Airspace change: a decision-making process for PPR (planned and permanent redistribution of air traffic) proposals

The purpose of this consultation was for you to give the CAA views on the process we should use for making decisions on PPR proposals – PPR meaning air traffic control operational procedure changes that give rise to a planned and permanent redistribution of air traffic.

The process begins once an air navigation service provider has identified (through an internal process) that an air traffic control operational procedure change might qualify as a PPR. After explaining to the CAA why it is needed, the air navigation service provider must then assess and compare the impacts of the options available to meet that need, consult those potentially affected about the option(s) chosen, and take feedback into account in any final proposal.

We had 103 formal responses to the consultation, which we have published where we have permission to do so. Of those 103, 55 were from residents affected by aviation, 19 from local government, 12 from the commercial aviation industry, eight from the General Aviation community, and nine from representative or national organisations or institutes. Eighty respondents were resident or based in the south-east, the others being from across the UK.

We received many responses challenging our proposed process and asking for modifications. There were a few common themes, but otherwise the modifications being asked for varied considerably and related to a specific element of the process rather than the whole. Some requests were diametrically opposed, for example some asking for a shorter process and some for a longer process. 

Although our consultation document made clear what was in or out of scope of the consultation, a number of the responses concerned matters out of scope that are not in the CAA’s gift to change. We were therefore obliged to disregard those elements for the purposes of this consultation. 

Airports generally thought that before an air navigation service provider initiated the PPR process, collaboration, consultation and/or agreement between the airport and air navigation service provider was essential. Some airports argued that they should be able to initiate a PPR. Other responses suggested that other organisations, such as local authorities or community organisations, could be the promoter of a PPR.

On the whole, industry respondents seemed to accept the need for the new regulatory process, but were keen to minimise the burden. Some thought that the process went too far and wanted reassurance that for minor changes the process would be appropriately scaled, and that safety-critical changes would not be held up. Some respondents wanted the process to be streamlined where proposals were improving noise impacts, while others called for a process that was at least as rigorous as for a proposed change in airspace design. 

The 'trigger' process for an air navigation service provider to identify a 'relevant PPR' received significant support from respondents, but some raised concerns with the way this would work.

Some respondents expressed concern that the CAA does not have the power to require an air navigation service provider to go through the PPR process retrospectively should it fail to identify that a change in operational procedures meets the criteria for a relevant PPR.

There was general consensus that when making a change in air traffic control operational procedures, the air navigation service provider should generally have multiple options, although it could depend on the circumstances and on the type of PPR.

Regarding our proposals for a post-implementation review – the stage where we verify whether the anticipated impacts and benefits in the original proposal and CAA decision have been delivered – there were some concerns about the air navigation service provider producing an objective assessment of the impacts.

There was support for a shortened process for temporary changes, providing that the change was genuinely temporary. Some respondents expressed concern that the shortened process was still over-long and asked what would happen should operational changes such as routine maintenance of ground navigation aids need to be achieved sooner than the process would allow.

There were concerns from industry that they and/or the CAA would not be ready to implement the new decision-making process by 1 November 2019. Some questioned the impact on CAA resources.

We identified and categorised nearly 100 specific recommendations or questions about how we could improve the process.

We have published a consultation response document Airspace change: outcome of the consultation on a decision-making process for PPR (planned and permanent redistribution of air traffic) proposals. 

Below we summarise how we have taken into account your responses. We are now proceeding to publication of the process in a new third edition of CAP 1616 in January 2020. 

Structure
We are incorporating the PPR decision-making process into CAP 1616. For clarity we are dividing CAP 1616 into three parts:

Part 1: the airspace change process (permanent changes to the notified airspace design), including: 

• Part 1a: temporary changes to the notified airpace design
• Part 1b: airspace trials

Part 2: PPR, including:

• Part 2a: temporary PPR changes

Part 3: Airspace information: transparency about airspace use and aircraft movements.

Implementation arrangements
Deferred by the Secretary of State from 1 November 2019 until 1 February 2020. Because a supplementary instruction changing air traffic control operational procedures must normally be notified to the CAA’s Safety and Airspace Regulation Group on 30 days’ notice, the CAA will begin accepting PPR proposals once the new process is published in January 2020.

Overall PPR decision-making process
We are maintaining, for the most part, the process proposed in our consultation with some minor modifications. The consultation responses, in our view, did not identify alternative proposals that would better balance the needs and expectations of the policy requirements and/or different stakeholders.

CAA interpretation of criteria for a Type 1 'relevant PPR'
Revised chart illustrating what is and is not in scope. Clarification for airports with two parallel runways.

Who needs to apply for PPR approval
Only an air navigation service provider can seek approval for a PPR, but it will be required to confirm on the Statement of Need whether it has the full agreement of any relevant airport operator.

Stakeholder collaboration
Recognition that some PPR change activities may be led by airports or other stakeholders, and that we welcome collaboration between the air navigation service provider and other stakeholders. For example, airports could carry out consultations, and communities could help promote environmentally beneficial changes.

Statement of Need
A Statement of Need is submitted by an air navigation service provider, if necessary on behalf of an airport operator, where:

• it identifies a proposed operational procedure change as a relevant PPR
• it identifies a proposed operational procedure change as not being a relevant PPR, but wants the CAA’s confirmation of that assessment, for example to provide transparency for local residents
• it is unsure whether a proposed operational procedure change is a relevant PPR, and is asking the CAA to make a determination under paragraph 15 of the annex to the Air Navigation Directions.

Post-implementation review
Clarification that when the CAA reviews the air navigation service provider’s post-implementation report, we will state whether we consider the post-implementation report closed, open, or partially satisfied: 

• we will consider it closed if the implemented change in operational procedures satisfactorily achieves – within acceptable tolerance limits – the objective of the proposal as it was approved by the CAA
• we will consider it open if we are not satisfied with the report (if, for example, we believe the analysis or conclusions to be inconclusive) and will require the air navigation service provider to rectify the shortcomings in the report
• we will consider it partially satisfied if the change in operational procedures requires modifications to better achieve the objective of the proposal as it was approved by the CAA.

In the third case, the CAA will require that those modifications are then further monitored for effectiveness. Once the modifications have been implemented and operated for a period (approximately six months), there are three further possible outcomes (mirroring the process in Stage 7 of Part 1 of CAP 1616):

• noting that the modifications did not better achieve the objective of the proposal as it was approved by the CAA, we may conclude that the original change in procedures was satisfactory and is confirmed; or 
• noting that the modifications did not better achieve the objective of the proposal as it was approved by the CAA, we may conclude that the original change in procedures was not satisfactory and the original change is not confirmed (in which case, in order to pursue its change in procedures, the air navigation service provider will need to commence a fresh PPR proposal from Stage 1); or
• we may conclude that the modifications do better – within acceptable tolerance limits – achieve the objective of the proposal as it was approved by the CAA and so the modified procedures will be confirmed.

Temporary changes
A shorter and more meaningful process than we originally proposed, in recognition that it would be disproportionate to mirror the existing CAP 1616 process for a temporary change to airspace design. There were concerns that the decision-making process might take longer than the temporary change in operational procedures itself. In recognition of concerns from communities at the six month maximum duration of a temporary PPR, we are requiring the air navigation service provider to provide a short report on the change after three months before we consider extending approval for a further three months.

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Responses to the consultation

Responses, where we have consent to publish, can be viewed by following the the link below under 'Published Responses' (for online responses) and the link at the foot of this page under 'Related Documents' (for offline responses).