Response 572847966

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About you

A. What is your name?

Name (Required)
Rich O'Gorman

C. Where do you live?

Please select one item
(Required)
East of England
East Midlands
West Midlands
North East
North West
Northern Ireland
Scotland
South East
South West
Wales
Ticked 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
Cyrrus Limited
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(name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)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 Considering the draft guidance overall, to what extent does it meet the following criteria?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
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
How would you improve?
Proportionate: Gateway meeting schedule not a flexible means of getting business done. Missing a single deadline may result in 6-week delay to an ACP project. If this happens twice then that is 12-weeks delay and so it goes on. Comprehensible: Where does the CAP785 process fit into this? The two processes do not appear to be good bedfellows at present and it is not clear how the two can be worked in tandem. The conduct of instrument flight procedure design work early in the CAP725 process would be a direct contradiction of consultation best practice as, owing to the investment needed to do such work, it would suggest a degree of predetermination has taken place. Comprehensible: Terminology: Over, or inappropriate, use of the term “airspace design” in the introductory sections of the document. We consider the term “design” to be inappropriate to the wider aspects of the airspace configuration. The terminology “airspace arrangements” has served well over many years, including in the legal context, encompassing both the notified dimensions and classification of airspace and the notified procedures contained within it - some of which may not be subject to a formal “design” process. We consider that, for the wider aspects, the longstanding and well understood terminology “airspace arrangements” should remain. Furthermore, the terminology “airspace design” should be avoided within the early and conceptual stages of the airspace change process where formal “design” processes (such as ICAO PANS-OPS and application of the various design Policies) may have not yet been applied. Comprehensible: Terminology: There are a number of definitions in the Glossary, and terminology used elsewhere in the document, which do not reflect the formal aviation use of the terminology. Perhaps the most significant is that TMA is not Terminal Manoeuvring Area but is Terminal Control Area. Other Glossary errors include (this list is not exhaustive): CTR and CTA: Should reflect the correct ICAO definitions; GAT: The definition given for GAT is at variance with that in the UK AIP; Holding Stacks: The Heathrow Stacks were not set by Government; Why is MATS Part I not included when MATS Part II is included? It is equally important as it establishes National ATM criteria; Safety Buffer Requirement: This definition is at variance with the Policy Statement for safety buffer requirements which relate only to hazardous activities within Segregated Airspace, not between Classes of airspace. - WebTAG - See comments later in this document
General observations
In the light of the CAA’s response to the DfT on their Airspace Policy consultation (CAP1561) we have some concerns over the CAA’s proposal to seek legislated powers to compel Airports/ANSPs (or others) to undertake an airspace change. Under the new CAP725 Airspace Change Process even the smallest airspace change will incur substantial cost and other resourcing implications to the “CAA appointed” Sponsor which that Sponsor might not be able to meet. Cyrrus has consistently, throughout the CAP725 consultation, commented that the new Process will substantially increase costs to potential Sponsors which might deter them from embarking on a Process which they cannot afford. Furthermore, it might be the case that an Airspace Change might be imposed on an Airport (or its ANSP) where that Airport is wholly content with its existing airspace arrangements but is being forced (by the CAA) to change, at its own expense, only as a consequence of someone else’s airspace changes. The question of who should fund such “consequentials” should be taken into consideration.

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 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
Comprehensible: There is not enough guidance on how Step 1B might be accomplished. Comprehensible: Is there an expectation on the duration of the initial engagement (pre-consultation stage)? Comprehensible: You have chosen to refer to ‘Design Principles’. This could indicate a degree of pre-determination as having taken place as energy has or is about to be expended on ‘design’. Would it not be more appropriate to refer to them as ‘Concept Principles and Parameters’ or ‘Change Principles and Parameters’ at this early stage? Transparency: Does opening the floodgates to endless opportunities at this stage set unrealistic and non-achievable expectations amongst the uninitiated and non-airspace minded? There is a genuine risk that the process could get bogged down at this early stage, especially if lobby groups get involved. Proportionality: Statement of Need for a Level 0 change seems excessive and inappropriate. Comprehensible: Appendix A Table A2: Terminology: See above re-TMA. Suggestion: The Statement of Need form should include a ‘tick box’ aspect to determine which members of NATMAC the CAA and Sponsor both agree should be consulted. Not all ACPs are relevant to all members of NATMAC and this is evident from the historic levels of poor or nil response from many members noted in ACPs undertaken using the current CAP 725 process.

