with, wherever possible, priority being given to maintaining existing flight path swathes to avoid subjecting new areas to aircraft overflight. As regards the engagement evidence the CAA needed to validate for a sponsor to pass through a gateway if the CAA’s final guidance allows for a flexible approach to be applied to reflect local circumstances in respect of Tier 2 changes it is important for the change sponsor to provide evidence to support the approach that has been agreed between all parties so that the CAA can satisfy itself that the approach to be taken has the blessing of all parties. GATCOM also believes that airport consultative committees (ACCs) have a role in helping to ensure the airspace change sponsor has the evidence needed for submission to the CAA at the gateways sign off. A monitoring role for ACCs 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. GATCOM hopes therefore that this potential role can be referenced in the final guidance document. An important element of the new process is the consultation plan and ensuring that the right areas/local parish councils and local community groups are informed and engaged in the process. As the process is intended to be inclusive it is vitally important that the public has a choice of means to assess the consultation proposals and the response methods rather than the CAA and the airspace change sponsor relying on the on-line portal. As highlighted in GATCOM’s previous response, it is accepted that there is a need for consistency and fairness to all parties and use of the on-line portal and response method should be encouraged. However, there is still a vital need to allow exceptions so that written responses via traditional means can be submitted as not all members of the public have internet access or the IT skills to complete the on-line response forms. The consultation plan should therefore ensure that information is available via traditional methods and notification of the airspace change proposals sent by post to all owners/residents likely to be affected before any flight path is moved. All communications must be in Plain English with clear, up-to-date maps showing towns and villages. It is noted that in the case of changes with higher potential impacts, the CAA has stated that it may recommend the use by the change sponsor of an independent third-party facilitator to make early engagement with stakeholders on design principles more effective. It is important that this early engagement includes the involvement of affected parish councils and local community interest groups.

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

How to improve
GATCOM believes that airport consultative committees (ACCs) have a role in helping to ensure the airspace change sponsor has the evidence needed for submission to the CAA at the gateways sign off. A monitoring role for ACCs 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. GATCOM 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?

How to improve
An important element of the new process is the consultation plan and ensuring that the right areas/local parish councils and local community groups are informed and engaged in the process. As the process is intended to be inclusive it is vitally important that the public has a choice of means to assess the consultation proposals and the response methods rather than the CAA and the airspace change sponsor relying on the on-line portal. As highlighted in GATCOM’s previous response, it is accepted that there is a need for consistency and fairness to all parties and use of the on-line portal and response method should be encouraged. However, there is still a vital need to allow exceptions so that written responses via traditional means can be submitted as not all members of the public have internet access or the IT skills to complete the on-line response forms. The consultation plan should therefore ensure that information is available via traditional methods and notification of the airspace change proposals sent by post to all owners/residents likely to be affected before any flight path is moved. All communications must be in Plain English with clear, up-to-date maps showing towns and villages. GATCOM believes that airport consultative committees (ACCs) have a role in helping to ensure the airspace change sponsor has the evidence needed for submission to the CAA at the gateways sign off. A monitoring role for ACCs 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. GATCOM 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?

What else to show two way conversation?
The engagement evidence the CAA needed to validate for a sponsor to pass through a gateway if the CAA’s final guidance allows for a flexible approach to be applied to reflect local circumstances in respect of Tier 2 changes it is important for the change sponsor to provide evidence to support the approach that has been agreed between all parties so that the CAA can satisfy itself that the approach to be taken has the blessing of all parties. GATCOM also believes that airport consultative committees (ACCs) have a role in helping to ensure the airspace change sponsor has the evidence needed for submission to the CAA at the gateways sign off. A monitoring role for ACCs 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. GATCOM hopes therefore that this potential role can be referenced in the final guidance document.

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
It is noted that in the case of changes with higher potential impacts, the CAA has stated that it may recommend the use by the change sponsor of an independent third-party facilitator to make early engagement with stakeholders on design principles more effective. It is important that this early engagement includes the involvement of affected parish councils and local community interest groups

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?

How to improve
GATCOM is pleased to note that while the draft Guidance sets out a very comprehensive and more inclusive approach to seeking permanent airspace changes under Tier 1a, there is a much shortened process for seeking temporary changes and airspace trials. As stated in the response to the Tier 1a process, GATCOM believes that airport consultative committees (ACCs) have a role in helping to ensure the airspace change sponsor has the evidence needed for submission to the CAA at the gateways sign off. A monitoring role for ACCs 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. GATCOM hopes therefore that this potential role can be referenced in the final guidance document.

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
GATCOM welcomes the opportunity to comment on the principles for Tier 2 airspace changes (changes to air traffic control operational procedures or the planned redistribution of air traffic), should the Government decide to proceed with introducing that new category of airspace change. It is often those types of airspace changes that require a more speedy solution to address local problems suffered by communities. It is felt that the comprehensive process set out for Tier 1a airspace changes may not always be appropriate or proportionate to address a local problem. It is considered therefore that a more flexible approach should be applied. A “one size” approach is not always appropriate to address local circumstances. GATCOM therefore advocates the principle of adopting a more flexible process with the approach being agreed between all parties at the start of the process so that local circumstances are always at the heart of the process and taken into account and local solutions found in the most expeditious way possible. Whilst the importance of having a transparent and inclusive process for all types of airspace change is recognised, careful consideration must also be given to ensure that the costs are managed and proportionate. GATCOM is aware that airlines are concerned that the cost of the airspace change will ultimately fall to the airlines through charges by both the airport and the CAA in addition to the cost of amending their on board navigation systems which in turn is likely to be passed to the consumer through increased ticket prices. Allowing a flexible approach will therefore help to manage the cost of running the process.

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
Yes
No
Ticked Don't know

Tier 3: Other changes to air operations affecting noise impacts

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
GATCOM believes that airport consultative committees (ACCs) have a role in helping to ensure the airspace change sponsor has followed the best practice guidance. GATCOM hopes therefore that this potential role can be referenced in the final guidance document.