Response 652093411

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About you

A. What is your name?

Name (Required)
Jeremy Pine

C. Where do you live?

Please select one item
(Required)
Ticked East of England
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
Ticked 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
Yes
Ticked No
Please select one item
Yes
Ticked No

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

Please enter any further details
It is one of my duties to respond on behalf of the Council on strategic aviation matters.

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(name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)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 Considering the draft guidance overall, to what extent does it meet the following criteria?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?
230+ pages is a lot of guidance for the public to assimilate. It might be worth considering producing a summary guide to involvement in the process for the public (based on Appendix C), who may only need to engage once (or at least infrequently) in the process. This could be a simple, downloadable leaflet or booklet similar to guides that local authorities produce for involvement with the planning process. The guide should also include what would be expected to happen in Stage 7.
General observations
None

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
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
Better to say “local stakeholders will be…” rather than "local stakeholders should generally include…” Don’t give any get-out clauses.

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
How to improve
N/A

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
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
Recognition (paragraph 152) of the need to give the opportunity for those without internet access is welcomed and is essential. The Council has some discomfort about permitting sponsors to disregard email submissions in favour of the online portal. If this is to be justified, the portal must contain sufficient open dialogue boxes so that responders don’t feel constrained by the questions that are set. Online surveys tend to be geared towards the individual responders – organisations may prefer to use a different approach. Also, what is the justification in only allowing one response per email address, unless responders are able to edit their response until the consultation closes.

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
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
Comment – Paragraph 186 should set a minimum length of re-consultation, but it is agreed that there is a need to avoid never-ending cycles of re-consultation as that will weary the public.

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
How to improve
N/A

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
How to improve
N/A

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
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
Public expectations will need to be managed very carefully at this stage so as to not engage the “review / re-run” hope referred to in paragraph 250. There is a lack of clarity in paragraph 265 over what a “proportionate and reasonable response” is from the CAA where a redesign is needed. At this stage, there could be a large number of affected / concerned residents looking for more certainty of outcome.

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
What else to show two way conversation?
Comment – This requirement could be encapsulated in a Statement of Community Involvement submitted as a requirement with each airspace change application, and based on Stages 1-3.

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
Ticked Yes
No
Don't know
Facilitator further detail
In paragraph 100, it isn’t really clear what the third-party facilitator’s role would be, or what his or her particular specialism would be. Who would pay their fees? Would there be any benefit in the facilitator being, in effect, an independent stakeholder engagement group chair?

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

Facilitator - which places
No views.

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
Comment – Is there a typographical error in Table C2? The text under the heading “Responses which do not impact final proposals” should read “The content of this response will not include..”

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
Each case will be different, and the options appraisal will need to reflect the circumstances of each case.

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
It will depend upon who the reader is likely to be. One way might be to frame the sponsor’s summary as a series of frequently asked questions that the main assessment deals with.

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
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
Comment – In paragraph 273, the CAA states that, in extraordinary circumstances, it may consider approving an extension beyond 90 days. When (in length terms) would this fall foul of paragraph 283 and require the full airspace change process to be engaged?

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
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
N/A

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
No views.

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
The DfT’s UK Airspace Policy consultation acknowledges that Tier 2 changes can have a very similar effect to changes to the permanent airspace structure because they may result in planned and permanent redistributions of air traffic. In these circumstances all seven stages could be necessary but proportionality does need to be considered in each case.

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
Presumably the Government’s altitude-based priorities still apply to Tier 2, so could Tier 2 proposals not be scaled in the same way?

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

Tier 2 - other comments
No.

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
N/A

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
In relation to paragraph 305, how would the CAA publicly challenge airports and air navigation service providers, and what would happen if they didn’t respond adequately? Would the CAA have powers to require the intervention of a third-party facilitator (such as ICCAN) or could it recommend that the Minister intervenes? Is there a lack of general teeth here?

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
This is very useful information that could help potential house purchasers understand the operational environment around an airport. Perhaps the data could include informed projections of what may happen in the future.

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
Seems comprehensive already