House of Commons Transport Committee

The use of air space

Fifth Report of Session 2008–09

Report, together with formal minutes, oral and written evidence

Ordered by the House of Commons to be printed date 1 July 2009

HC 163 Published on 10 July 2009 by authority of the House of Commons London: The Stationery Office Limited £0.00

The Transport Committee

The Transport Committee is appointed by the House of Commons to examine the expenditure, administration and policy of the Department for Transport and its associated public bodies.

Current membership Mrs Louise Ellman MP (Labour/Co-operative, Liverpool Riverside) (Chairman) Mr David Clelland MP (Labour, Tyne Bridge) Mr Philip Hollobone MP (Conservative, Kettering) Mr John Leech MP (Liberal Democrat, Manchester, Withington) Mr Eric Martlew MP (Labour, Carlisle) Mark Pritchard MP (Conservative, The Wrekin) Ms Angela C Smith MP (Labour, Sheffield, Hillsborough) Sir Peter Soulsby MP (Labour, Leicester South) Graham Stringer MP (Labour, Manchester Blackley) Mr David Wilshire MP (Conservative, Spelthorne) Sammy Wilson MP (Democratic Unionist, East Antrim)

The following were also members of the Committee during the period covered by this report:

Clive Efford MP (Labour, Eltham) David Simpson MP (Democratic Unionist, Upper Bann)

Powers The Committee is one of the departmental select committees, the powers of which are set out in House of Commons Standing Orders, principally in SO No 152. These are available on the Internet via www.parliament.uk.

Publications The Reports and evidence of the Committee are published by The Stationery Office by Order of the House. All publications of the Committee (including press notices) are on the Internet at www.parliament.uk/transcom.

Committee staff The current staff of the Committee are Annette Toft (Clerk), Jyoti Chandola (Second Clerk), David Davies (Committee Specialist), Marek Kubala (Inquiry Manager), Alison Mara (Senior Committee Assistant), Jacqueline Cooksey (Committee Assistant), Stewart McIlvenna (Committee Support Assistant) and Hannah Pearce (Media Officer).

Contacts All correspondence should be addressed to the Clerk of the Transport Committee, House of Commons, 7 Millbank, London SW1P 3JA. The telephone number for general enquiries is 020 7219 6263; the Committee’s email address is [email protected]

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Contents

Report Page 1 Introduction 3 2 The management of 4 Current roles and responsibilities 4 Civil and military arrangements for use of airspace 6 Safety 7 3 Strategy, change and co-ordination in airspace management 8 Airspace Change Process 8 Presentation of options for airspace change 8 Establishing around 9 Airspace Master Plan 9 Joining up development and airspace planning 11 The third runway: airspace implications 12 New technologies and techniques 13 Precision Area Navigation (P–RNAV) 14 Continuous Descent Approaches 15 Communication by the CAA’s Directorate of Airspace Policy 16 4 Environmental impacts of airspace changes 17 Over-flying tranquil areas 17 Department for Transport’s environmental guidance to the CAA 18 5 European developments 20 Network management function 21 Extension of EASA’s safety responsibilities 22 SESAR 23 6 Conclusion 23

Conclusions and recommendations 25 The management of airspace 25 Strategy, change and co-ordination in airspace management 25 Environmental impacts of airspace changes 26 European developments 27

Formal Minutes 28 Witnesses 29 List of written evidence 30 List of Reports from the Committee during the current Parliament 32

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1 Introduction

1. The Government’s Future of Air Transport strategy aims to significantly increase UK airport capacity over the next two decades to accommodate the predicted growth in demand for air travel. New runways at Heathrow and Stansted airports are two of the key airport development proposals, first set out in the 2003 Future of Air Transport White Paper. If all the White Paper-supported airport development proposals came to fruition, current Government forecasts predict that the number of passengers passing through UK airports will increase from 241 million passengers a year in 2007 to 455 million passengers a year in 2030. This UK growth matches air traffic predictions for the whole continent. Eurocontrol, the European Organisation for the Safety of Air Navigation, predicts that European air traffic will double by 2020.

2. If rising demand for air travel is to be met effectively through additional airport capacity, a corresponding increase in airspace capacity must be realised. However, a country’s airspace—the portion of atmosphere above its territory and territorial waters, controlled by that country—is a finite resource. UK airspace, particularly in the South–East of England, is already some of the busiest and most complex to manage in the world. NATS (formerly National Air Traffic Services) handled nearly 2.5 million flights in 2007, with 1.4 million (up to 4,500 flights per day) handled over southern England. The interactions of flight routes serving a large number of airports within a relatively small geographical area in the South–East are a major limiting factor to increasing airspace capacity. Nearly doubling the number of air passengers flying by 2030 will almost certainly require improvements in the efficiency of the UK air traffic management system.

3. Accommodating the forecast growth in air traffic presents significant challenges for those organisations primarily responsible for managing UK airspace—the Civil Aviation Authority (CAA), the planner and regulator of UK airspace, and NATS, the monopoly provider of services to aircraft flying in UK airspace. The primary challenge is how to maintain the UK’s current high standards in air traffic management whilst the airspace over the UK and the rest of Europe becomes even busier over the coming decades. This will require greater co-ordination and shared practices. And, given the Government’s climate change commitments, and the requirements being placed on the aviation industry by the EU Emissions Trading Scheme, a further challenge is how we can improve flight efficiency, and thus reduce aircraft fuel burn. These challenges must be met without diminishing the commitment to high standards of safety.

4. Our inquiry aimed to shed light on how to meet these challenges. Our findings are aimed at those organisations responsible for airspace-related decisions in the UK: the CAA, NATS, and the Department for Transport. We examined what changes were required to airspace and air traffic management to accommodate the additional airport capacity outlined in the 2003 White Paper, and the progress to date in preparing for such necessary changes. We considered the safety implications of increased airspace utilisation, the current arrangements between civil, military and users, the opportunities to apply new technologies and techniques to improve efficiency and environmental performance, and the important developments occurring at European Union (EU) level to harmonise air traffic management across Europe.

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5. We recognise that the near-term future of the aviation industry remains uncertain. Passenger numbers and freight demand globally have declined in 2008 and in the first months of 2009. The International Air Transport Association has predicted that EU airlines will face a collective loss of $9 billion in 2009. Further uncertainty is added by the Competition Commission’s ruling that BAA Airports Ltd must sell three of its major UK airports. We examine these issues in our current inquiry on the Future of aviation which will report later in the year. In that inquiry, we will also address more general airport- related topics, such as the suggested Thames Estuary airport.

6. We are grateful to all those who provided written and oral evidence to our inquiry. We also wish to thank our specialist adviser Peter Brooker for his contribution.1 2 The management of airspace

Current roles and responsibilities 7. Several organisations have responsibility for UK airspace management and design. The Department for Transport is responsible for overall aviation policy, but has a minimal role in airspace policy. Its main airspace role relates to the setting of guidance and directions for the Civil Aviation Authority (CAA), the UK’s aviation regulator. The CAA, specifically its Directorate of Airspace Policy (DAP), is responsible for the planning and regulation of all UK airspace. Its overarching duty is to maintain a high standard of safety in the provision of air traffic services. This takes precedence over its other objectives, such as securing the most efficient use of airspace, satisfying the requirements of users of all aircraft (commercial aviation, military, and general aviation), and taking account of environmental objectives in line with Government guidance.

8. At the operational level, NATS (formerly National Air Traffic Services) is the monopoly provider of air traffic control services to aircraft flying in UK airspace, and over the north– east quadrant of the North Atlantic. A public-private partnership since 2001, NATS also provides air traffic control services on a commercial basis at 15 of the UK’s largest airports, including Heathrow and Gatwick. The Ministry of Defence provides air traffic control services for operational military aircraft.

9. European bodies also play an important role in the management of UK airspace. Although EU Member States hold sole responsibility for the design and management of their airspace, these activities are co-ordinated for 25 of the states under a co-operative agreement within Eurocontrol, the European Organisation for the Safety of Air Navigation. Moreover, since 2004, air traffic management has been brought under the EU common transport policy, which aims to lay down common rules applicable to international transport originating in, destined for, or passing through the territory of EU Member States.2 The European Commission is leading on the Single European Sky

1 Declared interests as of June 2009: (1) Employed by Helios Technology, consultancy. Holder of loan stock in the company. 2 Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, SEC(2008)2082.

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initiative, which aims to create a harmonised European air traffic management system by 2020.

10. The majority of our witnesses were complimentary about the competence and professionalism of both the CAA and NATS. The International Air Traffic Association (IATA) described the CAA as a “centre of expertise” that discharged its statutory responsibilities for safety “very efficiently”, and airlines commended the CAA’s professionalism.3 NATS was described by a US aerospace company as a “very progressive” air navigation service provider, focussed on improving both the operational utilisation of the air traffic management system and its own internal efficiency as an organisation.4 The Society of British Aerospace Companies said that NATS was doing “terrific work” to maintain high levels of safety within “saturated” UK airspace.5

11. Some suggested the relationship between the various organisations was too close. One environmental organisation told us there was a perception outside the aviation industry that a “revolving door” existed between the Department for Transport, the CAA, and NATS, and that the relationships between them were “damaging to public confidence in policy making”. It wanted responsibility for airspace decision-making to be placed in the hands of a body “completely independent of NATS and the aviation industry”, and suggested the Environment Agency’s role be extended to cover this.6

12. Other industry representatives, however, rejected this suggestion. IATA believed it was right that the CAA had responsibility for airspace decision-making: it noted that airspace policy was an extremely “specialised area” and the CAA had “built up a lot of expertise in managing and changing airspace”. Furthermore, establishing some kind of parallel decision-making process with the Environment Agency risked “complicating decision making”.7 A British Airways representative commented that environmental concerns were now high on the agenda right across the industry, so there was no rationale for the Environment Agency to be given such a responsibility.8 The Minister strongly denied the view that the relationship between the existing organisations was too close, and he was content to have these relationships publicly scrutinised in order to prove so. 9

13. Eurocontrol told us that the UK model for airspace management—with the CAA as regulator and NATS as service provider—had, in fact, been “an example for many [other European] states to follow”, and was therefore “very positive”.10 We agree with the majority of witnesses that the current general organisational structure of airspace management is entirely appropriate. It was clear from our evidence that most of the aviation industry did not support, or want, radical change in the current responsibilities for airspace management and decision-making.

3 Qq 213–214, 249. 4 Q 177 5 Q 198 6 Ev 182 7 Q 249 8 Q 249 9 Q 523 10 Q 285

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Civil and military arrangements for use of airspace 14. Airspace is shared by several different users who sometimes have diverging interests. One of the CAA’s objectives as airspace planner and regulator is to satisfy the requirements of users of all aircraft. As part of our inquiry, we examined whether the current balance between the civil and military users of airspace was fair and equitable. The ability to strike a fair and equitable balance will no doubt become increasingly difficult as demands on UK airspace increase over the coming decades.

15. We are pleased that most witnesses believed that the interface arrangements between military and civil use of airspace worked well. The Ministry of Defence was satisfied with the current arrangements and regarded its relationship with other stakeholders in the aviation community in a “very positive light”. It noted, however, that increased air travel over the period of the White Paper would inevitably “place stresses on airspace and on airspace structures”.11 NATS agreed that the interface arrangements were “extremely good”; in fact, they were “significantly better than elsewhere in Europe”. It stressed that the anticipated growth in air travel outlined in the Government’s White Paper would require “greater flexibility to accommodate civil flights during peak periods”.12

16. Airline and airport operator representatives told us that the arrangements were effective at the operational level but less so at the strategic level. The military was said to have precedence over commercial interests in some circumstances, simply as a result of historical or legacy factors.13 Birmingham International Airport noted that the size of the Royal Air Force had reduced significantly in recent decades without corresponding changes in airspace allocation. It questioned whether the allocation of military airspace remained appropriate.14 When questioned on this issue, the CAA acknowledged that fewer military aircraft were now in operation than in previous years. However, new, advanced military aircraft, such as the Eurofighter, required larger amounts of airspace to operate in compared to earlier models of military aircraft.15

17. The CAA told us it essentially had to perform a “balancing act” to satisfy the interests of the different users of airspace.16 To help achieve this balance, the authority’s Directorate of Airspace Policy (DAP) was staffed by experts from a wide range of operational aviation backgrounds, including commercial, business, recreational, and military aviation. We note, however, that the great majority of DAP Directors and Deputy Directors are current or ex- officers at the Ministry of Defence. We believe it should be an unambiguous objective of CAA staff planning that senior postholders within the Directorate of Airspace Policy represent the broad spectrum of operational expertise in a well-balanced manner.

11 Q 252 12 Ev 176 13 Ev 123; Ev 103 14 Q 404 15 Q 526 16 Q 53

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Safety 18. The UK has an excellent aviation safety record. It is clear from our inquiry that this record has been achieved by a team effort across the whole industry. A key airspace safety indicator is the annual number of Airproxes17 involving commercial air transport, which has shown welcome reductions over the last decade.18

19. Some witnesses were concerned that the busier skies forecast for the coming decades could have repercussions for safety. Chiltern Countryside Group said safety would be compromised if more aircraft movements were allowed in the “already over-crowded” airspace in the South–East.19 The Air Safety Group and the Parliamentary Advisory Council for Transport Safety (PACTS) were concerned about the increasing complexity of air traffic control, particularly that increased reliance on computer tools might pose problems in the event of a major system failure.20

20. We welcomed the assurances from NATS, the CAA and industry witnesses that safety was paramount and would not be compromised as airspace was increasingly utilised.21 The CAA said safety was its primary air navigation duty. It would “take any actions necessary” to ensure that safety was not compromised and that the high safety standards within UK airspace, and its supporting infrastructure, were maintained, with “potential risks identified and appropriate mitigating actions taken”.22 NATS believed that “improved procedures and new technology and air traffic control tools” would help to ensure airspace capacity increased safely over the coming decades.23 An aerospace company told us that safety was a paramount consideration for the aviation industry, because safety problems were inevitably bad for business.24

21. As part of the EU Single European Sky proposals, the European Aviation Safety Agency will have its remit extended to include the safety of air navigation services and air traffic management. We discuss this development in chapter 5 below.

22. Our evidence has demonstrated there is much to commend in the current management of UK airspace. We have been particularly impressed by the technical competence and professionalism of the CAA and NATS. We reject suggestions that responsibility for decision-making about airspace be placed in a different organisation. We see no apparent and significant benefits from such a transfer.

17 An Airprox is defined as a situation in which, in the opinion of a pilot or controller, the distance between aircraft as well as their relative positions and speed was such that the safety of the aircraft involved was, or may have been, compromised. 18 Civil Aviation Authority, CAP 780: Aviation Safety Review 2008, November 2008, Chapter 16, p 15 19 Ev 115 20 Ev 130 21 Qq 179–180; Ev 198; Ev 176 22 Ev 198 23 Ev 176; Q 348 24 Q 179

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3 Strategy, change and co-ordination in airspace management

23. Many witnesses were, on the whole, content with the current management of UK airspace. The main concerns we heard were rooted in a fear about the potential future impact of the Government’s White Paper plans (to almost double the number of air travel passengers by 2030) on our already busy skies, particularly in the South–East of England. We examined several aspects of airspace management likely to become increasingly pertinent within this context of long-term, major growth in air travel. These included airspace design and planning processes, co-ordination and communication, and new air traffic management technologies and techniques.

