Ladies and Gentlemen
The deadline for response to NATS proposal to establish a TMZ around Stansted is 17 Apr 09. We have asked NATS over and again to give us the safety data that supports their case but they will not give it to us. They have proposed reasonable mitigation for access to the areas at the ends of the runway but not the areas at the sides. Moreover we have been told that NATS has asked the CAA to charge for the services they will provide in this area.
Please see the notes and LAA response documents on the Consultation tab on the left sidebar and send in a response of your own.
You may be interested to know that AOPA has proposed that this area should be class D controlled airspace. I do not agree with that because access would be impossible (ever tried to get a word in edgeways on Essex radar?) and flights would have to be special VFR. Moreover the ANO requires that an aircraft landing or taking off at airfields within Class D must use the visibility reported by ATC. So if the Stansted vis is below 5km you cannot use any airfield under the controlled airspace.
Many thanks,
John Brady
STANSTED TMZ PROPOSAL
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Will Greenwood
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Jonathan Smith
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Re: STANSTED TMZ PROPOSAL
JohnJohn Brady wrote:Ladies and Gentlemen
The deadline for response to NATS proposal to establish a TMZ around Stansted is 17 Apr 09. We have asked NATS over and again to give us the safety data that supports their case but they will not give it to us. They have proposed reasonable mitigation for access to the areas at the ends of the runway but not the areas at the sides. Moreover we have been told that NATS has asked the CAA to charge for the services they will provide in this area.
John Brady
Do you now have the data you require?
Who told you that NATS wants to charge for access into the area?
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Jonathan Smith
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Imagine, for a minute, that you are an ATC service provider and during 2008 you had experienced 120 infringements of a piece of controlled supporting a busy international airport and in two of those incidents only providence prevented a mid-air collision. Add to this situation that those two most serious incidents and many of the other 120 incidents that the aircraft involved were not emitting altitude information which in the vast majority of circumstances would have mitigated the severity of the incident by the application of many safety nets. Would you not pursue the establishment of a TMZ around that airspace? Indeed would you not be negligent if you didn't pursue that measure?
Now add to that situation that during the first few weeks of 2009 the situation has dramatically worsened across the whole of your TMA. You are now experiencing even greater numbers of infringements than ever before including 3 or perhaps 4 incidents which again have came as close to a mid-air collision as you can get. What would go and ask the CAA to do?
IT IS TIME TO WAKE UP AND SMELL THE COFFEE - If we (and I include myself in this category as a GA pilot, an LAA member and a controller) don't accept that collectively we have become incapable of routinely executing a flight in the south-east of England without infringing controlled airspace and if we don't start supporting and implementing a range of measures to immediately remedy this situation we are going to experience the unthinkable for the GA community in this country and for the aviation industry as a whole - a mid-air collision between a light/sport aircraft and a passenger carrying airliner.
Now add to that situation that during the first few weeks of 2009 the situation has dramatically worsened across the whole of your TMA. You are now experiencing even greater numbers of infringements than ever before including 3 or perhaps 4 incidents which again have came as close to a mid-air collision as you can get. What would go and ask the CAA to do?
IT IS TIME TO WAKE UP AND SMELL THE COFFEE - If we (and I include myself in this category as a GA pilot, an LAA member and a controller) don't accept that collectively we have become incapable of routinely executing a flight in the south-east of England without infringing controlled airspace and if we don't start supporting and implementing a range of measures to immediately remedy this situation we are going to experience the unthinkable for the GA community in this country and for the aviation industry as a whole - a mid-air collision between a light/sport aircraft and a passenger carrying airliner.
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John Brady
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Hi Jonathan,
no but I have been told today that the data I asked for is not available. I asked for the 2008 incursion statistics for each of the 4 areas in the consultation broken down by risk catagory. I also asked for a definition of each catagory so we could understand what the numbers meant.
