About you
D. Are you answering this consultation as:
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(Required)
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Resident affected by aviation
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Airline passenger
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Member of the General Aviation community
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Member of the commercial aviation industry
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Military
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Government and / or other regulators
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National representative organisation or institute
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Elected political representative
G. Do you consent for your response to be published?
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(Required)
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Yes, with identifying information
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Yes, without identifying information
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No
CHAPTER 4: How the CAA is considering revising the airspace change process
1. Will the new process gateways improve the airspace change process?
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Yes
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No
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Don't know
Please give reasons for your answer.
As you have provided.
Proposals for Stage 1
2. Should the sponsor engage local stakeholders to agree design principles for the airspace change?
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Yes
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No
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Don't know
Please give reasons for your answer.
In our case we were confronted with a 'fait accompli' in which large numbers of low-altitude Gatwick-bound aircraft started flying directly over us in late 2013, even though all authorities continued to deny that there had been any change. After Gatwick finally admitted the change in 2015 it was, and remains, unclear the extent to which the stated reasons of safety and reducing flyarounds have been fully proven. An engagement to agree design principles would have avoided a considerable waste of time, effort and animosity that has been created with residents all around the airport and have allowed a democratic process.
3. What types of data would you find it useful for the sponsor to provide when engaging local stakeholders about design principles? How should this data be presented?
Please enter your comments
Exact nature of the change.
Purpose for the change.
A clear definition of what will change for each class of affected stakeholder.
Measures intended to minimize specific negative side effects.
Definition of key measurements pertaining to prime purpose.
Definition of key measurements pertaining to side-effects.
Historical values of both the above.
Intended values that will define failure and success of the above.
Purpose for the change.
A clear definition of what will change for each class of affected stakeholder.
Measures intended to minimize specific negative side effects.
Definition of key measurements pertaining to prime purpose.
Definition of key measurements pertaining to side-effects.
Historical values of both the above.
Intended values that will define failure and success of the above.
4. In addition to specific detail, what general background information would you find it useful for the sponsor to provide as context for its proposals?
Please enter your comments
Any original studies that determined the need.
Impact studies (environmental/noise/number of people affected, etc).
Similar case histories.
Best practices elsewhere.
Impact studies (environmental/noise/number of people affected, etc).
Similar case histories.
Best practices elsewhere.
5. Overall, will Stage 1 improve the airspace change process?
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Yes
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No
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Don't know
Please give your reasons and any other views on Stage 1.
The process of having to consider/consult local communities from the outset will ensure more careful design of the envisaged change and a smother less costly implication process.
Proposals for Stage 2
6. Will introducing the options appraisal we propose improve the airspace change process?
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Yes
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No
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Don't know
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Full
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Indicative
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Don't know
Please provide your reasons
There are always unforeseen implications of any change. The process should ensure that these are more likely to be identified as early as possible.
7. Overall, will Stage 2 improve the airspace change process?
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Yes
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No
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Don't know
Proposals for Stage 3
8. Would an independent third-party facilitator make a sponsor’s consultation more effective?
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Yes
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No
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Don't know
If so, should a facilitator be a mandatory requirement for certain types of airspace change? Please give your reasons and any other views (including benefits and disbenefits) on facilitators.
A third-party facilitator should be mandatory. We have increasingly seen with time, in the case of the Gatwick Arrivals Review conducted in 2015/6, the extent to which experts hired by the airport to consult have increasingly refrained from discussing certain inconvenient truths or appear to have modified their final propositions as a result of pressures from outside community groups.
9. Should the CAA publish all consultation responses in full, except to moderate them for unacceptable content?
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Yes
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No
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Don't know
Please give reasons for your answer.
Everything should be made clear. This is the only way to pick up on potential important issues that others might not have seen. It should also have a moderating effect with respect to extreme point of view.
10. Should the CAA publish airspace change consultation responses as they are submitted, rather than at the end of the consultation period?
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Yes
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No
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Don't know
Please give reasons for your answer.
See above.
11. Should consultation responses be made solely through the online portal?
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Yes
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No
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Don't know
12. Do you think that the consultation process proposed in Stage 3 achieves the right balance between fairness, transparency and proportionality?
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Yes
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No
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Don't know
13. Overall, will Stage 3 improve the airspace change process?
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Yes
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No
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Don't know
Proposals for Stage 4
14. Should sponsors be required to adhere to a standard template for their airspace change submissions?
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Yes
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No
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Don't know
15. Is it reasonable for the CAA to publish a redacted version of the submission, with commercially sensitive details removed, as soon as we receive it, before we have assessed it and decided upon it?
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Yes
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No
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Don't know
16. Overall, will Stage 4 improve the airspace change process?
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Yes
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No
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Don't know
Proposals for Stages 5 and 6 (including Public Evidence Session and Appeal discussions)
17. Will introduction of a new Public Evidence Session improve the airspace change process?
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Yes
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No
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Don't know
18. Is Step 5B (CAA decision) a clear and transparent way of making an airspace change decision?
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Yes
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No
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Don't know
19. Overall, will Stage 5 improve the airspace change process?
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Yes
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No
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Don't know
20. What are your views on our proposal not to introduce an appeal against process irregularities into the airspace change process?
Please enter your comments below.
I agree. An appeal process needs to be independently conducted.
Proposals for Stage 7 (including Oversight Committee discussion)
21. What types of data would you find it useful for the sponsor to provide, and in what form, when seeking feedback for its post-implementation review?
Please enter your comments below.
