Norwich bids for Lebensraum
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Bill Scott
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John Brady
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To update progress with Norwich, the Operations director came to Turweston to discuss the issues with the LAA and BGA. I append the text of an email I sent him afterwards summing up our position on behalf of both organisations. It is good to be working with the BGA who have people with expertise we don't have
Sorry the text is a bit long but we had a lot to say!
John
Dear Richard,
Thank you for coming to Turweston on Friday. Both our organisations found it helpful and we hope it was worthwhile for you too. We thought it might be useful to list some of the key points as we saw them.
1. We spent some time discussing the problems of access to CAS for GA and particularly gliders, referring to our experience that controllers are unable to give a clearance to multiple gliders and other aircraft. We also noted that at other regional airports, access to ATSOCAS services has reduced because of the need to concentrate on class D clearances which are themselves limited by controller capacity. You told us that you would always have sufficient controllers but the same has been said during every recent consultation on CAS at regional airports but it has not been delivered. We know you cannot have extra controllers on immediate standby to respond to a tactical change in traffic levels caused by groups of gliders or numbers of light aircraft taking advantage of a spell of good weather. There is just no business case for having more staff than you need for your core activity so we maintain our position that other airspace users would be severely affected by the proposal, even those who could seek a crossing clearance.
2. We also confirmed our concern about the choke point effect that would arise from this access issue and the consequential increase in risk in the remaining class G airspace. We were grateful for the realignment or the corners of the proposed CAS and whilst that will ease the issue in some areas, it does not resolve it. The issues with choke points are well known; there is increased risk of collision between aircraft outside CAS and there is increased risk of infringement impacting on traffic inside CAS. Given the 2 recent fatal accidents involving air cadets, both of which had elements of choke point risk in their causes, we remain particularly concerned about the air cadet gliding operation to the west and the impact of that choke point on both air cadet aircraft and other aircraft using the airspace. We think you need to deal with that. The very existence of these choke points increases workload and stress for controllers which you are at pains to reduce in your proposal. Should you go forward with this proposal we request that your submission includes your consideration of the possible increase of risk that will inevitably occur to other airspace users close to the proposed airspace and how you intend to mitigate for this situation.
3. We were very concerned about the proposal to cede class D airspace to RAF Marham as that would make access by GA aircraft and gliders more difficult than the normal clearance procedure. Indeed it would almost certainly make it impossible. As an alternative we asked you to consider FUA allowing free access by all to that area during the relevant periods.
4. We raised the matter of Airprox and other events quoted in the consultation document as we had proposed that most of these were of no relevance to the proposed CAS. For example, we said the airprox that had occurred at FL180 well away from airport had no relevance. In reply you said that the relevance was that your controller would have been distracted by this airprox reducing their ability to control other aircraft safely and that having a class D CAS would have improved this situation. We found this explanation tenuous in the extreme and regard the control requirements within CAS to impose an increased responsibility on a controller such that a distracting incident outside the CAS would be likely to involve greater risk rather than less. Moreover you did not make any reference to this in your consultation thereby misleading consultees into thinking there was a direct risk of collision resulting from the absence of class D CAS when that was not the case. Your explanation was not at all persuasive. We maintain our position that listing these incidents which did not occur within the sphere of the proposed CAS was seriously misleading to consultees. We would ask that should you go forward with this ACP you ensure that DAP is aware of our specific concern about both the validity of the argument you put forward at this meeting and the way this data was presented in the consultation.
5. One of our number produced external data to demonstrate that even if all the Airproxes that you list were considered valid, the airprox rate per movement in the Norwich class G area is lower than the similar Airprox rate that a major UK airline suffers in Class A airspace. We therefore aver that your airspace is already safer than all UK airways and the London TMA. If you decide to go forward with this ACP we require that you draw specific attention to this in your submission to DAP. If you require data we could ask that it be released to you.
