Farnborough Controlled Airspace

[James Chan]

I can note the following risks as a result of the airspace proposal:

a. The impact to Fairoaks and Blackbushe departures and arrivals to/from the South West and South respectively has not been fully considered.
i. Departing aircraft should be able to obtain clearance while on the ground while arrivals properly co-ordinated to fully integrate with circuit traffic.
ii. If this is not done, it is likely that the risk of mid-air collisions will be greatly increased at the pinch point by aeroplanes orbiting waiting for clearance.
iii. Unnecessary orbiting is also a waste of time and fuel and increases aircraft noise to residents beneath.
b. Part of the Odiham and Blackbushe ATZ lies within the CTR – again another recipe for infringements as demonstrated by aeroplanes getting ‘lost’ going into and out of Denham and White Waltham.
c. The 1500ft base CTA is below MSA, a risk for CFIT for aircraft in IMC who cannot get IFR popup clearances, and also another recipe for infringements as demonstrated by Stansted incidents.
d. The RMZ, besides being asymmetrical which adds to airspace complexity, seems dubious whether it would work or achieve much in that area – For example there’s no way non-radio traffic can get past the Gatwick/Farnborough gap.

I personally believe the proposal should be rejected because:

a. The risks above have not been fully considered.
b. The total volume of the class of airspace requested does not justify the number of IFR movements, nor the passengers enplaned.

Code: Select all

Year      Allowed       Actual (Capacity Used-%)           Passengers
2008     28000         27946 (99%+)          Not published – Est. 7 avg. per aircraft
2009     28000         24262 (87%)                                 “
2010     28000         25835 (92%)                                 “
2011     31000         25027 (81%)                                 “           
2012     37000         25821 (70%)                                 “
2013     41000         24761 (60%)                                 “

c. Requesting for more Class A volumes of airspace on the south coast is unacceptable – just because they think nobody is using it is no basis for making it IFR-only. This must be resisted strongly, just like the London (TMA) Class A grabs.
d. Does not return to Class G when Farnborough is closed.
e. The conflictions with unknowns just outside the ATZ is one of the key drivers for this ACP. I’m not aware with any conflictions with other traffic outside 5nm of Farnborough so I’m not entirely convinced of the need for Class D airspace there.
f. The perceived exclusiveness of the airport to protect and serve some ultra high net-worth customers who can afford to pay a minimum of £450 to land there and consquently have improved flight efficiency and fuel-economy at the detriment of others around them.

Perhaps an alternative design that I could personally live with is:

a. The CTR that allows Farnborough to join up to the London TMA and no more. It is returned to Class G when Farnborough is closed. I gather most airports around the world with ATC and an IAP do have Class D airspace from the ground upwards. I hope this should eliminate the vast majoirty of the go-arounds that have happened due to unknown traffic with unknown intentions.

Just my thoughts.

[tnowak]

Will the LAA be providing guidance on how to formulate our individual objections regarding the Farnborough airspace proposal?

Or do we just do our own thing? Just around 40 days to go to submit our objections.
Tony Nowak

[tnowak]

Well, not many new posts/updates on here regarding Farnborough's airspace change proposal, nor anything in the latest LAA magazine.

Just under 30 days left to lodge your objections/comments.

I got this from the Vintage Aircraft Club, so thought it would be worth copying over:

===========================================================
As mentioned in the last issue of Vintage and Classic magazine, TAG
Aviation, who own Farnborough are attempting to have a very large area of
airspace in Southern England reclassified as controlled airspace. Their bid
is disproportionate and unnecessary, and would only benefit a very small
percentage of users of this airspace - and no doubt TAG's profit margins.

If it were to go ahead it would effectively block a huge swathe of air space
to VFR and non-radio, and likely, non-transponder traffic. The gliding
community will be particularly affected by this with Lasham, the world's
busiest gliding site, effectively rendered unviable were this 'grab' to go
ahead.

For this reason it has been agreed across the light aviation community via
the LAA and General Aviation Alliance, that the British Gliding Association
will take the lead in responding to the consultation and formulating the
case against TAG's proposals.

As you will see from BGA Chairman, Pete Harvey's message below, we are now
reaching the point where we as individuals should all now make our feelings
known. We have until May 2nd to do this, so please take a moment to read
the message below and take a look at the suggestions for framing your
response.