Airspace Change Process 24. Data on flight efficiency suggest that flights within Europe consume between 7–11% excess fuel, partly caused by indirect and non-optimal flight routeings.25 Changes to airspace design—for example, the redistribution of certain flight paths—are sometimes necessary to improve flight efficiency, to reduce delays, or to allow an increase in flights due to airport expansion. Such changes are usually proposed by air navigation service providers (most often NATS) or by airports themselves. It is estimated that changes made in January 2008 to the airspace structure linking the Midlands to the south of England will reduce flight delays, thus saving £68 million over eight years, and reduce annual CO₂ emissions by about 3% on those routes.26

Presentation of options for airspace change 25. A formal “Airspace Change Process”, including a consultation process, must be undertaken each time a proposal is made to change airspace. The CAA sets guidance on the process, specifying which information must be included in the proposal and who should be consulted. The CAA also makes the final decision on the airspace change proposal; it therefore holds ultimate responsibility for airspace changes.

26. The CAA’s Airspace Change Process guidance document—CAP 725—states that airspace change sponsors “should consider and assess more than one option” in their proposal.27 Some environmental bodies and local interest groups strongly criticised the recent Terminal Control North (TCN)28 airspace change consultation because the sponsor,

25 Eurocontrol Performance Review Commission, Vertical Flight Efficiency, March 2008

26 Although the exact amount of the CO₂ reduction is difficult to deduce using existing models and should therefore be treated with some caution. CAA Decision Letter, Changes to the existing airspace structure that links the Midlands to the South Coast, 29 January 2008. 27 Civil Aviation Authority, CAP 725: CAA Guidance on the Application of the Change Process, March 2007, Appendix B, p 7 28 The Terminal Control North area region is one of the most complex areas of airspace in the world, with routes in and out of a number of major airports including Heathrow, Stansted, Luton, and London City. The proposal is being designed to reflect the growth in air services over the past 15 years, as well as accommodating the forecast air traffic arising from general airport growth under the provisions of the Government’s 2003 White Paper.

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NATS, only offered one option for airspace change.29 The TCN region in the south of England covers a population of 12 million people, and the proposal was billed by NATS as “the biggest ever consultation on airspace change”.30 The lack of any alternative option presented by NATS was raised in the House.31 Following much criticism, NATS announced a second Terminal Control North consultation on revised proposals to redraw the aircraft route map in the TCN region in February 2009.

27. It is fundamental that those affected by airspace changes are presented with more than one option, assuming this is possible, during the consultation process. The CAA must encourage airspace change sponsors to follow the guidance requirement for more than one option to be presented, if possible.

Establishing controlled airspace around airports 28. Controlled airspace is essentially airspace in which aircraft receive an air traffic control service. Air traffic controllers endeavour to ensure that flights are on non-conflicting routes and they provide instructions to pilots when they see the possibility of a conflict. Above 19,500 ft (the area where international flying takes place) all airspace is controlled. Below 19,500 ft, approximately 40% of airspace is controlled.32 Military and general aviation largely operate outside controlled airspace, in uncontrolled, or ‘Class G’, airspace. means that an air traffic control service is not provided: it is predominantly a “see and avoid” environment.

29. General aviation representatives told us that NATS and the CAA often established excessive amounts of controlled airspace around airports. was said to have three times the controlled airspace of , despite handling only a third of the number of flights. Doncaster Airport had recently been awarded controlled airspace slightly larger than Gatwick but only had 2% of the number of flights handled at Gatwick.33 The Light Aircraft Association asserted that the CAA was out of line with continental European airspace designers in this respect; the equivalent German controlled airspace was said to be 40% narrower.34

30. The CAA and NATS should review the techniques used for designing controlled airspace around airports. The techniques used should match European and USA best practice standards to minimise the impact on general aviation, whilst ensuring safety and that current standards are not lowered.

Airspace Master Plan 31. The Government’s 2003 White Paper recognised that the additional airport capacity proposed “must be matched by a corresponding increase in airspace capacity”. The

29 Q 136 [2M Group]; Q 162 [Campaign to Protect Rural England] 30 “Biggest ever airspace consultation launched”, NATS press release, 21 March 2008. 31 21 May 2008, col 122WH 32 Q 526 [CAA] 33 Ev 247 34 Q 495

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Government therefore called for the CAA to “bring forward a structured programme for the redesign of UK airspace that would help to protect safety standards, relieve current constraints, take account of environmental impacts and accommodate the forecast increase in air transport movements where additional capacity was supported in the White Paper”.35

32. The majority of organisations submitting evidence to our inquiry believed some kind of “Airspace Master Plan” for the period of the White Paper (up to 2030) was necessary. Airlines, airport operators, and air traffic control representatives criticised the current “piecemeal” approach to airspace planning.36 Some witnesses were concerned, however, that a master plan could pre-empt the consultation process that currently occurs under the Airspace Change Process, each time there is a proposal to re-design airspace.37 Others agreed that it was unrealistic to plan for every possibility, due to the unpredictable nature of airport development planning.38

33. The CAA recently commissioned NATS, as the monopoly en-route service provider, to initiate a study into the future requirements for airspace, air traffic management and navigation policy for the busiest portions of UK airspace. This study, the Future Airspace Strategy (FAS), has the objective of setting out “a strategic plan for the reorganisation of the busiest portions of UK airspace out to 2025 so as to ensure safety, secure airspace efficiency and deliver the greatest degree of environmental mitigation, whilst ensuring cohesiveness with European strategies”.39 We were told that a project definition stage for the FAS had recently been launched.40

34. It is apparent from our evidence that many witnesses support the general principle of a long-term Airspace Master Plan, although its nature is not well understood. We believe that an Airspace Master Plan must be well-specified if it is to add real value and be a worthwhile endeavour. The objective of an Airspace Master Plan should be to maximise the efficiency of UK airspace, whilst meeting environmental constraints and taking account of stakeholder needs. The Master Plan should indicate those geographical areas within the UK where there would be significant difficulties designing airspace. In such instances, airspace design issues would be a much more important consideration in airport development proposals. An Airspace Master Plan should also cover the likely technological developments, including the impact of the Single European Sky. There needs to be clarity about what benefits an Airspace Master Plan would bring, in particular how such a plan would improve flight efficiencies and improve the effectiveness of the Airspace Change Process.

35. When the current project definition stage has been completed, the CAA should present its framework recommendations for a Future Airspace Strategy (FAS) to the Department for Transport and the industry. This work should explain the nature of the

35 Department for Transport, The Future of Air Transport, Cm 6046, December 2003, p 146; Department for Transport, The Future of Air Transport Progress Report, December 2006, Cm6977, p 42. 36 For example, British Airways [Ev 192, section 3], Manchester Airports Group [Ev 103, section 2.1], Guild of Air Traffic Control Officers [Ev 133] 37 General Aviation Alliance/Light Aircraft Association [Ev 247] 38 Air Safety Group/PACTS (Q 118); Redhill Aerodrome Limited [Ev 97] 39 Ev 198 40 Q 533

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FAS, the benefits to be achieved, how the strategy relates to airport development planning processes, and the impact of the strategy on the Airspace Change Process. It should describe the safeguards required to ensure that the FAS does not pre-empt the requirement for proper consultation on airspace change proposals.

36. Many witnesses criticised the length of time taken (since 2003) to make progress on an Airspace Master Plan. British Airways said there was “scant evidence to date of progress by the CAA in meeting this explicit remit from Government”.41 Airlines and airport operators were also concerned that they had not yet been consulted on the FAS work. The Airport Operators Association was concerned that, “as the representative body for UK airports”, it had not yet been invited to field any experts to contribute to this “much needed work”.42 Virgin Atlantic and British Airways also said they had not been contacted about the FAS work.43

37. We questioned the CAA about these criticisms. The CAA said that work on the FAS had in fact been taking place behind the scenes for some years. However, progress had been affected by the number of uncertainties that needed to be resolved due to their potential impact on UK airspace. These included the Government’s decision on a third runway at Heathrow and progress with the EU Single European Sky II and SESAR (Single European Sky ATM Research) initiatives. We were told that the FAS would take another two to three years to complete, and all major stakeholders would be consulted, perhaps later in 2009.44

38. The CAA could allay many concerns about the perceived slow progress in developing a long-term airspace strategy, and the lack of consultation to date on the FAS, through better communication with stakeholders. The CAA must improve its communication with key stakeholders about the ongoing work on the FAS and the likely timescales. It must ensure that stakeholders are properly consulted about the FAS when appropriate.

Joining up airport development and airspace planning 39. Several witnesses expressed concerns about the integration of the different aspects of the planning system. We were told that airport development proposals often did not adequately consider airspace implications.45 The Aviation Environment Federation wanted airspace management to be “brought forward in the planning process, if necessary, with outline permission being gained before further [airport] planning consideration is undertaken”.46 The Guild of Air Traffic Control Officers said it would “welcome the inclusion of the consideration of the potential impact on airspace and its management when airports are developing their master plans”.47

41 Ev 192 42 Ev 210 43 Q 227 44 Q 533 45 For example, the Aviation Environment Federation [Ev 163], Campaign to Protect Rural England [Q 167]. 46 Ev 163 47 Ev 133

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40. The Department for Transport aims to establish a suite of ‘National Policy Statements’ that will comprise “a statement for aviation, incorporating the [Future of Air Transport] White Paper”. Under the new system, the Infrastructure Planning Commission (IPC), established under the Planning Act 2008, will have primary responsibility for deciding on applications for the development of nationally significant infrastructure projects, such as airports. The Department says:

In submitting applications for airport development, a preliminary view will need to be taken of the various options for airspace configuration and capacity requirements. Those preliminary views will form part of the application and be subject to the necessary impact assessments. However, the detailed airspace design and subsequent consultation will depend on the nature of the airport development for which IPC consent is granted.48

NATS told us that airspace was just as important a part of the airport infrastructure as runways and ground access, and that it “must be factored in to consideration of airport expansion”. It warned, however that detailed airspace design was costly and could only be applied once a policy decision had been clarified.49

41. We believe that airspace impacts should be considered a vital part of airport development proposals. It is essential that National Policy Statements (NPSs) on the development of major airport infrastructure are based on advice from the CAA and NATS about the airspace implications of proposed developments. In the case of non- location specific NPSs, the NPS should include unambiguous guidelines to the Infrastructure Planning Commission on how to evaluate the airspace implications of any proposal. It is vital that the industry is well appraised of the methods used as well as the factors and information used by the Commission in making decisions on major airport developments.

The third runway: airspace implications 42. On 15 January 2009 the then Secretary of State for Transport, the Rt. Hon Geoff Hoon MP, announced that the Government’s three conditions for supporting a third runway at had been met.50 The Government therefore invited BAA, the owners of Heathrow, to bring forward proposals to build a third runway and a sixth terminal at Heathrow. We will examine the economic and environmental implications of the third runway at Heathrow as part of our Future of aviation inquiry. In this inquiry we focussed primarily on the airspace implications of a third runway, and particularly the opportunity it presented to reduce the amount of airborne holding, or “stacking”, around the airport.

43. Stacking—whereby aircraft are kept waiting in the air around the airport before air traffic control gives permission to land—currently occurs routinely around Heathrow Airport, largely because the airport operates at about 99% of its runway capacity.51 Stacking

48 Ev 21 49 Ev 176 50 HC Deb, 15 January 2009, col 355 51 Ev 176. Aircraft at Heathrow have an average holding period of ten minutes.

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also occurs at other UK airports, but not to the same extent as Heathrow. Excessive stacking can have both environmental and economic impacts. The Omega Academic Partnership—a partnership of nine UK universities focussing on the environmental issues facing aviation—said stacking was one of the main sources of flight inefficiency, and thus fuel burn and associated emissions.52 The Boeing Company told us that reducing excessive stacking could contribute to “less noise exposure under the flight path on approach”.53 Great Thurlow Parish Council described stacking as an “anti-social and unnecessary” practice, which resulted in a “notable decrease in quality of life for a concentrated few”.54 The CAA acknowledged that stacking was an “environmental issue”.55 We were told that the authority had recently carried out a study for the Department for Transport on resilience and the economic benefits of reducing time delays, including those caused by stacking.56

44. The additional capacity provided by a new runway at Heathrow would offer the possibility of reducing the number of aircraft stacking in the sky before landing. NATS said the third runway presented an opportunity to build additional resilience into the air traffic management system and reduce aircraft queuing; in NATS’ view, it was “vital” not to schedule to maximum capacity.57 The Director General of Civil Aviation at the Department for Transport agreed that the third runway offered “an opportunity for the airport to run more effectively and […] to reduce unnecessary stacking”. He was open to the possibility of setting targets to reduce excessive stacking around the airport, and suggested the CAA could play a role in setting and monitoring those targets.58 The CAA told us it was not part of its current remit to set and monitor such targets, but, if given the task, “it is the type of thing we could readily do”.59

45. Some “stacking” may be inevitable. But excessive stacking, such as frequently occurs at Heathrow, has negative environmental effects. A third runway at Heathrow Airport, if built, offers a real opportunity to add resilience into the air traffic management system and to help reduce excessive stacking. If a third runway is built at Heathrow, the Government should create a framework for setting targets to eliminate excessive stacking around the airport. The CAA should be given responsibility for setting and monitoring such targets. The targets should be included within the relevant National Policy Statement for the development.

New technologies and techniques 46. Air traffic management is based on core principles and technologies that have evolved only slowly in recent decades. The EU’s SESAR (Single European Sky Air Traffic Management Research) programme has ambitious aims to modernise European air traffic

52 Ev 218 53 Ev 175 54 Ev 139 55 Q 41 56 Q 520 57 Q 354; Ev 176 58 Qq 519–520 59 Q 522

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management technologies and techniques (see chapter 5), but it remains a long-term goal. We examined what opportunities existed in the nearer-term to apply new technologies and techniques within the UK, in order to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land—both of which contribute to flights within Europe consuming some 7–11% excess fuel.60

47. Witnesses told us that the application of new technologies and air traffic management techniques would become increasingly important over the coming years, as the need for additional capacity and improved fuel-efficiency increased. BAA Airports Ltd said that the implementation of new technologies was “essential rather than desirable […] at a time when the industry is becoming seriously affected by global economic instability”.61 British Airways told us there were “many opportunities available to reduce waste and inefficiency across the air traffic control system”.62 The Boeing Company agreed that there was “scope for improving the operational performance of the UK’s airspace”, and believed that “much of the technology that can deliver improvements is in existence today”. “Continuing the status quo” would “result in greater fuel burn than theoretically necessary, with a direct increase in emissions”.63 It is clear that the development and application of new technologies and air traffic management techniques are integral to improving flight efficiency, thus reducing excessive fuel burn, and increasing airspace capacity.