6. We asked you about your stated need to establish CAS up to 6000ft in order to have a 6000ft TA and 4 holding levels within CAS as well as facilitating CDAs. We believe that there is no DAP policy on setting a TA of 6000ft and no specific requirement for 4 holding levels nor that CAS at regional airports should have such a minimum upper level. As you had concluded that there is no justifiable safety requirement for airway connectivity because of the low traffic density and given that the incidence of holding is much less that the incidence of flight to and from airways, logically this suggest that there is no safety case for establishing the hold in CAS either. We therefore suggested that as holding by public transport flights is very unusual it could reasonably be established outside CAS. Thus the airspace design could have a lower upper limit allowing overflight by other Class G airspace users. As discussed, it would be interesting to know the frequency of holding by public transport flights; perhaps you will give us that data? We recognise that CAP 725 Appendix A requires the airspace design to contain all procedures (therefore including the hold) but we will write to DAP to propose that this requirement prevents proper consideration of the options within an ACP. We will send you a copy of that letter. Finally, although we did not discuss it at our meeting none of the 4 airline captains present had ever found the TA at all relevant to their ability to conduct a CDA effectively.
7. We asked you to consider other options from the airspace toolbox including class E airspace and perhaps class E plus radio which seemed to have the potential to completely satisfy your concerns and having much less impact on other users. We are aware that DAP policy on class E is driven by outside events which are not yet complete but you were going to ask them about this policy.
8. We were unconvinced that traffic levels had now bottomed and that you could look forward to a period of sustained growth. You have offered no evidence to support your assertion and previous forecasts have been proven wrong. You stated that you are now having some 80 movements daily but we produced movement data for CAT and Gas platform traffic for the period 0700 to 1755 last Friday that showed 10 CAT departures and 5 gas platform movement and over the same period 11 CAT arrivals and 1 gas platform movement. Thus a total of 28 commercial passenger movements. We found it difficult to believe that after 1800 this figure will have increased by more than a few. Perhaps you could let us have the relevant data to substantiate the 80 commercial transport daily movements? You also said that due to the fact that your movements are at a considerably low level you would probably wait a while, you said perhaps a couple of years before you would put the ACP forward but we were then very surprised that you stated that you wished to try and get the ACP to DAP by July. We appreciate that you said you had to make decisions going forward in the coming week so perhaps you could you give us guidance on your plans when you can. Whilst we recognise your business need to take a positive view of this, we were of the opinion that after many years of reductions of some 20% year on year, sustained growth needs to be seen for several years to provide actual evidence before the ACP goes forward.
9. Noting that the main issue in your consultation referred to the risk from uncoordinated military aircraft and we discussed that at some length. We remain concerned that you told us that there has been no effective engagement with MOD to resolve this. When we first drafted this note to you we included the following text:
We discussed the possibility that a military avoidance area could be established but perhaps because your main contact has been locally with RAF Marham, this has not been considered. We believe that several consultees referred to these areas in their response so perhaps we could expand on this issue for you. A procedure exists within the Military Low Flying System for protecting certain areas, predominately around civil airports and large conurbations by excluding military low flying traffic. These are practical areas, frequently but not necessarily governed by the shape of controlled airspace. They are within the gift of MOD and not subject to design rules such as those for controlled airspace. They are 'AVOIDANCE AREAS', colloquially known as 'Chain Link Areas' and they are clearly defined by a red chain symbol on military low flying charts. Examples of these are depicted on the attached fragments from military charts. You should be able to persuade MOD to establish an Avoidance Area to protect Norwich airport. Whilst you could ask for an Avoidance Area the size of the proposed CTR, we suggest that 3 nm either side of centreline would provide protection proportionate to your principal concerns. This Chain Link would not affect civilian airspace users. This an arrangement should be a practical solution that could be implemented quickly and cheaply and appears to hold the prospect of an immediate reduction in the perceived risk regardless of the outcome of an ACP. The sponsor for the UK Low Flying System (UKLFS) is Sqn Ldr Duffy whose post is ATC1 at HQ Air Command and the system is administered by the Operations Low Flying Cell at RAF Wittering. We think you should immediately ask DAP to facilitate an urgent discussion with Sqn Ldr Duffy.