This has been very frustrating - nay exasperating! On Wednesday I cracked and gave NATS 24 hours notice that unless I had an answer by the end of Thursday I would complain formally to the CAA consultation co-ordinator on the basis of lack of transparancy. This I shall now do. Meanwhile I have had to put up a final draft response which is not at all what I personally wanted to say. At NATMAC last week I gave a short presentation on the way consultations seem to be going with basic information needed for analysis being kept from the "other airspace users" and the impact of changes on them not being addressed at all.
On charging, AOPA published an article about charging in their column in Pilot. We were given a tip-off on this a few months ago but have said nothing waiting for some public statement. It would be good if this was shown not to be the case.
John
no but I have been told today that the data I asked for is not available. I asked for the 2008 incursion statistics for each of the 4 areas in the consultation broken down by risk catagory. I also asked for a definition of each catagory so we could understand what the numbers meant.
This has been very frustrating - nay exasperating! On Wednesday I cracked and gave NATS 24 hours notice that unless I had an answer by the end of Thursday I would complain formally to the CAA consultation co-ordinator on the basis of lack of transparancy. This I shall now do. Meanwhile I have had to put up a final draft response which is not at all what I personally wanted to say. At NATMAC last week I gave a short presentation on the way consultations seem to be going with basic information needed for analysis being kept from the "other airspace users" and the impact of changes on them not being addressed at all.
On charging, AOPA published an article about charging in their column in Pilot. We were given a tip-off on this a few months ago but have said nothing waiting for some public statement. It would be good if this was shown not to be the case.
John
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Jonathan Smith
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John
If the consultation document had simply said that the Stansted controlled airspace experienced 120 infringements during 2008 and that 2 of those incidents were categorised as the most severe safety significant events in that only providence prevented a mid-air collision, would that have been the sort of data to persuade you and the membership?
Jonathan
If the consultation document had simply said that the Stansted controlled airspace experienced 120 infringements during 2008 and that 2 of those incidents were categorised as the most severe safety significant events in that only providence prevented a mid-air collision, would that have been the sort of data to persuade you and the membership?
Jonathan
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John Brady
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Thanks Jonathan,
the consultation does not say what you have said. It gives no numbers at all and NATS has chosen not to give them. I don't know why. You write about the need for TMZs in the whole of the south of England and because the consultation does not use any Stansted specific incursion figures, it also tends to suggest there should be TMZs under all controlled airspace.
However this consultation is not about that it is about about a change in 4 specific pieces of airspace. You have insider information that makes you believe this change should be approved. That information is not available to us although we have asked for it.
Although I want to support measures such as this, NATS seem to have gone out of their way to stop me understanding the issues. I have spent an inordinate amount of time trying to resolve this but I have now given up.
John
the consultation does not say what you have said. It gives no numbers at all and NATS has chosen not to give them. I don't know why. You write about the need for TMZs in the whole of the south of England and because the consultation does not use any Stansted specific incursion figures, it also tends to suggest there should be TMZs under all controlled airspace.
However this consultation is not about that it is about about a change in 4 specific pieces of airspace. You have insider information that makes you believe this change should be approved. That information is not available to us although we have asked for it.
Although I want to support measures such as this, NATS seem to have gone out of their way to stop me understanding the issues. I have spent an inordinate amount of time trying to resolve this but I have now given up.
John
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John Brady
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Very kind Ian thank you,
I should say that having flown Airbusses out of Stansted for some years and been a member of the Stansted flight ops committee until last year, I am absolutely in favour of airspace safety measures. I have lived in a very open safety culture where we were able to talk about issues, problems and mistakes without fear or favour or recrimination.
With my LAA airspace hat on I have to examine the case presented for all airspace changes and ensure there is good reason for the proposal and a proper balance for all airspace users. I rather expect that NATS and other ATS providers would also have an open safety culture but in this case they seem determined that we shall not find out what is actually going on in the airspace. Perhaps this is a function of Big Business - I don't know.
John
I should say that having flown Airbusses out of Stansted for some years and been a member of the Stansted flight ops committee until last year, I am absolutely in favour of airspace safety measures. I have lived in a very open safety culture where we were able to talk about issues, problems and mistakes without fear or favour or recrimination.