48. We focus on two specific examples below: Precision Area Navigation and Continuous Descent Approaches.

Precision Area Navigation (P–RNAV) 49. Precision Area Navigation, known as P-RNAV, is a method that uses satellite navigation, ground-based aids, and on-board electronic systems to allow aircraft to self- navigate on any desired path. It differs from traditional, less flexible navigational practices whereby aircraft determine their position using ground-based beacons. P-RNAV can improve the flight efficiency of aircraft, for example by reducing the distances of aircraft, and can enable the use of best practice techniques, such as Continuous Descent Approaches (CDAs), with subsequent environmental benefits. P-RNAV and CDAs are valuable in their own right, but are also precursors for longer-term SESAR operational concepts.

50. Industry witnesses, academics, environmental organisations and European organisations all strongly supported greater use of P-RNAV technology. Virgin Atlantic Airways said P-RNAV could deliver “significant benefits” in terms of safety and additional capacity.64 The Guild of Air Traffic Control Officers said P-RNAV, by enabling routes to be spaced closer together, improved the efficiency of the airspace and could increase capacity.65

60 Eurocontrol Performance Review Commission, Vertical Flight Efficiency, March 2008 61 Ev 235 62 Ev 192 63 Ev 175 64 Ev 123 65 Ev 133

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51. Modern commercial aircraft are usually fitted with P-RNAV capability, but we heard from airlines that the full benefits of the technology were not being utilised. British Airways said we had been “slow to take full advantage” of existing technology and wanted a roll-out of P-RNAV procedures to be “accelerated” with “much greater emphasis” placed on promoting the technology.66 Part of the problem was said to be that older aircraft were not equipped with the technology, which meant that airspace was still primarily designed in a traditional way. Eurocontrol told us it was “not efficient” if only some aircraft had P- RNAV capability.

52. The Department for Transport and the CAA highlighted that current airspace change proposals under development would seek to promulgate technologies such as P-RNAV.67 Despite this, the CAA does not appear to have offered clear statements to the industry and public about its broader P-RNAV strategy for the UK. In evidence to us, the CAA recognised that P-RNAV offered “tremendous benefits”, but said it was still too early to understand the full extent of those benefits. Asked about a timescale for implementing some of those benefits, the CAA was non-specific, suggesting it could perhaps be “something like a five-year period”.68

53. We have heard very wide support for Precision Area Navigation (P-RNAV), but a great deal of uncertainty remains amongst industry parties about the actual plans and commitments for the widespread introduction of this technology in the UK. The CAA should produce a strategy for P-RNAV within 12 months.

Continuous Descent Approaches 54. Aircraft have traditionally descended towards their destination in a series of steps, largely due to inherent airspace restrictions. This approach is not ideal from the perspective of either noise or fuel burn, and thus emissions. A Continuous Descent Approach (CDA) involves an aircraft descending towards an airport in a gradual, uninterrupted approach with the engine power cut back.

55. Currently, CDAs are agreed by the air traffic controllers and pilots on a flight-by-flight basis, according to weather and traffic conditions. Their use in the UK is well-established; in fact, they have been used extensively in the UK for certain airports such as Heathrow for several years. Practice varies, however, both between airports and also between airlines.69 For example, British Airways’ CDA performance at Heathrow Airport in 2007 was 95%, compared to the airport average of 83%.70 Heathrow Airport was achieving an average of 70% CDAs 30 years ago.71

66 Qq 240, 242 67 NATS has confirmed it will propose P–RNAV routeings in a second Terminal Control North (TCN) airspace change consultation. 68 Qq 548–550 69 Ev 217 70 British Airways, Corporate Responsibility Report 2007–08, p 10 71 CAA Paper 78006, The Noise Benefits Associated with Use of Continuous Descent Approach and Low Power / Low Drag Approach Procedures at Heathrow Airport.

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56. Many witnesses, including airport operators, aerospace companies and academics, emphasised the fuel and noise reduction benefits that could be gained from employing CDA landings and advocated the adoption of this approach. The Society of British Aerospace Companies (SBAC) said CDAs resulted in average reduced fuel burn and emissions of 100 kg of fuel and 315 kg of CO₂ per flight, compared to a conventional approach, and markedly less noise exposure for communities under the early descent of the flight path. The Society noted, however, that CDA utilisation was “often limited by air traffic management resource, airspace capability or pilot uptake”.72 P-RVAV technology was also said to facilitate a higher proportion of CDA landings.

57. There is currently noticeable variation between airports and between airlines in the take-up of Continuous Descent Approaches (CDA). It is necessary to improve airports’ performance in the use of CDA landings so that the best practice standard is adhered to as near to universally as is achievable. The Civil Aviation Authority must adopt a more active role in encouraging the industry to adopt CDA. The CAA should monitor the CDA performance of major airports and airlines, publish statistics, and promote practices and changes that lead to greater utilisation of CDA.

Communication by the CAA’s Directorate of Airspace Policy 58. Our inquiry revealed several areas of “dissonance” between the perceptions of airlines, airport operators, and other stakeholders on one hand and the official line given by the CAA on the other. These include concerns from the industry about the work underway for the Future Airspace Strategy (see para. 36), uncertainties about the implementation of Precision Area Navigation (P–RNAV, see para. 51), and the general aviation community’s concerns about Mode S Transponder plans. With regards to the Future Airspace Strategy, the CAA said “the time was simply not right to engage with external stakeholders” because the proposals were at too early a stage.73 We believe better communication by the CAA with its stakeholders could have helped to address some of the concerns we heard during our inquiry.

59. We believe that many concerns from industry stakeholder could be alleviated by improved communication on the part of the CAA. The CAA should review its communication strategy in DAP (Directorate of Airspace Policy) to ensure that policy and technical matters are communicated in a timely and effective manner to all stakeholders.

72 Ev 160 73 Q 533

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4 Environmental impacts of airspace changes

60. The environmental impact of aviation is currently a very high-profile issue. It is estimated that aviation contributed 6.3% of total UK CO₂ emissions in 2005, and the Government forecasts this proportion will grow to between 24% to 49% by 2050.74 The Climate Change Act set legally binding targets to reduce CO₂ emissions by at least 26% by 2020 and 80% by 2050. In January 2009, the then Secretary of State for Transport, the Rt Hon Geoff Hoon MP, announced that aviation emissions in 2050 should be below 2005 levels. From 2012, aviation will also be brought under the EU Emissions Trading Scheme. Emissions from airlines flying from and within the EU will initially be capped at 97% of average 2004–06 annual emissions, but this will tighten to 95% of average 2004–06 emissions from 2013.

61. We examine the broader environmental impacts of aviation in our Future of aviation inquiry. As part of this inquiry, we considered the environmental impacts of airspace changes, particularly the emissions and noise impacts of creating new flight paths or modifying existing ones, and how best to balance those impacts.

Over-flying tranquil areas 62. Several witnesses were concerned about new routeings and marked traffic growth over- flying tranquil areas. Shropshire County Council said the CAA’s West End Area Airspace Changes, implemented in March 2006, had resulted in a 21% overall increase in air traffic flying over the Shropshire Hills Area of Outstanding Natural Beauty.75 Similarly, the Campaign for National Parks strongly criticised the CAA’s Terminal Control South West decision in January 2008, which redirected flight paths over parts of the New Forest National Park.76 It was generally accepted that there was a paucity of quality research about tranquillity and the effects of aircraft on tranquil areas.77

63. The CAA said it endeavoured to avoid aircraft over-flying Areas of Outstanding Natural Beauty, in line with current guidance. However, the guidance also necessitated the CAA to make a “balanced judgement” of all the various environmental impacts, when deciding airspace changes.78

64. Tranquillity is a key factor in sensitive areas such as National Parks and Areas of Outstanding Natural Beauty. Current guidance appears to allow unchequed increases in aviation activity over these areas. Without some level of constraint, the noise environment in these areas might degrade progressively as traffic increases.

74 With no radiative forcing factor. Department for Transport, UK Air Passenger Demand and CO₂ Forecasts, January 2009, p 60, p 173. 75 Ev 107 76 Ev 94 77 For example, Shropshire County Council [Ev 107], Natural England [Ev 128], National Trust [Ev 140]. 78 Qq 529–530

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65. The DfT and the CAA should examine the case for adopting maximum limits on noise levels and numbers of aircraft permitted per hour over sensitive areas such as National Parks and Areas of Outstanding Natural Beauty. The DfT should fund exploratory research on evidence-based limits.

Department for Transport’s environmental guidance to the CAA 66. Environmental guidance set by the Department for Transport in 2002—Guidance to the CAA on the Environmental Objectives Relating to the Exercise of its Air Navigation Functions—sets a framework within which the CAA must operate when making decisions on airspace change proposals. The 19-page document states that the CAA must consider “the need to reduce, control and mitigate the environmental impacts of civil aircraft operations”, in particular aircraft noise and emissions. However, the guidance is largely discursive in nature: it does not provide a clear Governmental policy view about priorities in airspace design, other than safety being paramount. The guidance has also not been updated since 2002, despite climate change having risen up the Government’s agenda considerably in recent years. Thus, it does not take account of major shifts in Government thinking such as the Stern Review on climate change (2006) and the Eddington Transport Study (2006).79

67. Several witnesses criticised the environmental guidance as lacking clarity, especially in terms of determining the priorities of different environmental impacts such as noise and emissions. NATS argued for “greater clarity […] in […] environmental policy on matters such as concentration/dispersal of noise and the relative importance of noise and emissions; this in turn will enable clearer guidelines provided by the CAA for airspace design and future airspace rule-making”.80 The Guild of Air Traffic Control Officers said the existing guidance was “woolly”. It wanted “more prescriptive guidance” because currently there was no “clear guidance when you are designing and developing the airspace as to what environmental criteria you are meant to be adhering to”.81 The Aviation Environment Federation said:

You have got different constituents out there and the community will always be interested in noise. Increasingly, the Government will be interested in the emissions side, and the inclusion of aviation into the Emissions Trading Scheme will make sure that airlines will be saying to NATS, “Design us a system that gives us the most efficient routes in and out”, but you have got to try and reconcile that. […] I think that the CAA and NATS taking that value judgment about which to prioritise over the other is inappropriate. It is exactly why we argue that you have to have “sophisticated” guidance.82

68. We recommended, in our 2006 Report on The work of the CAA, that the Government amend its 2002 environmental guidance to give the CAA and others better information

79 The Eddington Transport Study noted that emissions from the transport sector were a significant and growing contributor to the UK’s overall greenhouse gas emissions, and said it was essential that the environmental impacts of transport were fully reflected in decision-making. 80 Ev 176, Summary 81 Q 122 82 Q 173

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about how to balance different environmental factors.83 The Pilling Strategic Review of the CAA, reporting in July 2008, made similar recommendations.84

69. The Department for Transport told us it was currently re-examining the 2002 guidance, following the findings of the Pilling Review.85 The Minister acknowledged that concerns about CO₂ emissions were “much more prominent” now compared to even a couple of years ago.86 The CAA said that the new guidance would have to include any relevant findings from the Stern or Eddington reports. However, it warned that the guidance was intended to be of a general nature, and there was no such thing as a “perfect formula” for the Directorate of Airspace Policy to apply. It said different environmental considerations had to be considered in different locations throughout the UK.87

70. The CAA is not an elected body and it would be inappropriate for the authority to be the final arbiter of decisions or decision-making criteria, regarding airspace design changes that have significant environmental impacts. The CAA should be basing its decisions on clear principles set out by Government on its environmental priorities, to enable the authority to better make the difficult decisions where the advantages of direct flight routeings and noise impacts have to be balanced against one another. The Department for Transport (DfT) should issue up-to-date Environmental Guidance to the CAA before the end of the year. The guidance should represent current Government thinking on CO₂ and other emissions in relation to transport decision-making. The guidance must be clear about the basic policy principles by which the Government expects the CAA to make its airspace assessments.

71. The CAA’s own airspace change guidance document, CAP 725, is partly based on the existing DfT environmental guidance.88 The process set out in CAP 725 has to be followed by those organisations proposing airspace changes, usually air traffic service providers or airports. CAP 725 is described as a “living document” subject to occasional revision.89 The environmental requirements set out in the document are out-of-date regarding key Government policy reports, such as Stern and Eddington, despite CAP 725 last being revised in March 2007. We asked the CAA whether it was satisfied that its airspace policy documents reflected current Government policy. The CAA said the documents “reflect Government policy as given to us through the [Department’s] environmental guidance”.90

72. Once the DfT has issued new environmental guidance to the CAA, the CAA must produce clear and comprehensive new guidance on airspace change for the industry. The CAA should adopt a regular review cycle to update the environmental material in the document.

83 Thirteenth Report of Session 2005–06, HC 809, para 157. 84 Sir Joseph Pilling, Report of the Strategic Review of the CAA, p 40. 85 Qq 532, 535. 86 Q 539 87 Qq 537, 540. 88 Appendix B of the document, “Airspace Change Proposal—Environmental Requirements”. See also CAA evidence [Ev 198] 89 NATS [Ev 176] 90 Q 541

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5 European developments

73. Airspace over Europe is highly fragmented, having developed largely around state geographic borders and boundaries. International flights currently have to pass through national air traffic zones or “blocks”, before being handed over from one national authority to another. For example, passenger aircraft travelling between Brussels and Rome must pass through nine different air traffic control zones. This system leads to bottlenecks and delays, forcing aircraft to consume more fuel and jeopardising safety. As a consequence, flights in Europe are on average 49 kilometres longer than needed. The European Commission estimates that the fragmentation of Europe's airspace costs €1 billion each year and that shorter, direct routes could save five million tonnes of CO₂ annually. 91

74. Important developments are taking place at the European level to create a more rational organisation of European airspace and additional capacity, whilst maintaining high safety standards. The European Commission’s Single European Sky (SES) initiative, adopted in 2004, brought air traffic management (ATM) under the EU common transport policy, which sets common rules applicable to international transport originating in, destined for, or travelling within, the territory of Member States. SES aims to create, by 2020, an ATM system designed, managed and regulated in a harmonised way. The new European ATM system is intended to sustain European aviation from an ATM viewpoint for the subsequent 30 to 40 years.92 A second package, the Single European Sky II (SES II), was published by the European Commission in June 2008, which placed greater emphasis on the potential environmental benefits to be gained through modernising the European ATM system. The package was adopted by the European Parliament in March 2009. SESAR (Single European ATM Research) is the industry-led research and technology programme accompanying the SES legislation.

75. The SES initiative received almost uniform support from witnesses submitting evidence to our inquiry. It was hoped the initiative would deliver increased capacity and environmental benefits.93 The Department for Transport confirmed to us that it “strongly supported” the SES initiative.94

76. An important SES development to date has been the creation of the UK–Ireland “Functional Airspace Block” (FAB), implemented in July 2008, which has rationalised existing airspace arrangements between the two countries. Under the 2004 SES legislation, Member States are required to establish FABs, across national boundaries, by the end of 2012. The intention is to deliver operational efficiencies across national boundaries by developing more fuel-efficient routes, improving delays and enhancing safety. The UK is also a “co-operative partner” in the development of the proposed FAB Europe Central, involving the airspace of France, , the , Belgium, Luxembourg and Switzerland—one of the highest traffic density areas in the world.