Even if you are based far from the south of England, do not think that this
is "not your problem". Whilst it may not affect you directly, we are still
asking for you to get involved. We believe that a number of regional
airports are watching the outcome of this ACP very carefully. If Farnborough
succeeds in obtaining large volumes of new controlled airspace, we expect a
number of applications for new controlled airspace from other airports. One
of these may affect you.

Please read on.

Best regards

Stephen Slater
Chairman
Vintage Aircraft Club

-----Original Message-----

TAG Farnborough ACP Consultation

The BGA has published its guidance to help pilots formulate their response
to the TAG Farnborough Airspace Change Proposal consultation.

This guidance, together with other useful links and a new message from BGA
Chairman Pete Harvey is available on the Farnborough ACP consultation page
of the BGA web site at
http://www.gliding.co.uk/bgainfo/airspa ... orough.htm

The message from Pete Harvey is reproduced below:

Message starts..........

The operator of Farnborough Airport, TAG Farnborough, has begun the formal
process of applying for controlled airspace.

Their proposals directly affect current controlled and uncontrolled airspace
across a large area of southern England - not only in the immediate vicinity
to Farnborough Airport.

If TAG get what they want, the likely impact on gliding (and other forms of
general aviation) would be significant. Pilots and clubs will be affected.
The impact would range from catastrophic for some gliding clubs through to
extremely disruptive for other clubs and pilots flying in the area.

The impacts are not restricted to aviators and aviation. Many other local
groups are also likely to be adversely affected.

The only party to benefit will be TAG.

The TAG Farnborough proposals are out for consultation up until 2 May 2014.
TAG will then formally submit their application to the CAA sometime during
the summer.

It is vitally important that everybody that is part of our community
provides input to the consultation and makes their opposition clear. The
main general aviation organisations are already working closely and will be
providing information to help people understand the issues that are of most
concern.

Please do not imagine for one moment that this will not affect you. If you
are ever likely to fly in the southern part of England, it will. And please
do not imagine for one moment that others will sort the situation out for
you. They will not be able to do that unless you play your part and actively
oppose TAG.

Please read the background and guidance and plan to respond. We will all be
very grateful for your help.

You can view the update by going clicking the following link;
http://www.gliding.co.uk/bgainfo/news.htm

=================================================
Tony Nowak

[Tom Beck]

Time is running out for all of us. Please have a look at GliderPilot.net and make up your mind.

Here is a piece written by John Johnson this evening on uras:-

“The CAA is NOT a government department, we might be better off if it was.
The CAA as its name suggests an agent of the government. It is closer to a
private company than a government department, it is if you like a private
company tasked with the administration of aviation matters and the
enforcement of government laws and regulations. One of the constraints put
upon it is that it must be budget neutral, it does not and cannot be
allowed to receive any funds from the public purse for this task. It gets
the money it needs to operate from charges it makes to its "customers"
which includes you and me, yes the fees we pay go to pay the numpties who
staff it except they are not numties, they are well qualified business
people from the commercial aviation sector with a smattering of former
senior military officers. The income stream from GA and gliding is a
pittance, the major source of its income is the commercial aviation sector
so who do you think it might favour when making decisions? It's response to
an overspend would have to be an increase in charges.
It does not have to negotiate anything, it is the regulator, and there is
no simple way of appealing any of its decisions save a judicial review. If
you have that sort of power do you really need to respond to what anyone
says, particularly from people who do not provide much income.
The way it is set up it does not have to take instructions from government
save the laws and regulations that parliament may make, it cannot otherwise
be told what to do, it is like any other private company.
If after reading this you conclude we are screwed you are probably right.
Don't take my word for it, read up on it, there is enough information out
there”.

Don't for one minute expect the CAA to do the right thing for recreational aviation.

[Andrew Leak]

As Tom quite eloquently puts, we're all screwed! TBH I've replied to just about every consultation thrown at us for the past few years and two things have come out of this for me: for info, I fly powered a/c and gliders and live in Southampton so this will affect me. That being that, I am running out of energy with all this airspace grabbing, licensing and medical changes, airfield closures etc etc and I don't know: 1. whether I can be bothered to respond to ANOTHER consultation that looks to be a waste of time for GA as organisations like TAG are too powerful and judging by their clientelle they can afford a legal fight. 2. I don't know how to respond to this one as I've been through the proposals and I am more confused than ever as the altitudes for the proposed CAS is a tad irratic to say the least, let alone what they want to do with the rest of the coverage! Maybe I should just forget this flying stuff as a non viable hobby now as I fear I may be one of those pilots to stray into the Farnborough 'Triangle' and either disappear without trace or have my license pulled when my Aware isn't quick enough to tell me I'm 50 feet into someones Class A or strayed slightly too high! Is there anyone who has put a rationally usable template together so I can get my head around this stuff? before they make the whole UK, Class A, from surface to FL195. I don't normally go down without a fight but this has to be the final straw.