Performance indicators directly related to the purpose.
Other impact indicators as originally defined and agreed.
Any other positive of negative impacts that were unforeseen.
Independent certification of the validity of these measurements.
Summary of any feedback from stakeholders, plus detailed feedback.
Intervening pertinent changes from elsewhere.
Other impact indicators as originally defined and agreed.
Any other positive of negative impacts that were unforeseen.
Independent certification of the validity of these measurements.
Summary of any feedback from stakeholders, plus detailed feedback.
Intervening pertinent changes from elsewhere.
22. Overall, will Stage 7 improve the airspace change process?
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Yes
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No
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Don't know
23. Overall, will the airspace change process proposed in Chapter 4 achieve the right balance between fairness, transparency and proportionality?
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Yes
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No
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Don't know
24. Should the CAA set up an Oversight Committee?
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Yes
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No
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Don't know
Summary of guidance for the proposed process
25. Are there any other areas where the CAA should provide guidance?
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Yes
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No
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Don't know
Please give reasons for your answer
(If this doesn't already form part of any of the above):
Guidelines for preparing an impact statement (noise, air pollution, congestion, etc. as it relates to ALL affected communities). With respect to noise perception, this should include not just decibel range, but also geographic spread/positioning of traffic corridors, contrast with background noise level, night and day flights, frequency of overflights (minimum times between successive flights AND flights per hour), altitude ranges and descent and take-off angle distribution within the audible zone should all receive mention and consideration.
Guidelines for preparing an impact statement (noise, air pollution, congestion, etc. as it relates to ALL affected communities). With respect to noise perception, this should include not just decibel range, but also geographic spread/positioning of traffic corridors, contrast with background noise level, night and day flights, frequency of overflights (minimum times between successive flights AND flights per hour), altitude ranges and descent and take-off angle distribution within the audible zone should all receive mention and consideration.
CHAPTER 5: Scaling the airspace change process
26. Does Table 5.1 give sufficient clarity and detail of how the process will be scaled?
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Yes
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No
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Don't know
27. Do you have (i) any views on the way the Levels are categorised in Table 5.1, (ii) alternative suggestions as to how we might categorise different airspace changes, or (iii) other views about the proposed scaling of the process generally?
Please enter your comments below.
No.
28. Do you agree that the number of airspace change proposals put forward to the CAA is likely to increase in the future?
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Yes
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No
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Don't know
CHAPTER 6: CAA duties when carrying out our airspace functions under section 70 of the Transport Act 2000
29. Do you have any views about the CAA’s interpretation of section 70 of the Transport Act 2000, as set out in Chapter 6?
Please enter your comments below.
None.
CHAPTER 7: CAA cost recovery for administering the airspace change process
30. Do you have a preference for either of the long-term options for recovering the CAA’s airspace change costs that are set out in Chapter 7? Please give your reasons and any other views on how the CAA recovers its airspace change costs.
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Option 1: UK en route unit rate
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Option 2: A new statutory charge
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No preference
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Don't know
31. In the short term the CAA will still have to set up a new statutory charge. On which entity would it be most appropriate to levy this charge? Please give your reasons.
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UK airport operators
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UK airlines
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NATS/NERL
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No preference
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Don't know
CHAPTER 8: Transition to a new process
32. Are our proposed transition arrangements between the old process and the new process reasonable?
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Yes
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No
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Don't know
CHAPTER 9: Next steps
33. Are our timescales for introducing the new process reasonable?
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Yes
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No
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Don't know
Appendix B: A portal for airspace change proposals
34. Do you agree with the concept of an online portal?
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Yes
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No
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Don't know
35. Should the online portal contain any functionality beyond what we describe or documentation other than that shown in Table B1?
Please enter your comments below.
Don't know of any.
36. What are your views on locating the sponsor's consultation on a CAA portal where the sponsor administers the documentation and responses?
Please enter your comments below.
Any third party managing the consultation process should have oversight of the consultation responses and analysis.
37. Is it essential that the online portal is a single website or could different websites (CAA, sponsor, consultation portal) be used for different aspects of the process?
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Yes
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No
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Don't know
Please give reasons for your answer.
The consultation portal should be separate.
38. Do you have any views on the CAA's analysis of the three options for an online portal, bearing in mind that the CAA will need to recover its costs through charges on those it regulates?
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Yes
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No
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Don't know
Please give reasons for your answer.
See above.
Appendix D: The impact of the CAA's proposals
39. Is our assessment of the effects of the new process in Table D1 reasonable?
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Yes
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No
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Don't know
40. We are interested in your views on the additional costs in terms of time and resources that the proposed process will create for all parties. We are particularly interested in estimates of the monetary costs and benefits to sponsors of previous airspace changes and how these would have been affected by the CAA’s proposed new process.
Please enter your comments below.
I suspect estimates of real costs would be impossible. For example, Gatwick's unilateral and secretive arrivals flight path changes in 2013 spawned between 10-20 voluntary community action groups plus dedicated efforts on behalf of local councils, and employment of time on behalf of all parties concerned simply because a democratic process had not been followed in the first place, facts were hidden, unnecessary unproductive animosity created, etc. Apart from any measurable legal costs engendered by a challenge to Gatwick's actions, the overall real social cost engendered has already been colossal, and the lack of trust that still persists and failure to provide answers to some key questions, imply that all this will continue. By tidying up the process, it has to be believed that the CAA would be reducing a considerable amount of wastage of effort, albeit only a small fraction of it measurable in monetary terms.