91 “EU seeks to end fragmentation of European airspace”, EUbusiness, 26 June 2008. Quote by EU Transport Commissioner Antonio Tajani. 92 CAA [Ev 198] 93 For example, Virgin Atlantic Airways [Ev 123], Aviation Environment Federation [Ev 163], Air safety Group/PACTS [Ev 130]. 94 Q 508

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77. We support the principles of the Single European Sky (SES) initiative to create a more rational organisation of European airspace, for example by establishing cross- border Functional Airspace Blocks. It is unacceptable that, on such a crowded continent, airspace is still largely managed in isolation based on national borders. Greater harmonisation of air traffic management practices at the European level would lead to improvements in efficiency, environmental performance, and capacity. However, it is essential that NATS and the CAA remain at the very forefront of SES developments over the coming decade. Their world-class expertise in air traffic management services are second to none in Europe. It is essential that the UK’s high standards are the benchmark to which the SES initiative aspires and delivers.

78. We also require assurances from the Government about certain aspects of the SES initiative.

Network management function 79. A key component of the Single European Sky II (SES II) proposals is the establishment of a “network management function”. It is intended that the function’s main tasks will include:

• ensuring local design solutions are consistent with European network efficiency requirements and that all airspace users can fly optimal trajectories;

• optimising the use of scarce resources (such as frequencies and transponder codes) through a centralised inventory of these resources, with a view to sometimes overcoming conflicting local solutions;

• traffic flow management, slot co-ordination and allocation—to allocate slots as a function of the “required time of arrival” to improve the predictability of operations; and

• management of the deployment of SESAR technologies and the procurement of Europe-wide infrastructure elements.95

Eurocontrol is expected to take on these roles.

80. One of our concerns was that the proposed network management function may have the power to overrule recommendations made by national regulators, such as the CAA. When questioned on this matter, the Director of Air Transport of the European Commission’s Directorate-General for Energy & Transport told us that discussions had not yet reached this level of detail. However, he did not believe that the network management function would be able to overrule national authorities. He told us that the network manager had “functions of co-ordination” but not “decision-making powers in relation to the national authorities”.96 Similarly, the CAA emphasised that the proposed arrangements were strongly focussed on “collaboration and partnership”, and there would

95 Ev 237 96 Q 307

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be “no infringement” on the vital prerogatives of the UK regulatory system.97 NATS believed that the rule-making framework within the EU meant it would be “highly unlikely we would end up in a conflict where we were forced to do something that we did not think was appropriate”.98 The Minister believed there was “no threat to UK sovereignty within the framework that is being established”.99

81. We accept that a more rationalised European airspace requires a co-ordinating body. It is important to remember, however, that airspace is still subject to national sovereignty. The onus of the network management function should be to work closely with national airspace authorities to ensure they are aware of the wider implications of airspace en-route changes.

82. The Government must be explicit that the focus of the European network management function should be on co-operation, in order to improve efficiency across European airspace. The function should not have the power to overrule recommendations from the national regulator. Such recommendations are firmly based on consultation arrangements with people affected by flight paths.

Extension of EASA’s safety responsibilities 83. The Single European Sky II (SES II) package also includes the objective of establishing a single safety framework for Europe, centred on the European Aviation Safety Agency (EASA), tasked with improving safety levels alongside the increase in air traffic. EASA, established in 2003, has responsibility for setting the regulations and standards for the airworthiness of aircraft, air operations and flight crew licensing. In March 2009, the European Parliament adopted an amending Regulation to extend EASA’s remit to the safety of aerodromes, air navigation services and air traffic management. This means EASA will now establish harmonised rules on air traffic management systems and air navigation services.100 The UK Government supported the legislative proposal.

84. In our October 2006 report on The Work of the CAA, we strongly criticised EASA. We said the fledgling organisation was in a “chaotic state” and “an accident waiting to happen”.101

85. When giving evidence to this inquiry, both the Minister and the CAA said they were satisfied that the UK’s high safety standards would not be compromised by the extension to EASA’s remit. The Minister acknowledged our previous criticisms of EASA, but said the organisation had improved considerably in recent years. The CAA highlighted that one of

97 Q 545 98 Q 346 99 Q 544 100 European Parliament legislative resolution of 25 March 2009 on the proposal for a regulation of the European Parliament and of the Council amending Regulation (EC) No 216/2008 in the field of aerodromes, air traffic management and air navigation services and repealing Council Directive 2006/23/EC (COM(2008)0390 – C6-0251/2008 – 2008/0128(COD). 101 Thirteenth Report of Session 2005–06, HC 809

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the priorities was to ensure EASA obtained the necessary resources to carry out its new functions effectively.102

86. The Committee welcomes the statements made by the Minister and the CAA that the performance by the European Aviation Safety Agency (EASA) has improved. However, the Committee remains concerned that the extension of EASA’s remit may lead to a decline in safety standards and requests the Government and the CAA provide six-monthly reports on progress to this Committee.

SESAR 87. SESAR (Single European Sky Air Traffic Management Research) is the accompanying technology programme of the Single European Sky (SES) legislation. It is a joint European project, mainly industry-led, with the aim of re-engineering the European air traffic management network to become more efficient, better integrated, more cost-efficient and safer. The overall cost of the SESAR programme, set to be implemented in 2016, is estimated at €30 billion (approximately £26 billion)103, most of which will be spent on the implementation of new technologies.104

88. The Ministry of Defence’s Assistant Chief of Air Staff said he had “some questions about the degree of resources” to be invested in the SESAR project. According to 2007 data, the capital contribution of European military users to SESAR amounts to €11.7 billion, most of which is investment into equipment.105 The Assistant Chief also said there would be additional costs for airspace users in the longer-term to adopt the technologies, once it had been developed. He said it would be “a challenge for me and quite likely my successors to ensure that those resources are made available from the Ministry of Defence”.106

89. The CAA should lead work to establish the broad costs and benefits of SESAR for each of the different sections of the UK aviation industry. It should also set out how it intends to improve the phasing of projects within SESAR so as to maximise the benefits to aviation stakeholders most cost-effectively. 6 Conclusion

90. Our inquiry demonstrated that there is much to commend in the current management of UK airspace. The CAA has a global reputation as a respected airspace planner and regulator. NATS is recognised as one of the world’s leading, and most progressive, air navigation service providers. The UK’s airspace safety record is excellent. And, whilst we heard about some of the conflicting demands for the use of airspace, many witnesses affirmed that the current arrangements between civil, military, general and business aviation worked well. Given that the UK has some of the world’s busiest airspace, these

102 Q 547 103 Oanda exchange rate, 1 July 2009 104 “SESAR chief: Airlines ‘key’ to modernising EU airspace” [Interview], Euractiv.com, 25 February 2009, euractiv.com 105 SESAR Consortium , The ATM Target Concept, September 2007, p 74. 106 Q 277

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achievements must be applauded. Our report aims to build on this strong position through further improvements, such as better communication and consultation with stakeholders.

91. Despite the recent decline in passenger numbers, most industry forecasters believe that demand for air travel will eventually recover to former levels and continue to grow. Indeed, the Government has reiterated its view that its long-term forecasts up to 2030 remain broadly valid. The primary challenge in airspace management is how to maintain the current high standards whilst our and our neighbours’ airspace become even busier over the coming decades and the need for co-ordination and shared practices increases. And, given the Government’s climate change commitments, and the requirements being placed on the aviation industry by the EU Emissions Trading Scheme, the second challenge is how we improve flight efficiency, and thus reduce aircraft fuel burn. These significant challenges must be met, with the top priority always being high standards of safety.

92. Our inquiry highlighted some areas on which to focus over the coming years. Several industry witnesses told us that the development of a strategic “Airspace Master Plan” could offer real benefits in improving the process of UK airspace design. We hope that the Future Airspace Strategy, currently being developed, will facilitate a more systematic and integrated approach to airspace planning in the UK. Proper consultation with stakeholders on the development of the strategy is essential, and should occur sooner rather than later.

93. Efficiency and environmental improvements can also be gained from increased promulgation of new technologies, such as Precision Area Navigation (P–RNAV), and improved air traffic control techniques, such as Continuous Descent Approaches (CDAs). We believe there needs to be a more pro-active, concerted and focussed drive to ensure that the benefits of new technologies and best practice techniques are achieved. And, with more flights forecast in UK airspace, it is crucial to improve the efficiency of the air traffic management system so that Government and the aviation industry meet their respective greenhouse gas requirements. A first step is for the Government to issue revised environmental guidance to the CAA, reflecting current Government thinking on CO₂ and other emissions, and to set out the basic policy principles to which the CAA should adhere when making its airspace design assessments. The Government and CAA must work to ensure that environmental assessments for airspace change proposals use reliable evidence- based criteria.

94. The changes we mention above could largely be made within the next two or three years. But, for the longer-term, the UK’s ability to meet the White Paper growth forecasts will depend on the success of the Single European Sky (SES) initiatives. There will be improvements in the structure of European airspace and new technologies will be developed and implemented, through the SESAR (Single European Sky Air Traffic Management Research) programme. These should have a major impact on the ability of UK and neighbouring airspace to accommodate future growth safely, efficiently, and with minimum environmental impact. It is essential that the UK continue with its leading role within the SES initiatives and SESAR projects to help ensure the delivery of their potential capacity and efficiency benefits over the coming decade.

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Conclusions and recommendations

The management of airspace 1. Our evidence has demonstrated there is much to commend in the current management of UK airspace. We have been particularly impressed by the technical competence and professionalism of the CAA and NATS. We reject suggestions that responsibility for decision-making about airspace be placed in a different organisation. We see no apparent and significant benefits from such a transfer. (Paragraph 22)

Strategy, change and co-ordination in airspace management 2. It is fundamental that those affected by airspace changes are presented with more than one option, assuming this is possible, during the consultation process. The CAA must encourage airspace change sponsors to follow the guidance requirement for more than one option to be presented, if possible. (Paragraph 27)

3. The CAA and NATS should review the techniques used for designing controlled airspace around airports. The techniques used should match European and USA best practice standards to minimise the impact on general aviation, whilst ensuring safety and that current standards are not lowered. (Paragraph 30)

4. There needs to be clarity about what benefits an Airspace Master Plan would bring, in particular how such a plan would improve flight efficiencies and improve the effectiveness of the Airspace Change Process. (Paragraph 34)

5. When the current project definition stage has been completed, the CAA should present its framework recommendations for a Future Airspace Strategy (FAS) to the Department for Transport and the industry. This work should explain the nature of the FAS, the benefits to be achieved, how the strategy relates to airport development planning processes, and the impact of the strategy on the Airspace Change Process. It should describe the safeguards required to ensure that the FAS does not pre-empt the requirement for proper consultation on airspace change proposals. (Paragraph 35)

6. The CAA could allay many concerns about the perceived slow progress in developing a long-term airspace strategy, and the lack of consultation to date on the FAS, through better communication with stakeholders. The CAA must improve its communication with key stakeholders about the ongoing work on the FAS and the likely timescales. It must ensure that stakeholders are properly consulted about the FAS when appropriate. (Paragraph 38)

7. We believe that airspace impacts should be considered a vital part of airport development proposals. It is essential that National Policy Statements (NPSs) on the development of major airport infrastructure are based on advice from the CAA and NATS about the airspace implications of proposed developments. In the case of non-location specific NPSs, the NPS should include unambiguous guidelines to the

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Infrastructure Planning Commission on how to evaluate the airspace implications of any proposal. It is vital that the industry is well appraised of the methods used as well as the factors and information used by the Commission in making decisions on major airport developments. (Paragraph 41)

8. Some “stacking” may be inevitable. But excessive stacking, such as frequently occurs at Heathrow, has negative environmental effects. A third runway at Heathrow Airport, if built, offers a real opportunity to add resilience into the air traffic management system and to help reduce excessive stacking. If a third runway is built at Heathrow, the Government should create a framework for setting targets to eliminate excessive stacking around the airport. The CAA should be given responsibility for setting and monitoring such targets. The targets should be included within the relevant National Policy Statement for the development. (Paragraph 45)

9. It is clear that the development and application of new technologies and air traffic management techniques are integral to improving flight efficiency, thus reducing excessive fuel burn, and increasing airspace capacity. (Paragraph 47)

10. We have heard very wide support for Precision Area Navigation (P-RNAV), but a great deal of uncertainty remains amongst industry parties about the actual plans and commitments for the widespread introduction of this technology in the UK. The CAA should produce a strategy for P-RNAV within 12 months. (Paragraph 53)

11. There is currently noticeable variation between airports and between airlines in the take-up of Continuous Descent Approaches (CDA). It is necessary to improve airports’ performance in the use of CDA landings so that the best practice standard is adhered to as near to universally as is achievable. The Civil Aviation Authority must adopt a more active role in encouraging the industry to adopt CDA. The CAA should monitor the CDA performance of major airports and airlines, publish statistics, and promote practices and changes that lead to greater utilisation of CDA. (Paragraph 57)

12. We believe that many concerns from industry stakeholder could be alleviated by improved communication on the part of the CAA. The CAA should review its communication strategy in DAP (Directorate of Airspace Policy) to ensure that policy and technical matters are communicated in a timely and effective manner to all stakeholders. (Paragraph 59)

Environmental impacts of airspace changes 13. Tranquillity is a key factor in sensitive areas such as National Parks and Areas of Outstanding Natural Beauty. Current guidance appears to allow unchequed increases in aviation activity over these areas. Without some level of constraint, the noise environment in these areas might degrade progressively as traffic increases. (Paragraph 64)

14. The DfT and the CAA should examine the case for adopting maximum limits on noise levels and numbers of aircraft permitted per hour over sensitive areas such as National Parks and Areas of Outstanding Natural Beauty. The DfT should fund exploratory research on evidence-based limits. (Paragraph 65)

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15. The Department for Transport (DfT) should issue up-to-date Environmental Guidance to the CAA before the end of the year. The guidance should represent current Government thinking on CO₂ and other emissions in relation to transport decision-making. The guidance must be clear about the basic policy principles by which the Government expects the CAA to make its airspace assessments. (Paragraph 70)

16. Once the DfT has issued new environmental guidance to the CAA, the CAA must produce clear and comprehensive new guidance on airspace change for the industry. The CAA should adopt a regular review cycle to update the environmental material in the document. (Paragraph 72)

European developments 17. We support the principles of the Single European Sky (SES) initiative to create a more rational organisation of European airspace, for example by establishing cross- border Functional Airspace Blocks. It is unacceptable that, on such a crowded continent, airspace is still largely managed in isolation based on national borders. Greater harmonisation of air traffic management practices at the European level would lead to improvements in efficiency, environmental performance, and capacity. However, it is essential that NATS and the CAA remain at the very forefront of SES developments over the coming decade. Their world-class expertise in air traffic management services are second to none in Europe. It is essential that the UK’s high standards are the benchmark to which the SES initiative aspires and delivers. (Paragraph 77)

18. The Government must be explicit that the focus of the European network management function should be on co-operation, in order to improve efficiency across European airspace. The function should not have the power to overrule recommendations from the national regulator. Such recommendations are firmly based on consultation arrangements with people affected by flight paths. (Paragraph 82)

19. The Committee welcomes the statements made by the Minister and the CAA that the performance by the European Aviation Safety Agency (EASA) has improved. However, the Committee remains concerned that the extension of EASA’s remit may lead to a decline in safety standards and requests the Government and the CAA provide six-monthly reports on progress to this Committee. (Paragraph 86)

20. The CAA should lead work to establish the broad costs and benefits of SESAR for each of the different sections of the UK aviation industry. It should also set out how it intends to improve the phasing of projects within SESAR so as to maximise the benefits to aviation stakeholders most cost-effectively. (Paragraph 89)

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Formal Minutes

Wednesday 1 July 2009

Members present:

Mrs Louise Ellman, in the Chair

Mr David Clelland Mark Pritchard Mr Philip Hollobone Ms. Angela C. Smith Mr John Leech Graham Stringer Mr Eric Martlew Mr David Wilshire

Draft Report (The use of airspace), proposed by the Chairman, brought up and read.