However, on Monday one of our number spoke to Sqn Ldr Duffy to try to move this forward and we were surprised to find he had been working with the you (Norwich Airport) on this for the last 18 months. At our meeting you signalled that you were unaware of the options related to management of military traffic but that seems not to be the case. Sqn Ldr Duffy told us that the risk from military traffic has all but 'gone away' and that high energy runs on Coltishall are incredibly rare. Fast jets descending quickly from 16,000ft to undertake close air support work VFR at Swanton Morley and return to high level are also an infrequent event but we understand that you are notified about them so these are not unknown to you as you have suggested. He went on to say that such training was essential and that was the reason they had discussed the issue of ceding airspace to the west so it could continue in the event that the CAS is approved. It seems to us that by appearing to be ignorant of the MOD position, traffic levels and procedures you intended to play us off, one against the other, maintaining for our benefit the illusion of continued intense military traffic that you were unable to defend against. Perhaps that is the reason you sought to see us separately. It is now clear to us that your position on risk from military aircraft is grossly overstated and that you have kept the reduction in such traffic secret as you seek to justify class D CAS which does not now seem to be needed. It now appears that at our meeting, at which we tried to be as helpful as possible in the wider interest of air safety, you seem to have been less than open about your involvement with MOD. This is most disappointing.
In summary we believe the risk from military traffic is now negligible and much of what there is is already known to you. If you believe that military traffic still presents a risk you should seek an avoidance area, the arrangements for which you already aware of and do not need us to tell you. If you have failed to agree such an avoidance area with MOD you should ask DAP to arbitrate. In our view no CAS application should be considered until that is resolved to the satisfaction of DAP. On civil traffic there is clearly no risk based case for the establishment of CAS as your airspace is already safer than class A. Moreover you have insufficient traffic to warrant such CAS. Our overall position has not changed in that we believe that the traffic levels at Norwich do not justify the large area of controlled airspace proposed and we continue to oppose the proposal because it does not in any way meet the needs of other airspace users and will increase risk in the North Norfolk area. Indeed with the information you have given us and the facts we have now obtained from MOD, we oppose your proposal more strongly than before.
Sorry the text is a bit long but we had a lot to say!
John
Dear Richard,
Thank you for coming to Turweston on Friday. Both our organisations found it helpful and we hope it was worthwhile for you too. We thought it might be useful to list some of the key points as we saw them.
1. We spent some time discussing the problems of access to CAS for GA and particularly gliders, referring to our experience that controllers are unable to give a clearance to multiple gliders and other aircraft. We also noted that at other regional airports, access to ATSOCAS services has reduced because of the need to concentrate on class D clearances which are themselves limited by controller capacity. You told us that you would always have sufficient controllers but the same has been said during every recent consultation on CAS at regional airports but it has not been delivered. We know you cannot have extra controllers on immediate standby to respond to a tactical change in traffic levels caused by groups of gliders or numbers of light aircraft taking advantage of a spell of good weather. There is just no business case for having more staff than you need for your core activity so we maintain our position that other airspace users would be severely affected by the proposal, even those who could seek a crossing clearance.
2. We also confirmed our concern about the choke point effect that would arise from this access issue and the consequential increase in risk in the remaining class G airspace. We were grateful for the realignment or the corners of the proposed CAS and whilst that will ease the issue in some areas, it does not resolve it. The issues with choke points are well known; there is increased risk of collision between aircraft outside CAS and there is increased risk of infringement impacting on traffic inside CAS. Given the 2 recent fatal accidents involving air cadets, both of which had elements of choke point risk in their causes, we remain particularly concerned about the air cadet gliding operation to the west and the impact of that choke point on both air cadet aircraft and other aircraft using the airspace. We think you need to deal with that. The very existence of these choke points increases workload and stress for controllers which you are at pains to reduce in your proposal. Should you go forward with this proposal we request that your submission includes your consideration of the possible increase of risk that will inevitably occur to other airspace users close to the proposed airspace and how you intend to mitigate for this situation.
3. We were very concerned about the proposal to cede class D airspace to RAF Marham as that would make access by GA aircraft and gliders more difficult than the normal clearance procedure. Indeed it would almost certainly make it impossible. As an alternative we asked you to consider FUA allowing free access by all to that area during the relevant periods.
4. We raised the matter of Airprox and other events quoted in the consultation document as we had proposed that most of these were of no relevance to the proposed CAS. For example, we said the airprox that had occurred at FL180 well away from airport had no relevance. In reply you said that the relevance was that your controller would have been distracted by this airprox reducing their ability to control other aircraft safely and that having a class D CAS would have improved this situation. We found this explanation tenuous in the extreme and regard the control requirements within CAS to impose an increased responsibility on a controller such that a distracting incident outside the CAS would be likely to involve greater risk rather than less. Moreover you did not make any reference to this in your consultation thereby misleading consultees into thinking there was a direct risk of collision resulting from the absence of class D CAS when that was not the case. Your explanation was not at all persuasive. We maintain our position that listing these incidents which did not occur within the sphere of the proposed CAS was seriously misleading to consultees. We would ask that should you go forward with this ACP you ensure that DAP is aware of our specific concern about both the validity of the argument you put forward at this meeting and the way this data was presented in the consultation.