With my LAA airspace hat on I have to examine the case presented for all airspace changes and ensure there is good reason for the proposal and a proper balance for all airspace users. I rather expect that NATS and other ATS providers would also have an open safety culture but in this case they seem determined that we shall not find out what is actually going on in the airspace. Perhaps this is a function of Big Business - I don't know.
John
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Nigel Hitchman
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Jonathan,
I agree with you, something needs to be done to avoid these infringements.
However making aircraft flying outside of the current controlled airspace fit transponders isnt going to stop any infringements. It may allow ATC more visibility of aircraft on their radar, but nothing else. Unless ATC are actually talking to the particular aircraft who's transponder code they see is gonig to infringe, they cant do anything about it (but they can have a slightly better idea of what to do with any airliner it might be getting close to)
There are still infringements of LHR class A which is down to the surface and transponders required for any transit, so having transponders hasnt stopped that.
If ATC and the airlines really want these aircraft to fit transponders while flying in free airspace, why arent they doing anything constructive about it? Why isnt there some kind of airline/NATS fund out of which transponders can be purchased- oh no we cant have that, that would mean the benificieries of GA aircraft having transponders would have to pay for it, cant have that, NATS and Mr O'leary's profits would go down! Instead lets just make those people who we've already taken lots of airspace from and squeezed them into narrow corridors pay instead, doesnt help them , but if they dont pay they cant fly around here!
A better proposal from NATS would be to rationalise and modernise the controlled airspace, a bit like the small step Manchester have made. No longer do they need to protect climb outs of Boeing 707s or DC-6s on three engines doing 200fpm, or to cope with aircraft in the hold at 1500ft and then doing a big long teardrop procedural approach. Use todays aircraft performance on climbout, and the know procedure of radar vectors to the ILS with platform altitude 3000ft and no leaving that until on the glide (maybe needs to be lower on 05 due to other airspace not sure)
Then the low level controlled airspace can be much smaller and maybe better defined so easier to know that you are definitly outside. This would then result in far less infringements as there is less airspace to infringe.
I wonder why you say there have been more infringments in 2009, is this co-incident with the Farnborough supplied LARS service, more people thinking ATC will keep them out of trouble, rather than looking at the map and taking care for themselves.
It is also interesting reading the MOR reports (I think thats what it is) that come with GASIL. Although homebuilt and vintage aircraft are a sizeable proportion of the UK fleet, they hardly seem to figure in any airspace incursion reports, nearly all of the incursions seem to be Cessna 152/172, PA-28, Cirrus etc nearly all of this aircraft are club aircraft, or expensive private aircraft and presumably nearly all are fitted with transponders. Hardly any LAA type aircraft in these reports and no microlights (perhaps microlights arent reported in this document) So perhaps more effort should be made in training flying club pilots (not just students) maybe that would have the desired effect.
Thats not saying that LAA type aircraft pilots are immune or can relax, its just that they dont seem to make up much of the statistics.
Also Essex radar/Stansted have a reputation of not giving clearances to cross their airspace, whereas other class D such as Luton, EMA, Birmingham, Lyneham, Brize seem to be more accomodating. Thus perhaps people talk to them more or at least listen out. No point in talking or even listening to Essex/Stansted, if you can get a word in, they will always say no. Perhaps with a better allocation of controllers to airspace, people could get a word in, maybe some crossings could be given and ATC would have a better picture of what is going on, without everyone having to have transponders. Yes it might cost an extra controller, but ATC and the airlines should get the benefit, a small price for them to pay.
So in conclusion there is a lot that can be done to improve the situation, without having a TMZ.
I agree with you, something needs to be done to avoid these infringements.
However making aircraft flying outside of the current controlled airspace fit transponders isnt going to stop any infringements. It may allow ATC more visibility of aircraft on their radar, but nothing else. Unless ATC are actually talking to the particular aircraft who's transponder code they see is gonig to infringe, they cant do anything about it (but they can have a slightly better idea of what to do with any airliner it might be getting close to)
There are still infringements of LHR class A which is down to the surface and transponders required for any transit, so having transponders hasnt stopped that.