Ordered, That the draft Report be read a second time, paragraph by paragraph.

Paragraphs 1 to 94 read and agreed to.

Resolved, That the Report be the Fifth Report of the Committee to the House.

Ordered, That the Chairman make the Report to the House.

Ordered, That embargoed copies of the Report be made available, in accordance with the provisions of standing Order No. 134.

Written evidence was ordered to be reported to the House for printing with the Report.

[Adjourned till Wednesday 8 July at 2.30 pm.

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Witnesses

Wednesday 21 January 2009 Page

Sir Roy McNulty, Chairman, and Mr John Arscott, Director, Airspace Ev 1 Policy, Civil Aviation Authority

Mr Roger Gardner, Chief Executive, Professor Ian Poll, Cranfield Ev 9 University, Dr Rod Self, Southampton University, and Dr Tom Reynolds, Cambridge University, Omega Academic Partnership

Mr Rob Marshall, President and Chief Executive Officer, Mr Mark Green, Ev 14 Vice President, Policy, Guild of Air Traffic Control Officers (GATCO), Mr Andrew du Boulay, ATM Portfolio Holder for the Air Safety Group, and Mr Rob Gifford, Executive Director, Parliamentary Advisory Council for Transport Safety, Air Safety Group & Parliamentary Advisory Council for Transport Safety

Wednesday 25 February 2009

Mr Tim Johnson, Director, and Ms Laura Simpson, Policy Coordinator, Ev 18 Aviation Environment Federation; Mr Lawrence Wragg, Chairman of Aviation Advisory Group, and Mr Michael Nidd, Technical Adviser to Aviation Advisory Group, Campaign to Protect Rural England; Mr Colin Stanbury, Aviation Adviser, and Councillor Serge Lourie, Leader, London Borough of Richmond upon Thames, 2M Group

Mr Christian Dumas, Head of Sustainable Development and Eco- Ev 24 efficiency, Airbus; Mr Kevin Brown, Vice President and General Manager of Air Traffic Management, The Boeing Company; and Mr Bruno Esposito, Director of Civil Air Transport, Society of British Aerospace Companies (SBAC)

Wednesday 4 March 2009

Captain Dean Plumb, Manager Technical Developments, British Airways, Ev 31 Mr Geoff Clark, Head of Flight Operations Regulatory Affairs, Virgin Atlantic Airways, and Mr Gerry O’Connell, Assistant Director, Safety Operations and Infrastructure, Europe, International Air Transport Association

Air Vice-Marshal Tim Anderson, Assistant Chief of the Air Staff, and Air Ev 40 Commodore Mark Wordley, Director, Defence Airspace and Air Traffic Management, Ministry of Defence

30

Wednesday 18 March 2009

Mr Daniel Calleja-Crespo, Director of Air Transport and Mr Sven Halle, Ev 46 ATM Expert, Directorate-General for Energy and Transport, European Commission; Mr Alex Hendriks, CND Deputy Director for Network Development and Mr Bernard Miaillier, CND Deputy Director for SESAR, Eurocontrol

Mr Ian Hall, Director of Operations, Mr Alex Bristol, General Manager Ev 57 Operational Strategy and Investment, and Mr Lee Boulton, Manager Airspace Delivery, NATS

Wednesday 1 April 2009

Mr Tom Needham, Head of Operations Policy, Airport Operators Ev 64 Association, Mr Tim Hardy, Airside Director, BAA Airport Limited, Mr Paul Kehoe, Chief Executive Officer, Birmingham International Airport Ltd, Mr Richard Gooding, Chief Executive, London City Airport, and Mr Simon Butterworth, Head of Airfield Strategy and Compliance, Manchester Airports Group

Mr Paul Draper, Secretary, General Aviation Alliance; Mr Guy Lachlan, Ev 74 Chief Executive, British Business and General Aviation Association; and Mr John Brady, Vice-Chairman, Light Aircraft Association

Wednesday 22 April 2009

Jim Fitzpatrick MP, Parliamentary Under Secretary of State, Mr Jonathan Ev 81 Moor, Director General of Civil Aviation, and Mr John Parkinson, Head of Airports Policy Division, Department for Transport; Sir Roy McNulty, Chairman, and Mr Mark Swan, Director Airspace Policy, Civil Aviation Authority

List of written evidence

1 Campaign for National Parks Ev 94 2 Mike Andrews and John Sargent Ev 96 3 Little Thurlow Parish Council Ev 96 4 Redhill Aerodrome Limited (RAL) Ev 97 5 Gatwick Area Conservation Campaign Ev 101 6 Manchester Airports Group plc Ev 103 7 Shropshire County Council Ev 107 8 Ministry of Defence (MoD) Ev 108 9 Chiltern Countryside Group Ev 115

31

10 Marilyn M Fletcher BSc PhD Ev 118 11 Ashmansworth Parish Council Ev 122 12 Virgin Atlantic Airways Ltd Ev 123 13 Save our Peace and Quiet (SOPAQ) Ev 126 14 Natural England Ev 128 15 Air Safety Group (ASG) and the Parliamentary Advisory Ev 130 Council for Transport Safety (PACTS) 16 Guild of Air Traffic Control Officers (GATCO) Ev 133 17 The 2M Group Ev 138 18 Great Thurlow Parish Council Ev 139 19 National Trust Ev 140 20 New Forest National Park Authority Ev 144 21 Department for Transport (DfT) Ev 147, 152 22 Chilterns Conservation Board Ev 152 23 International Air Transport Association Ev 157 24 Society of British Aerospace Companies Ev 160 25 Aviation Environment Federation Ev 163, 166 26 Stop Stansted Expansion Ev 169 27 Strategic Aviation Special Interest Group Ev 173 28 The Boeing Company Ev 175 29 National Air Traffic Service (NATS) Ev 176, 181 30 Campaign to Protect Rural England (CPRE) Ev 182, 185, 187 31 London City Airport Ev 188 32 British Airways plc (BA) Ev 192 33 Civil Aviation Authority (CAA) Ev 198, 208, 209 34 Mrs Alastair Robinson, Suffolk Ev 208 35 M I Rushton, Cambridgeshire Ev 210 36 Airport Operators Association (AOA) Ev 210, 216, 217 37 Omega Academic Partnership of UK Universities Ev 218 38 Elizabeth M Balsom Ev 222 39 EUROCONTROL Ev 225 40 British Microlight Aircraft Association Ev 228 41 General Aviation Safety Council (GASCo) Ev 229 42 Airbus UK Ev 230 43 British Parachute Association (BPA) Ev 233 44 BAA Airports Ltd Ev 235 45 European Commission Ev 236, 237 46 British Gliding Association (BGA) Ev 238 47 Birmingham International Airport Ev 245 48 General Aviation Alliance (GAA) and the Light Aircraft Ev 247 Association (LAA) 49 British Business & General Aviation Association Ev 254

32

List of Reports from the Committee during the current Parliament

The reference number of the Government’s response to each Report is printed in brackets after the HC printing number.

Session 2008–09 First Report Work of the Committee in 2007–08 HC 211 Second Report School Travel HC 351 (HC 561) Third Report Appointment of the Chair of the Office of Rail HC 433 Regulation Fourth Report The Effects of Adverse Weather Conditions on HC 328 Travel Fifth Report The Use of Airspace HC 163

Session 2007–08 First Report Galileo: Recent Developments HC 53 (HC 283) Second Report The London Underground and the Public-Private HC 45 (HC 461) Partnership Agreements Third Report Work of the Committee in 2007 HC 248 Fourth Report The future of BAA HC 119 (HC 569) Fifth Report Ticketing and Concessionary Travel on Public HC 84 (HC 708) Transport Sixth Report The Blue Badge Scheme HC 475 (HC 1106) Seventh Report Department for Transport Annual Report 2007 HC 313 (HC 1102) Eighth Report Freight Transport HC 249 (HC 1103) Ninth Report The Draft Marine Navigation Bill HC 709 (HC 1104) Tenth Report Delivering a sustainable railway: a 30-year HC 219 (HC 1105) strategy for the railways? Eleventh Report Ending the Scandal of Complacency: Road Safety HC 460 (HC 136 & HC 422) beyond 2010 Twelfth Report The opening of Heathrow Terminal 5 HC 543

Session 2006–07 First Report Work of the Committee in 2005–06 HC 226 Second Report The Ports Industry in England and Wales HC 6I-I & 61-II (HC 954) Third Report Transport for the London 2012 Olympic and HC 199 (HC 484) Paralympic Games: The Draft Transport Plan Fourth Report Department for Transport Annual Report 2006 HC 95 (HC 485) Fifth Report The Government’s Motorcycling Strategy HC 264 (HC 698) Sixth Report The new National Boatmasters’ Licence HC 320-I & 320-II (HC 1050) Seventh Report Novice Drivers HC 355-I & 355-II (HC 1051) Eighth Report Passengers’ Experiences of Air Travel HC 435-I & 435-II (HC 1052) Ninth Report The draft Local Transport Bill and the Transport HC 692-I & 692-II (HC 1053) Innovation Fund

33

Session 2005–06 First Report UK Transport Security – preliminary report HC 637 Second Report Financial Protection for Air Travellers: Second HC 636 (HC 996) Report Abandoning Effective Protection Third Report Going for Gold: Transport for London’s 2012 HC 588-I & 588-II (HC 1152) Olympic Games Fourth Report Departmental Annual Report 2005 HC 684 (HC 1517) Fifth Report Future of the British Transport Police HC 1070-I & 1070-II (HC 1639) Sixth Report How fair are the fares? Train fares and ticketing HC 700-1 & 700-II (HC 1640) Seventh Report Parking Policy and Enforcement HC 748-I & 748-II (HC 1641) Eighth Report Piracy HC 1026 (HC 1690) Ninth Report The work of the Department for Transport's HC 907 (HC 1615) Agencies – Driver and Vehicle Operator Group and the Highways Agency Tenth Report Roads Policing and Technology: Getting the HC 975 (HC 290) right balance Eleventh Report Bus Services across the UK HC 1317 (HC 298) Twelfth Report Local Transport Planning and Funding HC 1120 (HC 334) Thirteenth Report The work of the Civil Aviation Authority HC 809 (HC 371) Fourteenth Report Passenger Rail Franchising HC 1354 (HC 265) First Special Report The Performance of the London Underground: HC 431 Government Response to the Committee’s Sixth Report of Session 2004–05 Second Special The Departmental Annual Report 2004: HC 432 Report Government Response to the Committee’s Fourth Report of Session 2004–05 Third Special Report Integrated Transport: the Future of Light Rail HC 526 and Modern Trams in the UK: Government Response to the Committee’s Tenth Report of session 2004–05 Fourth Special Search and Rescue: Government Response to the HC 586 Report Committee’s Eighth Report of Session 2004–05 Fifth Special Report Rural Railways: Government Response to the HC 587 Committee’s Fifth Report of Session 2004–05 Sixth Special Report Tonnage Tax: Government Response to the HC 611 Committee’s Second Report of Session 2004–05 Seventh Special Financial Protection for Air Travellers: HC 639 Report Government and Civil Aviation Authority Responses to the Committee’s Fifteenth Report of Session 2003–04 Eighth Special European Community Competence and HC 976 Report Transport: Government Response to the Committee's Ninth Report of Session 2004–05

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Transport Committee: Evidence Ev 1 Oral evidence

Taken before the Transport Committee

on Wednesday 21 January 2009

Members present

Mrs Louise Ellman, in the Chair

Mr Philip Hollobone Graham Stringer Mark Pritchard Mr David Wilshire Ms Angela C Smith Sammy Wilson

Witnesses: Sir Roy McNulty, Chairman, and Mr John Arscott, Director, Airspace Policy, Civil Aviation Authority, gave evidence.

Chairman: Good afternoon, gentlemen. Welcome to obviously particularly looking at the airspace our Committee. Do Members have any interests to capacity that will be needed in the south east of the declare? UK. Graham Stringer: I am a member of Unite. Q5 Chairman: How complex would you say UK Q1 Chairman: Louise Ellman, member of Unite and airspace is at the moment? co-chair of PACTS. Could I ask our witnesses to Mr Arscott: It is arguably one of the most complex in introduce themselves and their organisation, please, the world. It is certainly one of the more complicated for our records? in Europe but that is not across the whole Sir Roy McNulty: I am Roy McNulty. I am the of the United Kingdom. Essentially, that would chairman of the Civil Aviation Authority. apply to the south east of the UK. There are parts of Mr Arscott: I am John Arscott. I am the director of UK airspace which are relatively straightforward, airspace policy in the CAA. but there are competing demands from all airspace users in all parts of the UK. It is just that they are Q2 Chairman: What do you currently consider to be easier to solve in some parts of the airspace than in the most pressing issues relating to air traYc others. management and the use of airspace? What would you see as your top priorities to be dealing with? Q6 Chairman: What would the impact of the third Mr Arscott: At the moment clearly the economic runway be on airspace? crisis is something which focuses our attention. Mr Arscott: NATS would have to bring forward Europe is another dimension which we watch proposals as the air navigation service provider for carefully. The environmental issues associated with a redesign of essentially the London TMA and, as a aviation are clearly high on our agenda. Technology consequence, probably most of the airspace in the presents in part some solutions but needs to be south east of the UK. They recognise this; we focused. Certainly of late the government’s decision recognise that. It will be a significant task. We would on Heathrow has focused our attention in the seek to cover all of that in what we have called the airspace area and similarly of course we are working future airspace strategy, which is an initiative which with the recommendation of Sir Joseph Pilling’s we have jointly taken with NATS and government, strategic review of the CAA and how we might to develop for the timescale of the Air Transport implement those recommendations. White Paper—2030, an airspace arrangement for the south east which will be compatible with the demand Q3 Chairman: What do you see as the main that we expect at that time. challenges for the CAA in relation to these issues? Y Mr Arscott: Meeting demand in a safe and e cient Q7 Chairman: You gave us written evidence in manner. October and at that time you were supporting the long term growth forecasts in the White Paper, Q4 Chairman: What would you say is the most looking at growth in air travel and growth in the pressing priority and which are the more longer number of passengers. Do you still remain of that term ones? view? Mr Arscott: Safety is the most important thing that Sir Roy McNulty: We in the CAA do not we have as an obligation and clearly that is front, independently do long term traYc forecasts and centre of what we do. Seeking to ensure that ourselves. We rely on the forecasts that the when the economic climate turns up we are prepared Department for Transport makes. My to support the return to flying to the same levels as understanding is that their current forecast is a bit previously is one of our greatest challenges and lower than what they forecast in 2003, but it is not Processed: 06-07-2009 18:36:56 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG1