5. One of our number produced external data to demonstrate that even if all the Airproxes that you list were considered valid, the airprox rate per movement in the Norwich class G area is lower than the similar Airprox rate that a major UK airline suffers in Class A airspace. We therefore aver that your airspace is already safer than all UK airways and the London TMA. If you decide to go forward with this ACP we require that you draw specific attention to this in your submission to DAP. If you require data we could ask that it be released to you.
6. We asked you about your stated need to establish CAS up to 6000ft in order to have a 6000ft TA and 4 holding levels within CAS as well as facilitating CDAs. We believe that there is no DAP policy on setting a TA of 6000ft and no specific requirement for 4 holding levels nor that CAS at regional airports should have such a minimum upper level. As you had concluded that there is no justifiable safety requirement for airway connectivity because of the low traffic density and given that the incidence of holding is much less that the incidence of flight to and from airways, logically this suggest that there is no safety case for establishing the hold in CAS either. We therefore suggested that as holding by public transport flights is very unusual it could reasonably be established outside CAS. Thus the airspace design could have a lower upper limit allowing overflight by other Class G airspace users. As discussed, it would be interesting to know the frequency of holding by public transport flights; perhaps you will give us that data? We recognise that CAP 725 Appendix A requires the airspace design to contain all procedures (therefore including the hold) but we will write to DAP to propose that this requirement prevents proper consideration of the options within an ACP. We will send you a copy of that letter. Finally, although we did not discuss it at our meeting none of the 4 airline captains present had ever found the TA at all relevant to their ability to conduct a CDA effectively.
7. We asked you to consider other options from the airspace toolbox including class E airspace and perhaps class E plus radio which seemed to have the potential to completely satisfy your concerns and having much less impact on other users. We are aware that DAP policy on class E is driven by outside events which are not yet complete but you were going to ask them about this policy.
8. We were unconvinced that traffic levels had now bottomed and that you could look forward to a period of sustained growth. You have offered no evidence to support your assertion and previous forecasts have been proven wrong. You stated that you are now having some 80 movements daily but we produced movement data for CAT and Gas platform traffic for the period 0700 to 1755 last Friday that showed 10 CAT departures and 5 gas platform movement and over the same period 11 CAT arrivals and 1 gas platform movement. Thus a total of 28 commercial passenger movements. We found it difficult to believe that after 1800 this figure will have increased by more than a few. Perhaps you could let us have the relevant data to substantiate the 80 commercial transport daily movements? You also said that due to the fact that your movements are at a considerably low level you would probably wait a while, you said perhaps a couple of years before you would put the ACP forward but we were then very surprised that you stated that you wished to try and get the ACP to DAP by July. We appreciate that you said you had to make decisions going forward in the coming week so perhaps you could you give us guidance on your plans when you can. Whilst we recognise your business need to take a positive view of this, we were of the opinion that after many years of reductions of some 20% year on year, sustained growth needs to be seen for several years to provide actual evidence before the ACP goes forward.
9. Noting that the main issue in your consultation referred to the risk from uncoordinated military aircraft and we discussed that at some length. We remain concerned that you told us that there has been no effective engagement with MOD to resolve this. When we first drafted this note to you we included the following text:
We discussed the possibility that a military avoidance area could be established but perhaps because your main contact has been locally with RAF Marham, this has not been considered. We believe that several consultees referred to these areas in their response so perhaps we could expand on this issue for you. A procedure exists within the Military Low Flying System for protecting certain areas, predominately around civil airports and large conurbations by excluding military low flying traffic. These are practical areas, frequently but not necessarily governed by the shape of controlled airspace. They are within the gift of MOD and not subject to design rules such as those for controlled airspace. They are 'AVOIDANCE AREAS', colloquially known as 'Chain Link Areas' and they are clearly defined by a red chain symbol on military low flying charts. Examples of these are depicted on the attached fragments from military charts. You should be able to persuade MOD to establish an Avoidance Area to protect Norwich airport. Whilst you could ask for an Avoidance Area the size of the proposed CTR, we suggest that 3 nm either side of centreline would provide protection proportionate to your principal concerns. This Chain Link would not affect civilian airspace users. This an arrangement should be a practical solution that could be implemented quickly and cheaply and appears to hold the prospect of an immediate reduction in the perceived risk regardless of the outcome of an ACP. The sponsor for the UK Low Flying System (UKLFS) is Sqn Ldr Duffy whose post is ATC1 at HQ Air Command and the system is administered by the Operations Low Flying Cell at RAF Wittering. We think you should immediately ask DAP to facilitate an urgent discussion with Sqn Ldr Duffy.