If ATC and the airlines really want these aircraft to fit transponders while flying in free airspace, why arent they doing anything constructive about it? Why isnt there some kind of airline/NATS fund out of which transponders can be purchased- oh no we cant have that, that would mean the benificieries of GA aircraft having transponders would have to pay for it, cant have that, NATS and Mr O'leary's profits would go down! Instead lets just make those people who we've already taken lots of airspace from and squeezed them into narrow corridors pay instead, doesnt help them , but if they dont pay they cant fly around here!
A better proposal from NATS would be to rationalise and modernise the controlled airspace, a bit like the small step Manchester have made. No longer do they need to protect climb outs of Boeing 707s or DC-6s on three engines doing 200fpm, or to cope with aircraft in the hold at 1500ft and then doing a big long teardrop procedural approach. Use todays aircraft performance on climbout, and the know procedure of radar vectors to the ILS with platform altitude 3000ft and no leaving that until on the glide (maybe needs to be lower on 05 due to other airspace not sure)
Then the low level controlled airspace can be much smaller and maybe better defined so easier to know that you are definitly outside. This would then result in far less infringements as there is less airspace to infringe.
I wonder why you say there have been more infringments in 2009, is this co-incident with the Farnborough supplied LARS service, more people thinking ATC will keep them out of trouble, rather than looking at the map and taking care for themselves.
It is also interesting reading the MOR reports (I think thats what it is) that come with GASIL. Although homebuilt and vintage aircraft are a sizeable proportion of the UK fleet, they hardly seem to figure in any airspace incursion reports, nearly all of the incursions seem to be Cessna 152/172, PA-28, Cirrus etc nearly all of this aircraft are club aircraft, or expensive private aircraft and presumably nearly all are fitted with transponders. Hardly any LAA type aircraft in these reports and no microlights (perhaps microlights arent reported in this document) So perhaps more effort should be made in training flying club pilots (not just students) maybe that would have the desired effect.
Thats not saying that LAA type aircraft pilots are immune or can relax, its just that they dont seem to make up much of the statistics.
Also Essex radar/Stansted have a reputation of not giving clearances to cross their airspace, whereas other class D such as Luton, EMA, Birmingham, Lyneham, Brize seem to be more accomodating. Thus perhaps people talk to them more or at least listen out. No point in talking or even listening to Essex/Stansted, if you can get a word in, they will always say no. Perhaps with a better allocation of controllers to airspace, people could get a word in, maybe some crossings could be given and ATC would have a better picture of what is going on, without everyone having to have transponders. Yes it might cost an extra controller, but ATC and the airlines should get the benefit, a small price for them to pay.
So in conclusion there is a lot that can be done to improve the situation, without having a TMZ.
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Mike Cross
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John has produced an excellent submission.
However no-one seems to have picked up the fact that the NATS "consultation" only offers three options. One of those is "do nothing" which I expect most pilots would see as not an acceptable answer.
The other two options are two different flavours of TMZ. No consideration has been given to the option of creating a known environment by extending the Class D down to ground level and providing a controller to manage the traffic within what is currently the Class G beneath the zone.
Now consider the option of making it Class D down to ground level versus the transponder option. Assume the airspace that forms the existing Class G is reserved for VFR traffic, i.e. VFR traffic is only cleared into the Class D below the existing lower limit and IFR is not cleared into the space below the existing lower limit.
1. You get a known environment.
2. Pilots have to obtain clearance to enter so the controller knows who they are and can give them a squawk if they are transponder equipped.
3. The clearance is "not above xxx ft" so the pilot is reminded of the vertical limits.
4. Businesses within the zone do not suffer finanacially due to non-transponder traffic being shut out.
If you go for the TMZ option
1. You do not have a known environment.
2. You have no flight strips for the traffic in Class G. You don't know who they are working if anyone.
3. You don't even know their callsign. (If you had a clever lookup of registration using the 24 bit hex address you could get it for that part of the traffic that is Mode S)
The difference between the two, and the possible reason why NATS do not even consider controlling the VFR as an option is that a TMZ costs NATS diddly squat while controlling VFR traffic would cost them.