Ev 2 Transport Committee: Evidence

21 January 2009 Sir Roy McNulty and Mr John Arscott radically lower. Certainly they are forecasting traYc in Europe. We work very closely with the for 2030 very much higher than the traYc levels that Department for Transport and to date I would say we have today. we have been successful in getting agreed outcomes across Europe which do not threaten the standards Q8 Chairman: You feel confident that, despite the that we have here. Looking ahead on Single economic circumstances now, the growth will still European Sky, it is a major challenge in one sense. A be there? lot of change, both organisationally, institutionally Sir Roy McNulty: I think that is the most reasonable and in terms of regulation and technology, is basis on which to plan. We have had 30 years’ envisaged. That will be a challenge to do experience that shows how traYc grows as economic successfully, but it is very important that it is growth goes in parallel. I do not think we should be successful because, in terms of dealing with future planning on the basis that this recession is going to traYc growth, coordination and working together in be our permanent condition. I think we have to plan Europe is fundamentally necessary. in the expectation that some degree of economic prosperity and growth will return. That being so, we Q12 Mr Wilshire: But you will be keeping as close an need to cater and plan ahead to have the capacity to Y eye on mark two as you did on mark one to make deal with increased tra c. sure we are not being asked to reduce our standards? Sir Roy McNulty: I think we will keep an even closer Q9 Chairman: Is this a hope or is it based on eye on mark two because the risks are greater. To anything substantial? that extent, it requires greater attention, greater Sir Roy McNulty: That, to me, is the most realistic thought and more hard work from everybody. scenario to plan on based on all the experience we have had to date. Q13 Mr Wilshire: You said in reply to my first Q10 Chairman: You mentioned the Pilling Report. question that you knew of no evidence that the first One of the recommendations there was that you version had caused any lowering in standards. I should have more specific responsibility for assume that you have looked very, very hard for environmental issues. Do you think that would be evidence and failed to find it rather than it just helpful and when are you expecting to hear more having passed over your desk? about that? Sir Roy McNulty: We look in great detail—some Sir Roy McNulty: We do think it would be helpful. people would say to the point of tedium—at every I think it recognises today’s realities and priorities. element of what is put on the table as proposals, both We are currently in discussion with the Department from EASA and from the Single European Sky. We for Transport around that area and we would expect, satisfy ourselves that there is nothing in it that will during the next few months, to reach some be harmful to UK interests, both in terms of safety Y conclusions on what that environmental duty should standards, in terms of the e ciency of our system look like. Obviously in recent times we have had a lot and so on. of discussion with them around the Heathrow subject, but I think a broader environmental duty Q14 Mr Wilshire: With mark two, where if anywhere would make sense to us and probably makes sense to are there going to be concerns? What are the issues the Department for Transport. we ought to focus on to ensure that our standards stay as high as they are? Q11 Mr Wilshire: I want to see if I can resist the Sir Roy McNulty: With Single Sky mark two, temptation to get involved in Heathrow at the perhaps there are two I would highlight. One is moment. I think that is a matter for NATS. If I dealing with the institutional complexity in Europe. remember rightly,Sir Roy,last time you were here on As I am sure you are well aware, there are many, the report that we did on you, we got onto the subject many diVerent bodies involved. Getting them all to of the Single European Sky and we ended up having head in one direction simultaneously is quite a some concerns. We discussed with you that there was challenge, bearing in mind there are 27 diVerent a danger, if we were not careful, of levelling down countries that have to make the same changes at the standards rather than levelling up. That was our same time to make this programme eVective. That is view, not yours. I am not trying to put words in your one big challenge. The second big challenge relates mouth. We now have proposals for the future. Could to technological innovation. Within the Single Sky you tell us whether some of the fears of the past that two programme is SESAR, which is a major step you and others have expressed have come about? forward to the next generation of air traYc control Y Have there been di culties with single European systems. We believe that is a necessary step but, as we skies mark one? Will mark two that is now being know ourselves the hard way, major steps forward in consulted on solve any of those problems and make technology are not without risk and usually not some improvements? without pain. I think that will require a great deal of Sir Roy McNulty: To date we have seen no evidence attention. that standards get levelled down. That relates both to the Single European Sky and to EASA, the European Aviation Safety Agency. There is a risk Q15 Mr Wilshire: Having talked for a moment or that that could happen. We work extremely hard and two about the safety issues of the Single European we are putting a lot of time into dialogue with people Sky, can I ask about availability? Will mark two Processed: 06-07-2009 18:36:56 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG1

Transport Committee: Evidence Ev 3

21 January 2009 Sir Roy McNulty and Mr John Arscott make it easier or more diYcult for us to get a good Mr Arscott: At the moment, the statutory duty allocation of available airspace? Is it going to intrude which the CAA has for the performance of its air upon our ability to allocate our own space? navigation functions talks about, in addition to Mr Arscott: No. I think it is important to make the safety, securing the eYcient use of airspace and diVerentiation between the EASA safety activity meeting the needs of airspace users, but only taking which is in one part of the Commission and the account of the environmental impact of aviation. Single Sky arrangements which are in a diVerent Many would argue that that is not the right balance part. An important component of the Single Sky two for the current regime and that we should have a package will be a performance regime with targets stronger remit to take account of and mitigate the set at a European level. The whole purpose of that is eVects of aviation than we currently have. That is the to try to ensure that state arrangements do not stand reason we support Sir Joseph’s recommendation in the way of European eYciency. The Performance that we should have a statutory duty, but it is quite Review Commission of Eurocontrol, of which I am clear that the context of that statutory duty has to be a member, is focused on producing a performance within a clear policy framework and needs to not package for endorsement and enforcement by the conflict with the other statutory duties that we might Commission which will, I am fairly confident, make have. That is quite a big ask for government and it the passage of aircraft across Europe more is essential that we are given that statutory duty straightforward and reduce delays. It will of course which is, frankly, doable and does not conflict with depend on the sovereign states to comply with and meeting airspace users’ needs whilst doing contribute to that European basis. something for the environment. That is the reason that we feel a strengthening of the environmental statutory duty would be beneficial and would Q16 Sammy Wilson: In relation to the third runway recognise the feelings of society towards aviation at at Heathrow, are the air traYc implications of the moment. increasing the capacity of Heathrow any diVerent than if the availability of extra runways in the south Q18 Sammy Wilson: Is the danger of that not that, east of England being provided elsewhere would from an environmentalist’s point of view, they will have for air traYc control, or does it really matter always see that, whatever decisions you make, whether it is in the estuary or at Heathrow what the Y whatever recommendations you make and actions implications for air tra c in the south east of you decide on, you will always be in favour of the use England would be? of aeroplanes and they are against that. Therefore, Mr Arscott: Almost irrespective of where an even by giving you that remit, you are probably not additional runway was provided in the south east, a going to satisfy the people who are objecting to air whole scale review of the airspace arrangements is travel per se. going to be necessary, if you are starting not with a Mr Arscott: You are right of course but I think there clean sheet of paper, because you never can do that is a range of environmental interests which range Y in air tra c control, but you at least have the options from what you describe to people who acknowledge freely available to you to configure things in a more that society wants to be able to fly and that it is a Y e cient manner and our future airspace strategy matter of how you accommodate flying in the most work, which can now proceed apace now the environmentally sustainable manner. My feeling is decision has been taken on where that runway will be that the majority of the environmental interest will be, focused principally on that objective of groups are more perhaps towards the fact that Y securing that we get e ciency, which is the only people are going to want to fly and we need to do it common ground really between aviation and the in an environmentally sustainable way than the fact environmental interests; that we reduce delays, that that we leave the aeroplanes in a hangar and we recognise, as my Chairman said, that the SESAR everybody goes by train or walks. project which will cover all European ATM in the future is properly recognised and crucially the Q19 Graham Stringer: I hear what you say but I am sovereign obligations of states are properly finding it diYcult to imagine what would be diVerent recognised. Although it is a future airspace strategy if you had this power. You would not be changing for the United Kingdom, it will by definition expand the European environmental limits on noise, for over a great deal of Europe. Some of the initiatives instance, would you? You would not be changing the which came from Single Sky one like functional loud noise controls round airports, or would you? airspace blocks will facilitate that sort of debate. Mr Arscott: Unlikely.

Q17 Sammy Wilson: Given the fact therefore that Q20 Graham Stringer: What would you be changing whatever you do is going to have environmental if you were given this environmental remit? You say, implications in terms of stacking, in terms of “We want this environmental remit because it trajectory for planes landing, taking oV, etc., why is sounds good but it will not aVect anything else we there a need for a specific environmental remit? By are doing.” I want to know what it will aVect. What implication, any change that you make to improve will change if you get this responsibility? air traYc and the use of airspace are going to have Mr Arscott: It could put constraints on the air traYc an environmental impact anyway. Why the need for operation. For example, it may be that only in a specific guidance from an environmental point of exceptional circumstances will there be holding. view? Only in exceptional circumstances would there be Processed: 06-07-2009 18:36:56 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG1

Ev 4 Transport Committee: Evidence

21 January 2009 Sir Roy McNulty and Mr John Arscott more than two aeroplanes in a hold. What you want on Heathrow Express and things like that which is something which incentivises technological obviously have a transport benefit but also have an developments to enable you to operate aircraft in a environmental benefit. The purpose of the much more eYcient manner from an environmental environmental duty is to make it clear in the viewpoint. It could well be that, unless for example hierarchy of tasks that the CAA is given that the an aircraft has free passage to the ramp at the arrival environmental dimension is important. airfield and can unload the passengers and switch the engines oV, it does not get start clearance at the point Q24 Graham Stringer: We can all agree on that. I am of departure. That is the sort of obligation that the just trying to find out where you would change the government I am sure will think about giving us. We world as opposed to it being just a nice line in a remit. would just be concerned that it will be consistent Sir Roy McNulty: I think this is still work in with using the air traYc management system in an progress. We see the environmental duty on the CAA eYcient manner. sitting within a clear environmental policy Sir Roy McNulty: This environmental duty which is framework established by government relative to envisaged for the CAA would be a general duty that aviation. It is arguable that that does not exist today. applies to all of the things the CAA does, not just in There are clearly now targets for emissions overall airspace. For example, in carrying out our duties as by 2050 and probably intermediate targets. economic regulators of airports, at the moment there Eventually, those will translate into targets for is nothing in the statute that says the economic aviation and I think the CAA will be part of the regulation part of the CAA should take account mechanism whereby those targets get delivered. necessarily of environmentalists’ expenditures to improve the environmental performance around an Q25 Graham Stringer: Mr Arscott, if I can take you airport. If we had that general, environmental duty, back to stacking, you clearly would not apply that to that is something that the economic regulation part Heathrow in its current situation. You would not of the CAA would take into account in doing its say, “You cannot stack at Heathrow”; otherwise, work. you would reduce the capacity of Heathrow by quite a lot, would you not? Q21 Graham Stringer: Can I ask you the same Mr Arscott: It is most unlikely in the current question in terms of the noise round an airport or the environment. I think we need an incentive to nitrogen oxide levels? Would you be changing those improve the technology that might allow us to do and having higher standards than those that were that. previously set, particularly where there are European standards? Q26 Graham Stringer: Where would you apply it? Sir Roy McNulty: Not necessarily. I think the What would be the consequences? If you are not example that springs to my mind most obviously is allowing aeroplanes to stack, they have to go that, at the moment, the duties we have as economic somewhere else, do they not? regulators are focused on cost eYciency and the Mr Arscott: Not necessarily. This is all part of what provision of services to passengers. They do not call we envisage being undertaken in our future airspace in, so to speak, environmental considerations. The strategy work. We want to see the technology and we purpose of having this environmental duty is to are confident it can be developed, particularly if it is make sure that all parts of the CAA have that incentivised, that would enable aircraft not to take general duty and that the environmental aspects are oV until there was an optimal level— to be taken account of in setting prices for airports. Q27 Graham Stringer: At the moment I am with Q22 Graham Stringer: I can see for completeness landing aircraft. The point you make about taking that it is important. What I am trying to get to is oV is very sensible. I cannot understand why what would change. One of the biggest impacts, if aeroplanes start their engines before they are ready not the biggest impact, at airports is in road to go. If aeroplanes are coming in and you say that transport to the airport in terms of cars and lorries at that airport they cannot stack, they are going to arriving at the airport. Would you be looking at the have to go somewhere else, are they not, with capacity in the road system and those kinds of consequences in the fuel bill? environmental things beyond what the Highways Mr Arscott: No, I do not agree at all. They do not Agency and the Department for Transport are have to go somewhere else. If you have the doing? technology—and we are not that far oV—which Sir Roy McNulty: We might be looking at would enable an aircraft to take oV and fly on an contributions towards improving surface access for optimum profile to a final approach to a runway, environmental reasons which again, under our land and get on a stand and shut the engine down, current remit, it is arguable we might not take into you do not have to stack. All of that is a component account. of the future airspace strategy and how we might achieve that, but it is not unachievable in a Q23 Graham Stringer: Would you not be duplicating reasonable timescale that we are talking about for what is done by other agencies of government? the delivery of the Air Transport White Paper. Sir Roy McNulty: We would naturally be focusing on the airport and services that feed into the airport. Q28 Mark Pritchard: How do crowded airspace and In previous exercises, we have allowed expenditures regional airports fit in—for example, Birmingham? Processed: 06-07-2009 18:36:56 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG1