However, on Monday one of our number spoke to Sqn Ldr Duffy to try to move this forward and we were surprised to find he had been working with the you (Norwich Airport) on this for the last 18 months. At our meeting you signalled that you were unaware of the options related to management of military traffic but that seems not to be the case. Sqn Ldr Duffy told us that the risk from military traffic has all but 'gone away' and that high energy runs on Coltishall are incredibly rare. Fast jets descending quickly from 16,000ft to undertake close air support work VFR at Swanton Morley and return to high level are also an infrequent event but we understand that you are notified about them so these are not unknown to you as you have suggested. He went on to say that such training was essential and that was the reason they had discussed the issue of ceding airspace to the west so it could continue in the event that the CAS is approved. It seems to us that by appearing to be ignorant of the MOD position, traffic levels and procedures you intended to play us off, one against the other, maintaining for our benefit the illusion of continued intense military traffic that you were unable to defend against. Perhaps that is the reason you sought to see us separately. It is now clear to us that your position on risk from military aircraft is grossly overstated and that you have kept the reduction in such traffic secret as you seek to justify class D CAS which does not now seem to be needed. It now appears that at our meeting, at which we tried to be as helpful as possible in the wider interest of air safety, you seem to have been less than open about your involvement with MOD. This is most disappointing.
In summary we believe the risk from military traffic is now negligible and much of what there is is already known to you. If you believe that military traffic still presents a risk you should seek an avoidance area, the arrangements for which you already aware of and do not need us to tell you. If you have failed to agree such an avoidance area with MOD you should ask DAP to arbitrate. In our view no CAS application should be considered until that is resolved to the satisfaction of DAP. On civil traffic there is clearly no risk based case for the establishment of CAS as your airspace is already safer than class A. Moreover you have insufficient traffic to warrant such CAS. Our overall position has not changed in that we believe that the traffic levels at Norwich do not justify the large area of controlled airspace proposed and we continue to oppose the proposal because it does not in any way meet the needs of other airspace users and will increase risk in the North Norfolk area. Indeed with the information you have given us and the facts we have now obtained from MOD, we oppose your proposal more strongly than before.
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Norfolkjohn
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ChampChump
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Bill Scott
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John,
Thanks for your eloquent and civil rebuttal on our behalf.
You have exposed their dishonesty very clearly and shown us that these people cannot be trusted to be transparent in their dealing with the rest of the aviation community.
What is a little unclear to me is what happens next? Are they still intending to go forward with their proposal?
In the light of your excellent exposure of their twisted 'facts', half truths and side stepping of issues such as the real situation with the RAF, it is clear any decision in their favour would be a travesty. Would a judicial review be an option? What processes exist to challenge such a perverse decision, should it be made in their favour?
Also, I'm sure that the RAF chap would be happy to keep to keep you/us in the loop on any further discussions
Thanks for your eloquent and civil rebuttal on our behalf.
You have exposed their dishonesty very clearly and shown us that these people cannot be trusted to be transparent in their dealing with the rest of the aviation community.
What is a little unclear to me is what happens next? Are they still intending to go forward with their proposal?
In the light of your excellent exposure of their twisted 'facts', half truths and side stepping of issues such as the real situation with the RAF, it is clear any decision in their favour would be a travesty. Would a judicial review be an option? What processes exist to challenge such a perverse decision, should it be made in their favour?
Also, I'm sure that the RAF chap would be happy to keep to keep you/us in the loop on any further discussions
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John Brady
- Posts: 284
- Joined: Tue Jan 08, 2008 8:39 pm
Bill,
Norwich need to decide if they go forward or not. Humberside recently decided not to because of reduced traffic.