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 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 2: the guidance mostly meets this criterion Ticked 3: the guidance does not sufficiently meet this criterion
How to improve
Comprehensible: The conduct of the Options Appraisal is not made clear. This is compounded by the absence of guidance (and training) on the Government Green Book and WebTAG. Comprehensible: If a Safety Assessment is required at each Options Appraisal stage, will it be expected that a HAZID session should be held for each? Proportionate: The level of work required, and the staffing resource and expertise required, to generate and evaluate a number of options sufficiently (some of which may not be viable) will cost a great deal and will force many airport operators to avoid conducting airspace change. Ironically, this may mean that a positive change, that would have benefitted the airport, the community and the environment, may not happen owing to the costly nature of the process. The complexity of the whole process and the associated ‘high cost’ is likely to be a deterrent against embarking on the airspace change process. Moreover, most airports will not have staff with an adequate technical knowledge base or availability that could be dedicated to the options development and appraisal process. Visibility of the CAA’s response to the DfT consultation suggests the process will be mandatory regardless of the size of the operation. The cost of resourcing such a process is beyond the reach of many. Proportionate: Is it proportionate to expect the smaller scale operators to invest in full Options Appraisal including WebTAG analysis?

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 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 2: the guidance mostly meets this criterion Ticked 3: the guidance does not sufficiently meet this criterion
How to improve
Comprehensible: Data Protection Act Training? What should be redacted prior to publishing on the portal? The CAA should be more specific as to what should, can and cannot be redacted. Can commercially sensitive material be redacted? Comprehensible: Does the CAA expect Sponsors to respond to feedback during consultation (other than answering CQs)? Comprehensible: There is insufficient guidance as to the level of detail to be included in the consultation documentation given the potential complexity of the Options development and appraisal activity that has gone before. It is likely that a consultation document would be either: too lengthy and too technical for the lay person to understand (if the technicalities of the impacts and trade-offs for each Option are included); or be considered lacking in some way such that it would be necessary to generate another round of explanation if not included. Proportionate: Portal used for publishing responses during the consultation is inappropriate and could lead to a ‘snowball effect’ or a vexatious campaign.

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 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
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
Comprehensible: What is an Executive Summary version of the ACP, this is not explained? Please clarify, as we have interpreted it as a requirement for potentially 3 distinct versions of the same document. If correct, this seems excessive. Comprehensible: More guidance on what should be redacted should be given.

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 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 2: the guidance mostly meets this criterion Ticked 3: the guidance does not sufficiently meet this criterion
How to improve
Proportionate: Public Evidence Session (PES) is inappropriate as a requirement for all Tier 1 ACPs. Consultation should be sufficient as otherwise what is the point in having one? A PES seems to serve no additional purpose. If a PES is to be held (only where demand presents itself), then who defines there is a requirement or a demand? There seems to be a requirement for the Sponsor to generate yet a further round of documentation specific to the PES over and above that already produced for the ACP. 4 weeks is unlikely to be sufficient for the Sponsor to prepare such material, given that the Sponsor’s personnel are unlikely to be “dedicated” to the ACP alone. Furthermore, we believe that the PES will generate a further opportunity for objectors to introduce legal challenge to the ACP or other filibustering mechanisms to inject delay. Proportionate: Additional time required by ‘Draft’ decisions is again inappropriate having already significantly lengthened the process. Comprehensible: ‘Draft’ and ‘Minded to’ decision process is not only confusing but seems to be a ‘get out of jail free’ card for the CAA allowing wriggle room to delay or not to make decisions. Comprehensible: ‘Draft’ decisions - Not ‘designed’ as an opportunity for Stakeholders to make new representations; however, Stakeholders get an additional 4 weeks to respond. How then is this not an opportunity to make new representations?