Transport Committee: Evidence Ev 5

21 January 2009 Sir Roy McNulty and Mr John Arscott

Mr Arscott: They are an increasing component of Mr Arscott: They are significant. I think it is fair the air traYc mix in this country. The diYculties of to say we are in the lead in Europe, if not the world, going through Heathrow have meant that a lot of in facilitating access to UAVs into what is regional airports have grown in capacity over the commonly called civil airspace. In fact, this last two years, rightly so. In one respect, it presents morning at the board we took a presentation from us with some opportunities in that, if they are away British Aerospace Systems on exactly this point. from the south east of the UK, it gives us some The most challenging area for unmanned air routing opportunities to take them to the continent, systems is outside controlled airspace where north America or something like that without essentially separation is provided by the pilot seeing going through the south and south east. and avoiding conflicting aeroplanes. We translate Alternatively of course, if they are in the mainland that into unmanned air systems as a sense and UK, Scotland, Northern Ireland and Wales, and avoid as opposed to see and avoid. Getting the they want to get to Europe, then it is quite diYcult technology around a sense and avoid system is a to do that without going through the south east of really challenging exercise. In the controlled the UK. The option it gives you is to transit the airspace environment, arguably, the solution is south east of the United Kingdom at higher levels easier to come by because you have a much more than you would transit if you had taken oV from organised system and you can specify the the south east. Regional airports do have a great electronics on an unmanned system as you would utility and are popular with the public. We for an airliner. Broadly speaking, it is a more simple encourage their use and we facilitate the airspace operation. We have some experience of doing that arrangements to enable them to operate eYciently. with unmanned air systems flying through and into The environmental impact at regional airports is in UK airspace already. many respects less for the same given aeroplane than you would find if it was in congested airspace Q35 Mark Pritchard: Whether in or outside in the south east. controlled airspace, are you aware of any unmanned aerial vehicles that are currently being Q29 Mark Pritchard: Do you think extending piloted by pilots who are not resident within the Birmingham’s runway would help or hinder the United Kingdom? strategy that you are trying to make? Mr Arscott: I do not think so. We have had some Mr Arscott: That was one of the components of the aircraft fly through UK airspace which are Air Transport White Paper, to do that. A eVectively being controlled from outside the UK component was to have another runway which I but of course under the authority of the air traYc think has rather diminished now. The extension so control system in the United Kingdom. That is that you can operate larger aeroplanes for longer perfectly normal. haul is something that would need to be factored in in our airspace strategy. We do not see any huge Q36 Mark Pritchard: How many near misses have problem associated with that. there been in the last 12 months between commercial aircraft and UAVs? Q30 Mark Pritchard: Would that extension help or Mr Arscott: None that I am aware of. hinder the strategy you want to implement? Sir Roy McNulty: None that I am aware of either. Mr Arscott: I could not say either way. Q37 Mark Pritchard: You would be aware of it if Q31 Mark Pritchard: You used the words “factored there had been? in”. What does “factored in” mean? Is it factored Sir Roy McNulty: Absolutely. in positively or negatively? Sir Roy McNulty: It is taken account of. Q38 Mark Pritchard: You mentioned earlier that technology does not come without risk. In this day Q32 Mark Pritchard: Have you taken account of it? and age where we are going to have more and more Sir Roy McNulty: We will. This future airspace technology, cyber security and people trying to strategy— penetrate systems just for fun—some people perhaps for geopolitical reasons—how secure do Q33 Mark Pritchard: Do you have an interim view you think the United Kingdom air traYc control on the account that you have taken thus far or that systems are? How confident are you that they are you might take? secure, robust and resilient against malicious Sir Roy McNulty: We have not got to that stage. cyber attack? NATS are doing work on scoping exactly how this Mr Arscott: Were they to be interfered with, that exercise should be done, how big it is and so on. It would be a safety issue and we have a robust and is probably an exercise that will take us another two resilient system for reporting safety incidents. It is or three years to complete. one of the benefits of the aviation industry in this country that we have a full and frank, open Q34 Mark Pritchard: Again, back to crowded reporting system which encourages the reporting of airspace, increased use of unmanned air vehicles for safety incidents for the benefit of the industry as a military purposes, mapping, intelligence gathering. whole. We have very few examples of what you are How much of an issue are UAVs within domestic suggesting. On the few occasions that there have airspace? been, the courts and the police have acted very Processed: 06-07-2009 18:36:56 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG1

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21 January 2009 Sir Roy McNulty and Mr John Arscott quickly and vigorously. You will be aware that we Q44 Ms Smith: No clear timescale. I understand had some issues before Christmas on lasers which that. You seem to have some confidence that a resulted in people being imprisoned. That sent a programme of this kind will be implemented. very powerful signal about the sorts of things that Sir Roy McNulty: A programme of this kind, we have but, as with all aircraft and air traYc managed very well and done step by step, should systems designs, their resilience to electronic be able to be delivered. It needs a research phase interference is part of the certification of the in many cases to prove the concept and then we go system. I would expect that to continue in the ahead with the implementation. future. The industry is well aware of the potential that you allude to and I am certain that in the Q45 Ms Smith: Is it not the case that, even given future it will need to be suYciently mitigated so the development of technology such as this, careful that safety is not adversely aVected. planning for potential increases in use of airspace needs to be built in in order to make such technology work properly? In other words, if you Q39 Ms Smith: I just wanted to go back to the get the planning wrong, it does not matter how stacking issue. It is the case, is it not, that there is good your system is for managing landings of a stacking problem at the moment at UK airports? aircraft at airports, you will still have a stacking Mr Arscott: A problem is rather overstating it. arrangement. Sir Roy McNulty: One of the objectives of this Q40 Ms Smith: It happens? system will be to make the whole planning and Sir Roy McNulty: It is standard practice. execution of any given flight a much more precise Mr Arscott: As Mr Stringer said, if you want to operation. At the moment it is not so precise. The operate a runway at maximum capacity, at the timings are not so precise. The handing of aircraft moment with the current available technology the from one controller to the next controller from best way to achieve that is to have a ready pool of sector to sector is not a very precise exercise. What aircraft that the air traYc controller can pull oV at is envisaged under SESAR is much more precise will to ensure that the minimum separation is timing and coordination between all the flights that maintained in getting maximum runway capacity. are going on at any one time. It is a routine way of optimising runway capacity. Problems occur which are resolved by stacking as Q46 Ms Smith: What I was trying to say though is a consequence of bad weather, uncerviceability, that it is not just that, is it? It is about how much aircraft, ground systems and a whole myriad of capacity you have in terms of runways and so on things of which I am sure you are aware. Stacking in order to land the craft in the first place. It does is a proper practice for air traYc control in the not matter how good your technology is, you still current era. need runways to land on so careful planning of airspace use and capacity for landing craft are still major issues. Q41 Ms Smith: In environmental terms it can be Sir Roy McNulty: Absolutely. The whole system seen as a problem. has to work together. Mr Arscott: It is certainly an environmental issue. Q47 Ms Smith: On safety, the potential increase in Q42 Ms Smith: The technology you describe use of airspace has to be planned for of course but potentially to deal with this has been a long time can you reassure me that the strategy will take any in the development. How confident are you that it extra measures necessary to maintain safety will be ready in the foreseeable future? standards? Sir Roy McNulty: As I said earlier, this is a major, Sir Roy McNulty: Absolutely. major programme of research and technological development for the next 20 years. How confident Q48 Ms Smith: Are there any extra measures am I? Scared rigid might be the phrase. This is very planned? challenging but very necessary. It will deliver major Sir Roy McNulty: We are taking measures benefits in terms of cost eYciency, in terms of continuously. Just to go back to the Transport Act environmental performance but, as we know, big 2000 which set up the airspace policy activity within complicated technological leaps forward are full of the CAA, it was made crystal clear in that risks and need to be managed very carefully. legislation that safety was paramount. That is the first and major duty on the CAA. We work on safety aspects all the time. Everything that the Q43 Ms Smith: It has been, as I understand it, Airspace Policy Group does in terms of airspace about 30 years so far in the development. changes or other things is done in very close Sir Roy McNulty: No. The SESAR programme is coordination with our safety regulation people. We really only being launched now. This is the next big do not take steps that we are not satisfied are safe. step. In the United States they have a quite similar We have a series of programmes. At the moment programme called “NextGen”, next generation. we have an airspace safety initiative which is This is the next big step ahead for the air traYc particularly looking at safety issues in uncontrolled control system that we know and love and which airspace and where the junction between has been much the same for the last 20 to 30 years. uncontrolled and controlled airspace happens. That Processed: 06-07-2009 18:36:56 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG1

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21 January 2009 Sir Roy McNulty and Mr John Arscott is an exercise we are doing in close cooperation with what we believe to be the public interest. For NATS, with the Ministry of Defence, with general example, in the south east of the UK where you aviation interests, with the whole aviation have a large number of airports and a lot of intense community and getting excellent cooperation in commercial air traYc it is a challenge to have doing so. All of these people are wanting to see a general aviation and the military working in those safe system and are dedicated to working with us. areas. What we need to do is to give them areas, particularly for the MoD, where they can carry out Q49 Mr Wilshire: A topical issue which I think is what they need to do but not necessarily in that highly relevant to the general question of future portion where it conflicts with commercial air capacity is bird strikes. These are horribly topical transport. General aviation is more of a challenge just at the minute. I assume that that risk figures in that the opportunity to go further afield is less when you are doing an overall assessment of safety for them, obviously because of residents and the in air traYc control? ability to fly long distances quickly, but we do seek Mr Arscott: Yes. It is one of the many things which to make most of our airspace arrangements are considered. A safety case for an airspace change interoperable between the interests that you has to be produced, scrutinised by on the one part describe. Technology enables us to do that most the safety regulation group of the CAA and on the eYciently. We have a number of initiatives which other part, if there is a military connection, by the permit interoperability of disparate activities like Ministry of Defence. They assure us that the safety for example the mandatory carriage of is suYciently rigorous to enable that arrangement transponders which gives every aeroplane or every to be put in place. Specifically on bird strikes, if you air vehicle an electronic signature, which means of want, I can explain what we do. I do not know course that safety nets and safety systems can then necessarily that you have the time or inclination to be eVective and augment the see and avoid hear about that. principles in uncontrolled airspace that I described. Chairman: If you want to send us more information In an airspace which is as congested as the United that would be helpful but we will carry on with the Kingdom, I measure success on the grounds that, questions. if the level of abuse from the three interest groups that you describe is about the same volume, then Q50 Mr Wilshire: Could I pursue the general issue we probably have it right. If somebody rings me of bird strikes? Would it be reasonable to assume and says, “That was a really good decision” almost that some areas are at greater risk than others when certainly we have got it wrong. it comes to assessing bird strikes? Mr Arscott: Yes. We identify those by a number of Q54 Mark Pritchard: All three generate noise of means with the assistance of the RSPB and people course and I just wonder if there is a technical term. like that. They are marked on charts. There are In some airports, in some countries, the rate of certain statutory duties that operators of aircraft, descent is very rapid so aircraft are kept pretty high people who run airports, local authorities, DfT and they descend at a rate of knots from a far have as an obligation to notify those areas and greater height. What is the name for that? pilots of course are expected to react in a manner Mr Arscott: It is continuous descent approach. that we describe in the ANO in those areas, the objective of course being to minimise the possibility Q55 Mark Pritchard: Given that we see aircraft of something like happened in New York. coming in on the approach, maybe 10 or 15 aircraft at a time higher than one another flying over Q51 Mr Wilshire: Would you discourage me from London, disrupting lives sometimes, why are we thinking that salt marshes and coasts probably not using that mechanism more often? have a greater capacity for producing large birds Mr Arscott: What you describe is not actually than some inland sites? continuous descent approach. The steep approach Mr Arscott: No. That is exactly what we have said is what we operate at London City Airport because on the proposal in the Air Transport White Paper of the obstruction criteria around the airport. It for an airport at CliVe. was originally operated as a short take oV and landing airport and that is the configuration of the Q52 Mr Wilshire: That still remains the case? aircraft that fly in to it. It so happens that other Mr Arscott: Absolutely. aircraft now can use that configuration but there are— Q53 Mr Wilshire: You have the impossible task of satisfying three competing interests, military, Q56 Mark Pritchard: With the short take oV and general and civil aviation, all of whom will no landing, that is on take oV and landing by doubt tell you that you are being unfair to them. definition, talking about the length of the runway, Is the attempt to find more capacity now for civil not the rate of descent. aviation going to be at the expense of military Mr Arscott: Not so in as much as the flatter the activities and general aviation or can you cope with approach almost certainly the longer the run is that pressure? going to be; whereas a steep approach invariably Mr Arscott: The whole exercise is a balancing act. allows for a much shorter landing run, which is why Depending on what the government policy on the the military and others use that technique. The requirement is, that tends to direct us in fulfilling continuous descent approach is not about steep Processed: 06-07-2009 18:36:56 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG1

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21 January 2009 Sir Roy McNulty and Mr John Arscott approaches. It is about commencing the descent at Mr Arscott: Very significantly. The physical range and continuing the descent uninterrupted obstruction of the wind turbine can be mitigated such that you do not have the noise disadvantage adequately by lighting and operational procedures of increasing the power of the engines because you and safeguard zones around airports. The eVect have to maintain level flight, eVectively cleaning up that moving turbines have on primary radar is very the aeroplane. You therefore have a much lower significant. It is much less so with secondary radar, noise profile if you can operate continuous descent which is where there is a transponder in the aircraft approaches. which responds to an interrogation from the ground. That is another reason why, for the air Q57 Mark Pritchard: I realise that is where you traYc community, we want to move towards want to get to but where we are is that there is for transponder carriage by everybody so that we are some people a lot of noise. I just wonder why, given going to give a free hand, pretty well, to the wind that the runways are longer at City Airport and power industry to go ahead and develop their Heathrow, we are not seeing a steeper descent in turbines. In the CAA, I am a member of BERR, order to avoid noise. now DECC, aviation management board. We have Mr Arscott: Operationally, it produces disbenefits an aviation programme which is sponsored by the which are not— Prime Minister to seek to enable the government’s renewable energy targets to be met. We are doing Q58 Mark Pritchard: What about the introduction a lot of work on how that and the problems you of new technology? You are raving about new allude to, can be resolved. Technology is technology here and interoperability between steep undoubtedly a possibility but certainly we have descent and new technology. taken the role of seeking to facilitate solutions Mr Arscott: It is certainly an option that would between aviation and the wind power industry in the vicinity of airports by suggesting diVerent need to be considered but you get a more accurate V landing if you have made a slightly lower— operational procedures and di erent locations for the building of these turbines. Over the next year or so, we will probably see some quite useful Q59 Mark Pritchard: What is the definition of developments on that. Your view that they “accurate landing”? interrupt air traYc control radar at the moment is Mr Arscott: It enables you to land precisely and absolutely correct. therefore meet the fast turn oV that you want so you can improve the runway capacity. We need to be clear: continuous descent approaches are Q63 Sammy Wilson: What kind of area are you something that we advocate, we mandate and, talking about or what kind of distance from the generally speaking, are operated widely in the airport? United Kingdom. We would like to see more of it Mr Arscott: It is diYcult to say because it depends undoubtedly and we seek to achieve that in the on the type of radar. Generally speaking, anything technology development and certainly in the future which is within about I suppose 30 kilometres of a airspace strategy that I have described. radar is probably going to cause some problem. The Ministry of Defence, who I think have Q60 Mark Pritchard: I may be wrong here but after submitted a memorandum and may wish to answer the New York incident, the bird strike and the this point as well, have significantly greater aircraft that landed in Hudson Bay, I was watching problems than does the civil air traYc community a TV programme and a UK pilot said, “We do not on this point, but they are involved with this train for water landings.” I was not quite sure initiative with BERR and DECC. I think we are about that. I thought surely, given that we are an making progress even for the MoD but obviously island, there is practice for emergency landings on they would wish to speak for themselves. water which is standard in the United States. What is the position? Sir Roy McNulty: Pilot training, done on a three Q64 Graham Stringer: With the advancing year rolling programme for each pilot, does cover technology, what is the likelihood of the statutory all sorts of emergency procedures. We can give you minimum distances between aeroplanes being a separate note on that. reduced or between runways? Are either of those minimum distances likely to be reduced? Mr Arscott: We hope that that would be the case Q61 Mark Pritchard: Do you know if it includes but clearly there would have to be a safety case landing on water? produced and sustained to prove it. Sir Roy McNulty: From memory, it covers the check lists and everything that you would need for such a situation. Q65 Graham Stringer: Over what period of time? Is the technology there to reduce the distance between Q62 Mark Pritchard: With the proliferation of both planes now? land based and oVshore wind farms, how does that Mr Arscott: There are certain circumstances where aVect your business and in particular impact on the separation distances can be reduced already. If radar, disruption to radar, misinformation as a that was more widely available supported by a result of disruption, etc? safety case, we would be keen to see it. Processed: 06-07-2009 18:36:56 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG1

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21 January 2009 Sir Roy McNulty and Mr John Arscott

Q66 Graham Stringer: In terms of the technology Mr Arscott: Both what together? we have at the moment, what would that do to the increasing capacity at Heathrow? Q70 Graham Stringer: If you were to get the Mr Arscott: Since the limiting factor is runway aeroplanes closer together on the runway and in the capacity, nothing. air, you would be increasing the capacity, would you not? Mr Arscott: If you could have a shorter landing Q67 Graham Stringer: I do not understand that. I sequence, yes. do not know what the minimum distance is at the moment, but say it is three miles, if you were to Q71 Graham Stringer: Is the technology there to be reduce it to two miles you could presumably run able to do that? more aeroplanes. Mr Arscott: No, not at present. Mr Arscott: It depends how close you can have them on the runway. I thought you were talking Q72 Graham Stringer: Is it likely to be in the about separation in the air. future? Mr Arscott: I would have thought it would be an Q68 Graham Stringer: I was talking about two objective of the industry to do that, for obvious things. I was talking about the separation of reasons. aeroplanes in the air and landing, so that you could get more coming in, and, quite separate from that, Q73 Graham Stringer: Is there a time horizon for I was talking about the physical separation between that? runways, not planes on runways. Mr Arscott: Not that I am aware of. Mr Arscott: To take the two points: the separation of aircraft on final approach is determined by the Q74 Graham Stringer: The distance between separation that is acceptable on the runway. The runways? Mr Arscott: I am not aware at the moment. There separation between runways is occasioned by the are International Civil Aviation Organisation accuracy of the navigation systems on the aircraft criteria for this which have been reasonably robust and on the ground to ensure that there are no over time. I am not aware that there is any circumstances under which for runways which are V particular technology being developed now which close together the operation on one will a ect would facilitate runways being closer than the adversely the operation on the other. minimum specified under ICAO arrangements at the moment. Q69 Graham Stringer: Presumably, if you could get Graham Stringer: Thank you. them closer together you would increase the Chairman: Thank you very much for answering our capacity. questions.

