Response 557376026

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About you

A. What is your name?

Name (Required)
Anna Sullivan-Jones

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)
Ticked 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
Elected political representative

E. Are you affiliated with any organisation?

Please select one item
Ticked Yes
No
Affiliation
LADACAN (Luton and District Association for the Control of Aircraft Noise); STAQS (St Albans Quieter Skies) and ACF (Aviation Communities Forum)
Please select one item
Yes
Ticked No

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

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(name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)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

General observations

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 Considering the draft guidance overall, to what extent does it meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion Ticked 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
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
How would you improve?
• I don’t want to be too critical, because I realise a lot of work has gone into this document. But at the same time, I am a communications & engagement professional, and from a professional perspective, this guidance seems a bit of a disaster. The most important point is I don’t think you can reasonably expect large numbers of the public to read a 234-page document. Most people are working in full-time jobs and have busy lives, and will only be able to engage with these issues in their precious spare time. Expecting them to take the amount of time it would to digest this document is unreasonable I think. I understand there is a lot of material you need to cover in this guidance, but at the same time it’s unlikely you’ll get meaningful engagement on your documents until you find a way of communicating more simply. Essentially, I think this is a poor document (from a communications perspective), and this will lead to poor engagement on the issues, because people won’t be able to ‘get to’ the important information, and therefore provide their opinion on it. • To improve the guidance on this point, I would recommend asking yourselves: what does the public actually need to know about this issue? My suggestion would be that they need to know which stages of the process they can influence, and how to do so. You could easily pull together a document of only a few pages that sets this out. My expectation is the majority of people would engage just with that, but you could also provide the full document for the hardy few who can face 234 pages. • For a document being consulted on, I would also expect it to be written in plain English, and acronyms to be explained. This isn’t the case here, e.g. references to ‘NATS’ without explaining who they are. Provision of a glossary doesn’t ameliorate this issue. • When I’ve managed consultations in the past, we’ve always been very clear that documents should be available to people irrespective of how IT-savvy they are. I may have missed something, but I see no indication of how I would respond to this consultation if I wasn’t IT-savvy. This is a major problem, and may actually be an issue from an equalities perspective, because it seems a large chunk of the population (i.e. the non-IT-savvy) are barred from participating. • In terms of proportionality, the main problem I think are the timescales you’ve given in figure 2. You state that the process will take in the region of 109 weeks, so between 2 and 3 years. This is ludicrous for people who are being badly affected by aviation noise, and from interaction with our local airport, I know they want to be able to make changes more quickly too. Both communities and industry want flexibility to make quick changes where necessary, and based on the current guidance, they won’t be able to do this, because a long process is mandated. 1 year is much closer to what would be reasonable from the point of view of communities. So either the timeline should be changed, or airports should be given the flexibility to do things more quickly (but not more slowly; that is, there should be an upper limit on how long these activities should take but no lower limit. Or you could set a tolerance range, i.e. the whole process can be as quick as a year, but no longer than 109 weeks). • In terms of comprehensibility, a major issue is it’s unclear how this guidance maps across to government objectives. For instance, on p100 (B6), you state ‘there is no requirement on sponsors to undertake environmental assessment as part of this stage; however, desired environmental outcomes for the airspace change are very likely to form some of the design principles’. Given that a top priority for the government is minimising and where possible reducing the number of people ‘significantly affected’ by aircraft noise, one would expect noise to be a key consideration at every stage. Essentially, it’s hard to comprehend this guidance when such statements suggest it doesn’t align with government priorities. • Finally, although this document provides a huge amount of information, it completely misses something that I think is crucial, which is detail on what level of engagement the CAA expects airports to undertake. Creating a culture of real engagement is very difficult, as has been witnessed in the health sector following the introduction of the Health and Social Care Act in 2012. Even with legislation; the creation of Healthwatch; the requirement for an engagement lead to sit on Clinical Commissioning Group Boards; training support; and close monitoring of engagement outcomes by NHS England, it has been difficult for NHS organisations to make the necessary changes. For airports, all this guidance mandates is a requirement ‘to engage’. As such, there is a real danger that if you aren’t more specific and prescriptive, nothing will change; airports will continue conducting questionable engagement practices; and local communities will continue to be incensed by the fact they have no real voice on this matter. You need to describe what ‘good’ engagement looks like, because I don’t think local people have assurance that airports have the skills (and possibly the willingness) to develop robust engagement plans without being given this steer by CAA.

Tier 1a: Stages 1 to 7

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

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion Ticked 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
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
How to improve
• Same issues and suggestions as I’ve given in response to question 1.

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

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion Ticked 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
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
How to improve
• Same issues and suggestions as I’ve given in response to question 1.

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

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion Ticked 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
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
How to improve
• Same issues and suggestions as I’ve given in response to question 1.

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
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
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
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
How to improve
• Same issues and suggestions as I’ve given in response to question 1.