As others have stated the purpose of CAS is to protect CAT. The imposition of CAS is for the benefit of CAT and CAT should therefore bear the costs involved in running the airspace.
Who owns NATS?
A consortium of airlines (the Airline Group) owns 42%
BAA (operators of Stansted) own 4%
NATS staff own 5%
Government owns the remaining 49%
Is it any surpise that the options offered in the consultation are limited to those that cost the owners of NATS the least money?
Class D is a long established and proven method of protecting CAT within the UK and the procedures used within it are well proven. A TMZ is not an established methodology within the UK.
Contrary to the impression being given by some a TMZ is not the only option, others should be considered before a decision is taken.
However no-one seems to have picked up the fact that the NATS "consultation" only offers three options. One of those is "do nothing" which I expect most pilots would see as not an acceptable answer.
The other two options are two different flavours of TMZ. No consideration has been given to the option of creating a known environment by extending the Class D down to ground level and providing a controller to manage the traffic within what is currently the Class G beneath the zone.
Now consider the option of making it Class D down to ground level versus the transponder option. Assume the airspace that forms the existing Class G is reserved for VFR traffic, i.e. VFR traffic is only cleared into the Class D below the existing lower limit and IFR is not cleared into the space below the existing lower limit.
1. You get a known environment.
2. Pilots have to obtain clearance to enter so the controller knows who they are and can give them a squawk if they are transponder equipped.
3. The clearance is "not above xxx ft" so the pilot is reminded of the vertical limits.
4. Businesses within the zone do not suffer finanacially due to non-transponder traffic being shut out.
If you go for the TMZ option
1. You do not have a known environment.
2. You have no flight strips for the traffic in Class G. You don't know who they are working if anyone.
3. You don't even know their callsign. (If you had a clever lookup of registration using the 24 bit hex address you could get it for that part of the traffic that is Mode S)
The difference between the two, and the possible reason why NATS do not even consider controlling the VFR as an option is that a TMZ costs NATS diddly squat while controlling VFR traffic would cost them.
As others have stated the purpose of CAS is to protect CAT. The imposition of CAS is for the benefit of CAT and CAT should therefore bear the costs involved in running the airspace.
Who owns NATS?
A consortium of airlines (the Airline Group) owns 42%
BAA (operators of Stansted) own 4%
NATS staff own 5%
Government owns the remaining 49%
Is it any surpise that the options offered in the consultation are limited to those that cost the owners of NATS the least money?
Class D is a long established and proven method of protecting CAT within the UK and the procedures used within it are well proven. A TMZ is not an established methodology within the UK.
Contrary to the impression being given by some a TMZ is not the only option, others should be considered before a decision is taken.
030881
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Nigel Hitchman
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Mike,
I can see what you are saying, and agree that really for ATC and the airlines a class D zone would be better than a TMZ, but cost more.
But it would then of course be another bit of class D, unnecessary for the airliner operations at Stanstead, that they would report infringements of! So although the infringements might be further away from the airliners, as there is more class D and thus less space in class G for us to pass through, there would be even more infringements!
If we could be guarneteed a bit of class D airspace in which we would always get a clearance to go where we want to including if we have no transponder, then that would be more acceptable to most (but still leaves a problem for non radio aircraft)
However, judging by the response you get when asking for clearance into the curent class D around that area, it would be unworkable. Forever excuses of cant do this and that due controller workload, people being told to stand by and avoid controlled airspace and taking so long to get back to them, they have already diverted around the area.
AS for the consultation, with the options they give, the only one acceptable is do nothing. While that may not be acceptable in terms of improving the situation, they will then have to come up with other proposals that actually do something to help resolve the problem. A TMZ is unacceptable and doesnt solve the problem.
I can see what you are saying, and agree that really for ATC and the airlines a class D zone would be better than a TMZ, but cost more.
But it would then of course be another bit of class D, unnecessary for the airliner operations at Stanstead, that they would report infringements of! So although the infringements might be further away from the airliners, as there is more class D and thus less space in class G for us to pass through, there would be even more infringements!
