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

Closed 7 Jul 2019

Opened 9 May 2019

Feedback Updated 7 Jan 2020

We Asked

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.

You Said

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 Did

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).  

 

 

Results Updated 24 Jan 2020

On 22 January 2020, the CAA published an updated third edition of CAP 1616, Airspace Change: Guidance on the regulatory process for changing the notified airspace design and planned and permanent redistribution of air traffic, and on providing airspace information.

The third edition incorporates:

  • a new decision-making process for PPR proposals – a Planned and Permanent Redistribution of air traffic through a change in air traffic control operational procedure
  • an additional case (airspace reclassification) where the Secretary of State can call-in an airspace change proposal
  • updated references, and improved clarity and consistency.

Links:

Published Responses

View submitted responses where consent has been given to publish the response.

Overview

Update 11 October 2019: 

The new process for making decisions on Planned and Permanent Redistribution (PPR) proposals was due to be implemented on 1 November 2019. However, due to the liquidation of Thomas Cook, and the unprecedented scale of the repatriation programme to return its passengers to the UK, the CAA agreed with the Government to postpone this by three months, until 1 February 2020. This decision was made to allow the CAA to redeploy our staff across the organisation so that we could undertake the repatriation programme. 

                                         * * * * * * * *

During a review of its policy on airspace and noise the Government recognised that while changes to airspace design are subject to the airspace change process and are consulted on with relevant stakeholders, changes to air traffic control operational procedures could be implemented without consultation. Even if noise impacts were similar to those of a change in airspace design.

The Government has since given the CAA, as airspace regulator, a decision-making role for a wholly new category of airspace change. This category is known as a planned and permanent redistribution of air traffic through changes in air traffic control operational procedure. We refer to this as PPR for short.

Essentially a PPR concerns changes in the way existing airspace is used, rather than changes in the airspace design itself. Air traffic controllers are continuously making decisions as to how to control individual aircraft. The air traffic control operational procedures form a framework within which each air traffic controller makes those individual aircraft-by-aircraft decisions. Consequently the track over the ground taken by a given aircraft is a combined result of the airspace design, the air traffic control operational procedures and the individual expert decision of the air traffic controller on the day.

After consultation, the Government decided that where changes in air traffic control operational procedure lead to a planned, permanent redistribution of air traffic in certain ways, they ought to be subject to:

  • a CAA decision which considers all the section 70 factors in the Transport Act 2000, and
  • a similar process as a change in airspace design.

Only certain PPR proposals (known as ‘relevant PPRs’) will need to go through the approval process. These are the PPRs most likely to have a potential noise impact on the ground. 

Why We Are Consulting

The Government has formally directed us to introduce a new decision-making process by 1 November 2019* for deciding whether a relevant PPR can be implemented. 

The purpose of this consultation is to seek your views on:

  • our proposed principles for a new PPR decision-making process, which we have based on the existing airspace change process
  • our commentary on what changes are likely to fall within the Government’s definition of a relevant PPR.

These principles and commentary are set out in detail in our consultation document: Airspace change: consultation on a decision-making process for PPR (planned and permanent redistribution of air traffic) proposals

Our proposed PPR decision-making process

We propose to base the process on a shortened version of the existing CAP 1616 airspace change process.

The existing CAP 1616 process is made up of 14 steps in seven stages, with gateways that must be passed before the proposal can progress any further in the process. Our proposed PPR process is set out in our consultation document: Airspace change: consultation on a decision-making process for PPR (planned and permanent redistribution of air traffic) proposals

What we are not consulting on

We are not seeking your views on the policy on PPRs and relevant PPRs itself, other aspects of government airspace policy (including the Air Navigation Guidance, noise preferential routes or noise metrics), the existing CAP 1616 airspace change process, or specific airspace or air traffic control operational procedure changes. The CAA will disregard elements of responses to this consultation that focus on any of these areas.

Your views are invited

We are seeking your views on our proposed principles for the process that we will introduce from 1 November 2019*, bearing in mind that the process must be proportionate and reflect published Government policy. 

Once we have considered your views and any modifications needed to our proposed process, we can then incorporate it into a third edition of CAP 1616.

How to respond to this consultation

Please let us have your comments by following the "Give us your views" link below and answering the eight questions.

If you are not able to use the online consultation and wish to send a self-contained response we ask that your comments are structured around our questions. Otherwise we will not be able to analyse the submissions in the same way that we analyse the online responses.

This consultation closes on 7 July 2019. 

If you would like to discuss anything about how to respond to the consultation, please email airspace.policy@caa.co.uk.

 

* the implementation date was delayed in October 2019 to 1 February 2020.

What Happens Next

This consultation has now closed.

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

Audiences

  • Residents affected by aviation
  • Organisations affected by aviation
  • Community groups
  • Airline passenger
  • General Aviation
  • Commercial airlines
  • Air taxi operators
  • Military
  • Airport operators
  • Air Navigation Service Providers
  • Industry representative bodies
  • Eurocontrol
  • Air traffic control staff
  • Aerodrome Operators
  • Government departments
  • Regulatory bodies
  • Elected political representatives
  • National representative organisations or institutes
  • Workers' representative bodies

Interests

  • Aircraft noise
  • Aircraft emissions
  • Local air quality
  • Flightpaths
  • Airspace design, categorisation and access
  • Airspace change proposals
  • Air Traffic Control
  • Capacity
  • Safety
  • Air Traffic Control