If we have a complaint about a consultation the course of action is to write to the Head of Business Management at the CAA(DAP) who is the consultation coordinator.
We sent an initial letter to her in October last year but we would send a fuller letter once and if Norwich decides to submit an application. The text of our letter follows.
John
Dear Lou,
NORWICH AIRPORT CONSULTATION
You may be aware that in its response to Norwich the LAA took the sponsor to task for inaccuracies in its consultation document that had the potential to mislead the majority of respondents. The department will be aware of these issues from its own analysis but I would just mention the principle areas of concern to us which were airport movements and traffic growth, military activity levels in East Anglia and the use of Airprox reports outside the subject airspace.
Significant inaccuracies in consultations seem to be becoming the norm recently and it is unreasonable to expect consultees, especially non-aviation consultees, to be able to identify these and find the correct data. In this case the LAA deployed a team of people with specialist and local knowledge to analyse the document and research all facts presented by the sponsor. This proved to be a substantial task made urgent by our magazine deadlines and the need to get an analysis out to our members in time for them to make an informed response on correct data. Most other respondents will not have had this support and the majority will have formed their view on what was presented.
The level of detailed work on this consultation is unsustainable for the LAA and we believe that sponsors should be able to audit their own material for accuracy before publication. We would then only have to draw our members’ attention to the sponsor’s documents without detailed narrative.
Perhaps we could discuss in the margins of the forthcoming NATMAC.
Yours Sincerely
Norwich need to decide if they go forward or not. Humberside recently decided not to because of reduced traffic.
If we have a complaint about a consultation the course of action is to write to the Head of Business Management at the CAA(DAP) who is the consultation coordinator.
We sent an initial letter to her in October last year but we would send a fuller letter once and if Norwich decides to submit an application. The text of our letter follows.
John
Dear Lou,
NORWICH AIRPORT CONSULTATION
You may be aware that in its response to Norwich the LAA took the sponsor to task for inaccuracies in its consultation document that had the potential to mislead the majority of respondents. The department will be aware of these issues from its own analysis but I would just mention the principle areas of concern to us which were airport movements and traffic growth, military activity levels in East Anglia and the use of Airprox reports outside the subject airspace.
Significant inaccuracies in consultations seem to be becoming the norm recently and it is unreasonable to expect consultees, especially non-aviation consultees, to be able to identify these and find the correct data. In this case the LAA deployed a team of people with specialist and local knowledge to analyse the document and research all facts presented by the sponsor. This proved to be a substantial task made urgent by our magazine deadlines and the need to get an analysis out to our members in time for them to make an informed response on correct data. Most other respondents will not have had this support and the majority will have formed their view on what was presented.
The level of detailed work on this consultation is unsustainable for the LAA and we believe that sponsors should be able to audit their own material for accuracy before publication. We would then only have to draw our members’ attention to the sponsor’s documents without detailed narrative.
Perhaps we could discuss in the margins of the forthcoming NATMAC.
Yours Sincerely
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Bill Scott
- Posts: 137
- Joined: Sat Mar 28, 2009 6:25 pm
They got it !!!
Well, I'm absolutely disgusted. Despite exposing the inaccurate claims and showing that traffic (what there is of it) is declining, they got almost all of what they asked for.
I suspect that somebody at the CAA is covering his backside.
Click on link via this web page and scroll down to page 8 of the PDf doc for a graphical rendition of their CAS.
http://www.caa.co.uk/default.aspx?catid ... ageid=9326
How on earth anyone can justify CAS the size of Gatwick zone for this little tinpot outfit is beyond me.
The decision seems flawed, even perverse. I really do feel that we should respond in such a manner that will have to be taken into account at the 12 months revie stage.
I suspect that somebody at the CAA is covering his backside.
Click on link via this web page and scroll down to page 8 of the PDf doc for a graphical rendition of their CAS.
http://www.caa.co.uk/default.aspx?catid ... ageid=9326
How on earth anyone can justify CAS the size of Gatwick zone for this little tinpot outfit is beyond me.
The decision seems flawed, even perverse. I really do feel that we should respond in such a manner that will have to be taken into account at the 12 months revie stage.
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Tom Sheppard
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