Andrew

[Brian Hope]

Hi Andrew, I really do understand where you are coming from, it can seem these days that, despite promises from EASA and CAA, 'our end' of the GA spectrum is ridden rough shod over by the big boys, especially on airspace issues. It is time for the CAA to put its promises of making life better for GA into action, and I can think of no better example of that opportunity than the Farnborough proposal. It is patently clear that this is a morally baseless proposal by a group that has the financial clout to take it forward; in terms of numbers and the fair use of airspace it is groundless.
We are faced with two choices, sit back and do nothing, or make sure that the powers that be understand how badly we will be affected by the Farnborough proposal so that we get considered. Please do not give up, have your say. The BGA is leading on this particular issue and you will find some in-depth comment on their website about making a response http://www.gliding.co.uk/bgainfo/airspa ... orough.htm. There is also some advice on the LAA website in the NEWS section.
The consultation ends on May 2.

[Chris Martyr]

Andrew raises a valid point in his post. Most of us are sick up to the back teeth of these regional airfields with negligible traffic volumes trying to up their profiles by making unrealistic and unjustifiable claims to airspace which they think they're entitled to.

Many of us have made representations in recent years and sent in our objections . Not only with airspace stealing, but also in protest to airfield closures , and one does get to a stage in thinking if any of it has any sort of an effect on our adversaries , as all you get in response is an automatically generated e-mail from Mr [email protected]

This latest one is particularly galling as the responder is presented with a massively diversified document dealing with multiple aspects of the proposal and its justification and is then led into a mutli-choice response questionnaire which cannot be accurately answered without first spending literally hours attempting to read and digest it all. It's obvious what they're driving at .

I'm sitting here on a beautiful Saturday morning thinking what shall I do . Spend half the day going through airspace grab proposals and then embarking on a questionnaire which will probably leave me wanting to slash my wrists ?
Or go down to the airfield and pull out my aeroplane . I only do this for recreation , so what the heck,,I'll just stay away from Farnborough and their four biz-jet movements per day.

Yes, I know that it's a regrettable attitude , but Andrew's point resonates with many of us .

I apologise in advance to John Brady , as he does a brilliant job on our behalf, but I reckon that after T.Blairs demise , there must have been an awful lot of spin doctors with time on their slimy hands looking for new opportunities. And they've certainly found it in the fast growing airspace consultation industry !

Still,,,,must go. Clear Prop.

[Tom Beck]

Has anyone else noticed that TAG/NATS are changing the response form questions and answers as a function of the responses which they have received to date; talk about a moving target!

Best not bother with any of the loaded questions and even worse the selection of answers on the ACP. Go straight to E17 and download your FreeForm response. It can be a hand written document or a pre prepared word document.

There is no end to the skulduggery going on here and you would be well advised to send a copy of your submission to the LAA or BGA and certainly to the CAA. Try Jim Walker who is the secretary of the National Air Traffic Management Advisory Committee (NATMAC) and a member of the Director of Airspace Policy (DAP) within the CAA. The Chairman is Mark Swan and it is he who will make the final judgement on the FArnborough ACP - like he did at Norwich.

TAG/NATS have done everything possible to deter participation in this ACP.

"The Only Thing Necessary For The Triumph Of Evil Is That Good Men Do Nothing."

[Ian Law]

Thanks for your suggested course of action Tom and I'll try responding using that method.

I doubt I have the patience or time left to cope with the rest of the contrived nonsense thrown at us in these situations.

If we were able to respond by way of a "petition", endorsing the official LAA line, there would surely be an overwhelming rejection of these proposals. How many more times do we have to go through the same routine, I wonder and why should it be any less meaningful were I to endorse the much more expertly argued response from, say, John Brady.

Ian

[Tom Beck]

Sorry guys but you need to be very VERY careful over how you respond. In the case of Norwich, 537 individuals responded of which there were only 3 in support of the proposal. Guess what? 534 responses were thrown in the bin and the 3 carried the day.

The CAA, NATS and TAG all run programs which will trash any response which uses the same sequence of words or visual display. You must not be part of a campaign and you must use only your own words, so cut and paste is not an option and don't use anyone else's ideas. TAG are just looking for an excuse to chuck your response in the bin; don't give them that chance.

