Draft procedure for reviewing the classification of airspace

The UK aviation sector has suffered incredible financial detriment as a result of the COVID-19 crisis. Government priorities must take account of this.

Can the CAA realistically justify and/or absorb the cost of implementation of this new procedure during this time of crisis?

It is recommended that the review cycle should be extended out. Two years does not represent the length of time taken for a CAP 1616 ACP to be undertaken so this does not feel proportionate.

The procedure would exempt airspace that is already subject to change as part of stages 1-4 of the CAP1616 process but does not take into account the current situation where the continuation of ACP programmes may be in doubt if funding support is not forthcoming from government. This should be accounted for in that these ACPs are on long term pause. Any areas previously identified as areas for review under FASI-N or FASI-S should be “ring fenced” for the medium term to ensure the benefits of AMS on a delayed implementation timescale are not eroded by fast tracked airspace reclassification projects

The procedure states that CAA would not review areas of airspace currently in stages 1-4 of an ACP but would consider those in stages 5-7. It then states it would not consider a area until 3 years after post implementation review. This doesn’t make sense. In addition, airports are entitled to some assurance of return on their investment by virtue of having conducted a full CAP 1616 process, often over many years. Three years is not adequate. Most airports expect the newly implemented airspace to meet an asset life of 10 years. It would be unacceptable to expect the expense and effort of AMS to be gone through with a guaranteed benefit of only 3 years.

We are supportive of the suggestion that the Air Navigation Guidance would be appropriate for the CAA to consult when reviewing environmental impact of airspace classification cases.

Airspace controlling authorities will indeed need to devote resource and expertise to develop new operational procedures and a safety case for reclassified volumes of airspace and although this is mentioned, there is no clear message that this cost impact will be mitigated for ANSPs and airports
On the issue of recovering costs, we firmly believe that this should come from central Government funding. This policy change is clearly driven at Government level and does not take account of the current COVID crisis. It is completely unacceptable to seek funding contribution from any party other than Government

The suggestion that the NERL En-route rate could be a vehicle for cost recovery is wholly unacceptable and illogical. The clear aviation stakeholders to benefits from this procedure are the GA community and cost recovery via NERL does not reflect this.

Safety Case
Operational Case
Training
Implementation Plan
Post-implementation monitoring and reporting

All impacting costs need to be subsidised by Government