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
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
Proportionate: Expecting too much of the smaller operators in terms of PIR data gathering and transparency of data. The resource and associated cost is likely to be significant. The current disparity in the capability of different airport NTK systems is a case in point.

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 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 2: the guidance mostly meets this criterion Ticked 3: the guidance does not sufficiently meet this criterion
How to improve
Proportionate: Again, expecting too much of the smaller operators in terms of PIR effort. Effectively requiring a mini-consultation. Does the CAA expect the Sponsor to pro-actively seek feedback from Operators and Community stakeholders to inform the PIR in advance of the PIR notification to stakeholders on the portal? Comprehensible/Proportionate: Modification or return to previous state may not be tenable without full Tier 1 ACP. Is this appropriate?

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

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

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
Ticked Yes
No
Don't know

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
Following our initial evaluation of the consultation material, our answer to this question was ‘Don’t know’. Prior to submitting our response, we had sight of the CAA response to the DfT consultation and this changed our view. It is a ‘No’ if the CAA will not consider the size and nature of the operation in question.

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
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
Does there really need to be a 12-week consultation; this seems excessive? Where some temporary changes to the airspace arrangements take place on an annual (or otherwise routine) basis, is a full Tier 1b process necessary each time? Examples: Changes to London CTR helicopter routes for Royal Ascot and other racing events; delegation of controlled airspace segments for gliding competitions; temporary CTA establishment for particular sporting events and locations. If a temporary airspace activity or delegation requires an Exemption from certain aspects of legislation to enable it to take place does this constitute an airspace change in its own right?

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
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
Are there not aspects of Stage 1 and 2 of the full ACP process that could be seen to have been completed owing to the feedback from the trial engagement? It would seem excessive to force any Change Sponsor to jump through these hoops again.

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
Spacecraft are users of the airspace on their way to space from their launch site on the ground and, as such, this operation should be subject to the same airspace change constraints. Such flights would inevitably require segregated airspace, access to which would be denied to other airspace users during its period of activation. Would airspace segregation to account for re-entry of reusable spacecraft (or disposed of sections of spacecraft) be required? The airspace requirements of this segment of the Industry should be subject to the same scrutiny as other airspace activity.

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
Any new requirements imposed on Tier 2 changes should reflect the flexibility within the current arrangements for tactical radar vectoring to make the most efficient use of the whole of the airspace for the prevailing traffic situation. A “Fixed track” ethos should not override the ability for controllers to shorten notified routes (and thereby reduce fuel burn and emissions overall) when there are no traffic reasons to do so. London City Airport operations, where sometimes the whole of the Transition procedure is bypassed, is a prime example. Essentially, Tier 2s should follow the same process as Tier1s albeit with a slightly ‘lighter touch’ approach. The CAA should be able to assist Change Sponsors in pushing it through Gateways quickly where it is identified that work is evidently not required.

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
In order to be proportionate, scalability should consider more quantifiable metrics than simply the number of movements or ATMs.

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

Tier 2 - other comments
If changes to en-route practices have a direct impact on terminal practices, should the en-route ANSP not have to take some of ‘burden’ of any consultation requirement that the airport or terminal ANSP may have to shoulder? Also, see above comments (Question 18) regarding flexibility and facilitation of reduced fuel burn and emissions when operationally feasible to do so.

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
How to improve
Airlines should be encouraged to support airports in this activity particularly if it is changes that they have inspired or initiated. It should not simply be up to airports to conduct community engagement, there would be mutual benefit if airlines were to work more visibly with airports in this regard. The Airport Consultative Committee (ACC) seems to be the ideal vehicle for an airport to disseminate this type of information and obtain feedback. The document seems to focus excessively on airport and airline activity. There are many other types of airspace activity, particularly Sport and Recreational aviation which should fall under the Tier 3 banner as these often cause community annoyance.

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
CAA action on Tier 3 further detail
They should still address the issue and only following a period of arbitration in which there was no resolution should this be allowed into the public domain.

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
No

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