If we could be guarneteed a bit of class D airspace in which we would always get a clearance to go where we want to including if we have no transponder, then that would be more acceptable to most (but still leaves a problem for non radio aircraft)
However, judging by the response you get when asking for clearance into the curent class D around that area, it would be unworkable. Forever excuses of cant do this and that due controller workload, people being told to stand by and avoid controlled airspace and taking so long to get back to them, they have already diverted around the area.
AS for the consultation, with the options they give, the only one acceptable is do nothing. While that may not be acceptable in terms of improving the situation, they will then have to come up with other proposals that actually do something to help resolve the problem. A TMZ is unacceptable and doesnt solve the problem.
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Mike Cross
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Hi Nigel
I agree that it would need to be Class D with a whole new user experience, however by providing a controller specifically to handle what is currently the Class G below the zone, and keeping the IFR above the current lower limit:-
All the controller has to do is issue clearances and write flight strips. He has no responsibility for separation. (separation is not provided VFR/VFR in Class D).
He now knows who's who inside his airspace and can keep an eye on them. He can give squawks to those with transponders.
Clearances should therefore be routine, it's still see and avoid below the existing base.
I agree that it would need to be Class D with a whole new user experience, however by providing a controller specifically to handle what is currently the Class G below the zone, and keeping the IFR above the current lower limit:-
All the controller has to do is issue clearances and write flight strips. He has no responsibility for separation. (separation is not provided VFR/VFR in Class D).
He now knows who's who inside his airspace and can keep an eye on them. He can give squawks to those with transponders.
Clearances should therefore be routine, it's still see and avoid below the existing base.
030881
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iancallier
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- Location: hampshire
Historically how NATS have pushed their requests for more airspace, is to demand that an airfield requesting more airspace show that infringements are increasing. Then the airfield NATS ATC manager demands that every minor incursion , even the obvious half mile/180degree and out again is recorded.
These numbers (often irrelevent) are then used to demonstrate the HUGE number of infringements occuring.
Examples are: Teeside, Luton,Stansted and now Southampton.
John's request for incursions/areas is very important.
Class D airspace is not the answer-because each controller can only handle what he individually thinks he can cope with. And boy, oh boy some ATCOs are overloaded with one plane.
Think about how much it would cost to provide one ATCO to run Class D airspace 24 hours day. It needs 2 ATCOs on duty x 3 shifts, leave sickness, prgnancy -so say12 ATCOs to run the seat x £60,000- £120,000 per annum(virtually double the salary incurred).
NATS will run this nonsense for every piece of airspace in England - they have unlimited time and folk dreaming in offices!.
These numbers (often irrelevent) are then used to demonstrate the HUGE number of infringements occuring.
Examples are: Teeside, Luton,Stansted and now Southampton.
John's request for incursions/areas is very important.
Class D airspace is not the answer-because each controller can only handle what he individually thinks he can cope with. And boy, oh boy some ATCOs are overloaded with one plane.
Think about how much it would cost to provide one ATCO to run Class D airspace 24 hours day. It needs 2 ATCOs on duty x 3 shifts, leave sickness, prgnancy -so say12 ATCOs to run the seat x £60,000- £120,000 per annum(virtually double the salary incurred).
NATS will run this nonsense for every piece of airspace in England - they have unlimited time and folk dreaming in offices!.
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Jonathan Smith
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- Joined: Sat Mar 08, 2008 7:19 pm
MikeMike Cross wrote:Hi Nigel
I agree that it would need to be Class D with a whole new user experience, however by providing a controller specifically to handle what is currently the Class G below the zone, and keeping the IFR above the current lower limit:-
All the controller has to do is issue clearances and write flight strips. He has no responsibility for separation. (separation is not provided VFR/VFR in Class D).
He now knows who's who inside his airspace and can keep an eye on them. He can give squawks to those with transponders.
Clearances should therefore be routine, it's still see and avoid below the existing base.
All of the above would be achieved by Farnborough Radar providing access to a TMZ for non-equipped aircraft. Why would you burden suitably equipped aircraft and GA users in general with the additional onerous requirements of Class D airspace when the classification of airspace is simply not required?