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
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
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
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
How to improve
• Same issues and suggestions as I’ve given in response to question 1.

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
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
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
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
How to improve
• Same issues and suggestions as I’ve given in response to question 1.

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
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
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
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
How to improve
• Same issues and suggestions as I’ve given in response to question 1.

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?
• Further detail on the engagement process: o List of stakeholders. You need to be sure that the airport has engaged everyone they should engage on their plans, i.e. all residents who are likely to be affected by the change; local councillors and MPs who represent those people etc. (N.B. This information on ‘who to consult’ is also required on p120.) o Information on what the airport has done to engage those stakeholders, i.e. have they sent a flier to every house in the area? Have they presented to a relevant council meeting? etc. • Further detail on outcomes of the engagement process: o Unabridged versions of the feedback provided. If feedback was provided during a meeting, it can be summarised in minutes and all attendees should be given a chance to check those minutes are correct (the CAA should seek evidence that this has happened). o Based on the unabridged feedback, a document that summarises each of the main points being made. o The airport’s determination, taking into account the feedback provided. o Relative to their determination, the airport should provide information on ‘you said, we did’ for each of the main feedback points. i.e. Imagine a situation where an airport is engaging on whether to implement option A or option B. 100 people say ‘we prefer option A, because it will reduce noise’, and 80 people say ‘we prefer option B, because it will limit emissions’. Say the airport decides to go with option A. Re the feedback provided, the airport needs to set out: - “100 people said: ‘we prefer option A, because it will reduce noise’. We did: prioritise this, because we want to have a good relationship with our local community, and the decision also aligns with government policy xxx’. - “80 people said: ‘we prefer option B, because it will limit emissions’. We did: consider this, but found that limiting emissions is less of a priority than reducing noise, as set out in government policy xxx’. o If the CAA and airports wanted to run a ‘good’ engagement process, then they would also communicate this ‘you said, we did’ information to people once a decision has been made. That way, people will know how their feedback has been taken into account, and why the final determination has been made.

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
I’m not sure why this is important. Presumably there are situations where the relationship between airport and local community has broken down so far that a facilitator is required, and you could specify that a facilitator should be used in such circumstances.

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

Facilitator - which places
Again, I’m not sure why this is important. Perhaps there should be more detail in the guidance as to why facilitation is being suggested, to help us understand the context?

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
• Presumably airports will be required to provide several options, in line with good practice consultation guidance. Therefore the CAA should not just be looking for information / ideas that can contribute to the lead design option, they should be looking for information / ideas that can contribute to all options provided. Focusing on the lead option as you do presupposes that this will be the one chosen, because you are not considering any feedback on the other options. • Re Table C2, you say that other feedback (e.g. criticising the consultation format) should be logged and considered, but you have no process for checking that this is happening. If feedback like this is arising strongly from consultation responses, airports should be required to demonstrate how they are going to act on the feedback, and checks should be undertaken to ensure they are doing so.

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
• Surely there should be a core set of indicators that should be considered as part of any options appraisal, based on current government objectives around aviation. Beyond this, it’s sensible to have flexibility, so that processes can be tailored.

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
No.

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
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
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
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
How to improve
• Same issues and suggestions as I’ve given in response to question 1.

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
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
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
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
How to improve
• Same issues and suggestions as I’ve given in response to question 1.

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
• Only if the issues I identified in response to question 1 are rectified.

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
As public response to RNAV has shown, Tier 2 changes can have significant impacts re changes in aviation noise on the ground. As such, communities should be fully consulted on any such change.

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

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

Tier 2 - other comments
I have provided my views as part of the DfT 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 2: the guidance mostly meets this criterion Ticked 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
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
How to improve
• Same issues and suggestions as I’ve given in response to question 1.

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
• Expectations on level of trust to be achieved by airport with respect to local communities. In the Aviation Policy Framework (p62) it states that ‘the key principle should be that airports act as good neighbours, so that local communities have confidence that airport operators take their noise impacts seriously’. But there is no indication of what ‘a good neighbour’ would look like. The CAA needs to define this, so that airports know what to aim for.

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
• An up-to-date noise contour map, and a new noise contour map that reflects any difference that will be created by the tier 3 change. • If communities will be adversely affected (in terms of noise) by the change, they should be told which airlines will be flying the route that will affect them. • If the change concerns a difference in numbers of flights along that route, they should be told how many planes currently fly the route, and how many will fly the route after the change.

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?

Tier 3 mitigation - reasons for Q24 answer
Per my previous responses, I think you need to be more prescriptive about what 'good' engagement looks like, because I don't think it's reasonable to expect airports to know what to do, without a steer from CAA. I also disagree that the focus should be on mitigation, i.e. I think local communities should be given a say over Tier 3 changes, rather than being presented with a 'fait accompli', and their only opportunity is to influence mitigation measures, which may not be adequate to make the situation bearable for them. But from the looks of things, that point isn't up for discussion.