Response 545429770

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About You

A. Are you responding in an official capacity on behalf of an organisation?

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(Required)
Yes
No
London Biggin Hill Airport

B. What is your name?

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Peter Thompson

D. Are you answering as:

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(Required)
Air passenger, shipper or customer
Resident affected by aviation
Local organisation such as a community action group, airport consultative committee or forum
General Aviation (GA), including representative organisations
New or developing airspace user, such as remotely piloted aircraft system, eVTOL, space industry, including representative/related organisations
Commercial aviation/aerospace industry including trade associations
Consultancy
Central or local government body, including military
Elected political representative such as councillor or MP
National or international organisation (excluding GA organisations and industry trade associations), e.g. NGO

E. Where do you live or where is your organisation based?

Please select one item
East of England
East Midlands
West Midlands
North East
North West
Northern Ireland
Scotland
South East
South West
Wales
Yorkshire and the Humber
Outside the UK

G. Do you consent to us contacting you by email about progress with this consultation?

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Yes
No

H. Do you consent to your response being published?

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Yes, with personal identifying information (name, organisation, respondent category, location, additional information - please note your email address will NOT be published if you choose this option)
Yes, anonymised (no information in questions A to G will be published)
No

Background to the Proposals

1. In general terms, do you agree that a single airspace design entity in the form of a UK Airspace Design Service (UKADS) provider, properly scoped, funded and implemented, would address the challenges identified and improve delivery confidence in airspace modernisation?

Please select one item
Yes
Maybe
No
Don't know
We have recognised this as a requirement from the beginning of the process.

Scope and priorities

2. What are your views on our proposal that the end-state UKADS scope encompasses all ACPs in UK airspace?

Please select one item
Agree
Agree, subject to additional considerations
Disagree
Don't know
UK ADS is appropriate for large, complicated, multi-sponsor ACPs , such as FASI, but not appropriate for the majority of small single sponsor ACPs.

3. What are your views on our proposal that the short-term UKADS scope should be the London TMA region?

Please select one item
Agree
Agree, subject to additional considerations
Disagree
Don’t know

4. What are your views on our proposals for the UKADS scope in the medium term?

Please select one item
Agree
Agree, subject to additional considerations
Disagree
Don’t know
See question 2.

A phased approach to delivering the UKADS

5. Do you have any views on our proposed two-phase approach?

Please select one item
About right
Minor modifications needed
Major modifications needed
Don’t know
We agree with phase 1, but not with phase 2.

6. Do you have any views on the models that have been considered?

Please select one item
About right
Minor modifications needed
Major modifications needed
Don’t know

Our proposed initial operating model (UKADS1 within NERL)

7. Do you have any views on our proposal that NERL takes on the initial task of providing airspace design services through UKADS1?

Please select one item
Agree
Agree, but subject to additional considerations
Disagree
Don’t know

8. Do you consider that in progressing a particular cluster of the masterplan, UKADS1 should take over ACOG’s current coordination or masterplanning role for that cluster?

Please select one item
Agree
Agree, but subject to additional considerations
Disagree
Don’t know
This approach would lead to cliff edge discontinuity and would potentially mislay or obscure a great deal of accumulated knowledge gained thus far in the process.

9. Do you agree that organisations should be able to continue sponsoring ACPs that are in scope of UKADS1 if UKADS1 is not able to prioritise them?

Please select one item
Agree
Agree, but subject to additional considerations
Disagree
Don’t know
UKADS1 will need to ensure that it has adequate resource available.

Remit for the initial operating model (UKADS1 within NERL)

10. Do you agree with the proposals for UKADS1's remit?

Please select one item
About right
Minor modifications needed
Major modifications needed
Don’t know

11. Do you agree with the approach we propose for consultation and engagement on ACPs, including who pays for these activities?

Please select one item
About right
Minor modifications needed
Major modifications needed
Don’t know

Transition arrangements for the initial operating model (UKADS1 within NERL)

12. What are your views on our transition proposals?

Please select one item
About right
Minor modifications needed
Major modifications needed
Don’t know
UKADS needs to ensure that they have an airspace for all approach, to ensure that larger airports do not monopolise the available airspace.

13. What are your views on our proposal that, where appropriate, UKADS1 should merge the existing ACPs into a single ACP for the cluster or deployment?

Please select one item
Agree
Agree, with additional considerations
Another approach
Don’t know
UKADS will need to ensure equitable access to airspace.

14. What are your views on our proposal that the CAA approves each transition plan?

Please select one item
Agree
Agree, with additional considerations
Disagree
Don’t know
The UK CAA should have little input with the FASI ACP transition plan or determination, because it lacks the capability and competence to assess the design detail of an ACP of this scale. Determination should be made by the Secretary of State based on recommendations from the CAA/NERL.

15. What changes would you propose to amend and/or supplement CAP 1616 in order to accommodate the UKADS?

CAP 1616 needs a complete revisit as it it has not been designed for multi-sponsor ACPs. A bespoke process is required to deliver a multi-sponsor ACP such as FASI.

Governance for the initial operating model (UKADS1 within NERL)

16. What are your views on our proposals for UKADS1 governance?

Please select one item
About right
Minor modifications needed
Major modifications needed
Don’t know

17. Would these proposals give sufficient reassurance that potential conflicts of interest arising from NERL providing airspace design services through UKADS1 are mitigated?

Please select one item
Yes
Partly
No
Insufficient detail / don’t know
Some Sponsors employ NATS NERL Services, so it must be clear that such Sponsors are not advantaged in the process.

Funding UKADS and other airspace change

18. What are your views on our proposed new Airspace Design Charge to meet the efficient costs of NERL in providing an airspace design service through UKADS1 and to create a UK Airspace Design Support Fund for other eligible UK airport ACPs?

Please select one item
Agree
Agree, but with qualifications
Use another method
Don’t know

19. Which elements of expenditure on an ACP do you think should be eligible under the UK Airspace Design Support Fund?

Procedure Design, Environmental Studies and Public Consultations should be eligible for funding.

Airspace modernisation offers National economic and environmental benefits and should be treated as a National Structure and paid for by Government and/or user. The current system is akin to asking Service Stations to pay for the Road Network.

Our ambition and expectations for the proposed end-state operating model (UKADS2)

20. Do you have any views on our proposed concept for UKADS2?

Please select one item
About right
Minor modifications needed
Major modifications needed
Insufficient information / don’t know
UKADS2 is unnecessary and represents an overreach. There can be no rational benefits identified by imposing what amounts to a monolopy.