Here is a classic piece from the Norwich ACP response which the CAA went along with:- "Those pilots who make a conscious decision not to transit through CAS must do so in the full knowledge of the nature of the surrounding airspace. Thus the perception of choke points is a function of piloting decisions, not airspace classification. This issue has been discussed with the CAA.
Sleep tight.
Tom.

[Brian Hope]

I only do this for recreation, so what the heck, I'll just stay away from Farnborough and their four biz-jet movements per day.

That may be fine for you Chris, but what about the people who are based and fly in the Farnborough area for whom this airspace grab would have a very inconvenient impact?
I'm all right Jack attitudes won't do you any good if somebody decides to grab the airspace where you fly from or regularly operate, will they?
Sport and Recreational Flying can only have an impact on bad regulation and airspace if we work together. The Associations do that through the GA Alliance, and as members we should support the work our associations are putting in. 'Sorry John, I can't be bothered', or 'I don't have the time' is a cop out when you consider John is a volunteer who does not get paid to put in hours of work and attend meetings around the country to fight our corner. Good job he doesn't decide not to bother and goes flying in his RV instead isn't it?

[Chris Martyr]

Oops,,,,,,,,,looks like my brilliant tact and diplomacy skills have got me into hot water again .

Sorry mate , I guess that did come across as a tad flippant , although I can reassure everyone that I have been as pro-active as anyone else in objecting to all the airfield closures and airspace stealing.
That's why I became so irritated at Farnborough's rather convoluted and un-user friendly consultation bumph.
The point that I was really trying to make is , if they deliberately build in this over-complexity to their documentation then it diffuses the response into many, many fragments. Which of course works to TAGs advantage.
Along with many other members I am very grateful to John Brady and the other good folk who work so tirelessly for our hobby. Even you, y'grumpy old git.

[Brian Hope]

Hi Chris, no need to apologise to me, we are all entitled to a view. I’d like to think I’m generally a happy soul but we can all get frustrated (and grumpy) by the continual challenges that we have to fend off, often, I agree, with limited success.
I attended the White Waltham meeting the other week where TAG tried to justify their proposal, without success. Their presentation was pretty poor and as you might expect, there was in my view at least, a degree of arrogance. When asked what they intended to do if the CAA did not get a derogation from SERA, they said they had a ‘Plan B’ but they certainly weren’t prepared to say what it was. Why not? Do we not have a right to know? I suspect their Plan B is to carry on with Plan A, in which case they were wise to keep shtum about it.
For those not up to speed on SERA, it is the Standardised European Rules of the Air and will mean for a crossing of the propose Class D you will have to remain 1000ft clear of cloud. On a typical 2000ft cloud-base day that will mean it unlikely you will get a VFR clearance and will have to ask for a Special VFR clearance, which means you will need to be positively identified. Put bluntly you will need a transponder, despite their promises that they could identify you by alternate means. Their promises of enough controllers to meet demand and – wait for it – ‘possibly’ a dedicated crossing clearance controller also take a large dollop of trust (naivety) to believe. How long before they say ‘sorry guys, we cannot justify the expense’.
Yes the consultation response document is a bit tricky, and yes we have been here many times before, but what happens if we all decide to do nothing about it? We’ll end up like one rather misguided member at WW who commented – ‘personally I prefer to fly in a known environment.’ I could only wonder whether he still believed in the tooth fairy.

[Brian Hope]

Mike Jackson, who has been the LAA's liaison with BGA on the Farnborough proposal, today sent the following note re the submission of a response, which hopefully adequately explains the options available:

Following issue of this request, the LAA has received several queries on the airspace change process and the methods of making objections. The following notes are given to address the questions raised.

The CAA defines the required process for an Airspace Change Proposal to be followed by the applicant, in this case TAG Farnborough Airport. This process requires the applicant to conduct the consultation and receive all the responses. Responses do not need to be in the form as requested, and may be by post, but of course should clearly state that they are an objection to the Airspace Change Proposal.

To use their provided method for response, you may confine it to “Leave feedback for PART E” and answer as many or few of the questions as you wish, or confine your response to “Additional Comments” at the end. You will see that this enables you to attach a pre-prepared statement.

Every single response in its entirety is required to be forwarded to the CAA with the application when submitted, who consider all points made independently of the applicant.

Postal responses should be to TAG Farnborough Airport, GU14 6XA.

[Ian Law]

Thanks Brian. That seems like something I may be able to cope with.

Ian