Witnesses: Mr Roger Gardner, Chief Executive, Professor Ian Poll, Cranfield University, Dr Rod Self, Southampton University,and Dr Tom Reynolds, Cambridge University,Omega Academic Partnership, gave evidence.

Q75 Chairman: Good afternoon, gentlemen. Would Tom Reynolds, so he is probably best placed to you introduce yourselves and your organisations for answer the specifics on that particular element of our our record, please. programme of work. Dr Reynolds: Good afternoon. My name is Tom Dr Reynolds: Verymuch in the same vein as we heard Reynolds. I am with the Institute for Aviation from the CAA when they were talking about the Environment at the University of Cambridge. technology, they referred to the fact that, with the Dr Self: My name is Rod Self. I am at the Institute planned advance technologies that are being of Sound and Vibration Research at the University developed now, both in Europe and the US, we of Southampton. should be able to get closer to the ideal trajectory Professor Poll: I am Ian Poll. I am Professor of that all aircraft could fly if there were no other Aerospace Engineering at Cranfield University and constraints imposed upon them by the air traYc Technology Lead in the Omega Programme. management (ATM) system. If there were only one Mr Gardner: I am Roger Gardner, Chief Executive aircraft in the sky and there were no constraints on of the Omega Knowledge Transfer Partnership it, it could fly an environmentally optimal trajectory. Y based out of Manchester Met University. In the ATM e ciency study of the Omega Partnership we have been trying to quantify just how far from that environmentally ideal case we are in the current traYc management system, particularly in Q76 Chairman: Thank you very much. What are the Europe but, also, we have been doing some other main findings of your work examining ineYciencies works comparing European eYciencies with other in traYc management? parts of the world. In the submission we identified Mr Gardner: The partnership has addressed a range not only the current levels of ineYciencies, which of diVerent issues, of which this is one. The expert stand at somewhere between 10% and 15% (that is, who has done the majority of work in this area is Dr some aircraft are flying about 10–15% further than Processed: 06-07-2009 18:36:56 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG1

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21 January 2009 Mr Roger Gardner, Professor Ian Poll, Dr Rod Self and Dr Tom Reynolds the ideal case) in Europe, but also we identified some Q81 Chairman: What about the removal of of what the causes of that ineYciency are. Omega is stacking—do you have some ideas on that? trying to identify what the most important causes are Professor Poll: Stacking is an indication of waste in that are leading to those levels of ineYciency with a the system. As was said before, if the aeroplane takes view to then informing the technology developers oV and you know its time of arrival at destination, it and the stakeholder community, such as the ATM should get there just when it is expected, and when it providers, of some of the highest priorities are as gets there the runway should be clear and it should supported by the data analysis we have been doing. come straight into land. Any need to stack is fundamentally an expression of waste, so in an ideal Q77 Chairman: The wholesale removal of large system it would not be there. restricted areas is one of the things you suggest. Would that not compromise safety? Q82 Chairman: In your written evidence you discuss Dr Reynolds: One of the things we identified as being a number of research topics. Which are the most a primary driver of excess track distance was the fact important in delivering results in the near future? that the aircraft are flying standard routeings and Dr Reynolds: There are a number of other Omega standard flight levels, which is a necessary structure studies that are pertinent to the discussion in which that is imposed on air traYc management systems to this Committee is certainly interested. The eYciency maintain safety,and many of those standard airways work to which I alluded at the start is one. We have are flying around restricted airspace. One potential a stakeholder workshop next week which involves option for improving the eYciency is not removing groups from overseas as well. That will hopefully the structure but removing some of the obstacles to encourage debate amongst the stakeholder where that structure can evolve and how it is used. community, but there are many other Omega studies that are certainly relevant. Q78 Chairman: Is there not a safety issue here? Mr Gardner: Certainly there are. They are, by Dr Reynolds: The structure is there to maintain nature, longer term in terms of understanding the safety, and the restricted airspace is really just significance of some of the climate science that might putting constraints on where the structure can go. have a bearing upon where aircraft fly in order to For example, zones of military often require minimise environmental impacts. That is a question restricted airspace. Obviously they need areas to of understanding whether, for instance, one would train, et cetera, and so the airways route around that specifically wish to avoid contrail formation because restricted airspace. If you were to remove some of of the environmental gains that might be achieved that restricted airspace, you could still maintain the from doing that which could feed through into the structure which maintains the safety. So I would say, ATM system. Similarly, we are looking at the longer no, removal of restricted airspace does not change term environmental implications of various the safety in any way. technologies in order to try to understand what that might mean in terms of technology or operational strategies which might be deployed by diVerent Q79 Chairman: Dr Poll, would you like to add branches of air transport or the manufacturing something? sector—that, along with some activities related to Professor Poll: All safety issues impinge upon the nearer airport environmental impact. emissions. What you do to ensure safety almost invariably aVects the emissions of the aircraft. For example, the carrying of reserve fuel, which is there Q83 Chairman: Are you able to give us any idea of to take account of unexpected events. More often time on this? In how many years can something than not that fuel is not burned, but it is carried and specific be produced from you that is going to make therefore there is an emissions penalty. The same a significant diVerence? goes for the route and tracking. Mr Gardner: In terms of the answers to the scientific questions, the general understanding is that we are still five to 10 years away from bottoming out the big Q80 Chairman: Do you agree with the evidence from science questions that are going to enable clearer the Manchester Airports Group that more direct strategising. That said, however, a number of the routeing could be implemented widely without any studies which will be reporting over the next two or new technology or investment? three months will still give some pointers on that. Professor Poll: That is a good question: Could the They will give some road maps about when re-routeing be improved without new technology? I information might be available from diVerent parts suspect that the answer to that is no, because the of the academic community and from industry that systems that are used at the moment are, let us say, would help to sharpen up the view forward, but it is tried and true: they have been around for a long an iterative process and there are some things which time, they are people intensive, and they are there to can be done through nearer term findings and others make sure that accidents or incidents do not happen. which are clearly much longer term. Without the availability of a better knowledge of the position of aircraft, a better knowledge of the anticipated arrival time at particular destinations, I Q84 Graham Stringer: Can I take it from that that do not see how you could improve the situation the science of the impact of contrails on climate without potentially compromising safety.I think you change is not established? 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21 January 2009 Mr Roger Gardner, Professor Ian Poll, Dr Rod Self and Dr Tom Reynolds am aware, there is only one study that has shown the Canary Islands they had the option of flying into that. Do you consider the science to be established oceanic airspace which is significantly cheaper than or is it still to be confirmed? the domestic European airspace. Depending on the Mr Gardner: It is still open. There have been a range cost of fuel at that time, that was one of the only of pieces of research, going back to the 1999 special routes in Europe where there was any question as to report by the IPCC (Aviation and the Global whether it made sense from a total cost perspective. Atmosphere) which gave the greatest uncertainty in The conclusion of the Omega study,therefore, is that relation to aviation science on the contrails and from the analysis we have done it looks like it is very induced cirrus impacts. That uncertainty is much the exception rather than the rule that diVerent narrowing, but it is still fairly significant, and charging in diVerent parts of Europe has any eVect therefore there will be a period of time before that on the actual route that the airlines are flying. question can be answered. Whether it ends up by being a positive or negative signal is still a question Q86 Chairman: Have you done any work on aircraft of debate. noise in tranquil areas? Professor Poll: This is one of the areas on which I am Mr Gardner: No. working in Omega. The generation of a contrail is Dr Self: No. something which is entirely under our control: we know under what circumstances they are formed and Q87 Chairman: What problems are there that we know what to do to stop them forming. In a prevent the wider use of the continuous descent sense, it is part of the air traYc management approach? problem, because if you fly through air that is super Dr Reynolds: Continuous descent approaches mean saturated with respect to ice then you form a diVerent things to diVerent people and they are contrail. If you avoid that air—which is relatively defined diVerently in diVerent parts of the world. easy—you do not. In the climate implications of The perfect CDA, if you will, is when the CDA, as contrails, the one thing that is beyond dispute is that was described by the CAA gentlemen, is conducted anything you can see is not good news for the from the cruise altitude all the way down to the environment. And you can certainly see contrails ground, where in theory the aircraft should be at and the cirrus cloud that they tend to generate. The flight idle (that is, the engines are powered to a other thing that you might find interesting is that the relatively low thrust level and hence their fuel burn is reason that aircraft fly in the altitude zones that significantly lower) all throughout the descent. The generate contrails is down to the design of the problem that that introduces to the air traYc airport, because it is related to the requirement to management task is that it requires significant co- land the aeroplane safely within a given distance. ordination between many diVerent air traYc This has a first order impact on the size of the management regions and it makes the predictability aircraft; the size of the aircraft decides where it flies. of the descent that much less certain and therefore Chairman: A division has been called. I suspend the CDAs in that ideal sense are relatively diYcult to co- Committee. Ten minutes if it is one vote. We will get ordinate in the current air traYc control system. back as soon as we can, gentlemen, if you would Some of the advanced technologies that are being wait. developed, again, for example, by the SESAR programme should enable that co-ordination to The Committee suspended from 5.00 pm to 5.28 pm occur much more readily and therefore enables the for a division in the House. full environmental benefits of CDA to be achieved much more fully in the future. Q85 Chairman: I am sorry to keep you all waiting. Chairman: Thank you. You make reference to excessive mileage being flown to avoid going into expensive airspace areas. What Q88 Ms Smith: I want to ask about the range of your evidence is there of that? activities really. The comments made earlier, for Dr Reynolds: What prompted one of the Omega instance, about the carrying of reserve fuel on a studies was that there was a report from the BBC a plane and how that increases emissions, I found year or two ago that there was some evidence that on interesting. It is my understanding that there is a lot some routes in Europe airlines were potentially of work ongoing to produce lighter and stronger flying longer distances and therefore burning more materials for use in aircraft production, particularly fuel and hence emitting more carbon dioxide in around the Advanced Manufacturing Park, the order to fly into the less expensive airspace. Note partnership with Boeing at SheYeld. I wondered that every region in Europe has its own charging how much the partnership is involved in that kind of rate, they will use a constant formula, but then the work, because to my mind that could be potentially charging rate in that formula is diVerent for diVerent very useful in reducing emissions. countries. On the back of that anecdotal evidence, Professor Poll: We are trying to get a feel for what is Omega undertook a more detailed study to try to possible and, rather than working with the identify whether this was a real issue or not on a technologies themselves, to take a higher level view wider scale in European airspace and we examined and say, “Okay, what will that technology deliver if approximately 100 diVerent routes between 12 it is brought through to the largest possible extent?” diVerent city pairs covering the entire extent of You talk about composite materials and, yes, in Europe. We found that in the case that was identified principle, composite materials could lead to lighter by the BBC, which was some routes from the UK to structures—and I am choosing my words carefully Processed: 06-07-2009 18:36:56 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG1

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21 January 2009 Mr Roger Gardner, Professor Ian Poll, Dr Rod Self and Dr Tom Reynolds here because simply changing the material does not predictability of the approaches and departures to necessarily mean that you get a weight saving help the air traYc management process get the straight away—but let us be optimistic: carbon fibre maximum throughput as well of the resources that composite for use on wing structure and fuselage they have available. structure, as on the Boeing 787, potentially, after several design iterations and probably 10/15 years, Q91 Mr Hollobone: Could I come back to the eVects you could get 25% weight reduction on those of noise on tranquil areas. You say that you do not components but that does not mean that the fuel do any research on this but can I ask quite a long burn goes down by 25%. Fuel burn will go down question on this. You describe yourselves as a one- more like 10–15% and it will depend on the range stop shop providing impartial world-class academic that the aircraft is flying. There is always an expertise on the environmental issues facing attenuation between the technology and the fuel aviation. I want to put to you evidence we have burn performance. That attenuation can be quite received from Shropshire County Council which large, unfortunately. says that the CAA’s West End Area Airspace Mr Gardner: As with much of our work this issue is Changes have resulted in a 21% overall increase in geared to understanding the environmental issues air traYc over-flight in the Shropshire Hills, area of associated with various options for future outstanding natural beauty.Natural England told us development of either technologies, operations, near that recent airspace changes by NATS will increase airport impacts and the like, such that we can help over-flying of the New Forest National Park, the to provide underpinning knowledge to the industry North Wessex Downs, the Cotswolds, the Mendips or to airlines or to airports that allows them to do and so on. Shropshire County Council have said, what they do better and quicker. We are not really “There is a paucity of available research and models looking at the details of composite technologies, we for the appropriate consideration of the issues are looking, for instance in that area, at the extent to around tranquillity and noise intrusion from which those might be integrated and what the aircraft” and they have called on the Government to environmental benefits might be associated with “commission research and detailed studies on V various di erent scenarios and options. measuring tranquillity and mitigating impacts of aircraft noise on tranquillity.” Given your role as a Q89 Ms Smith: Overall, I take it from what you have one-stop shop, do you agree that research is urgently both said, with all the caveats in place that were required in this area? mentioned, that it is still potentially a useful Mr Gardner: Omega has been going for two years contribution towards the future of the industry. now and our initial programmes were defined by Professor Poll: From what we see, aviation can be what were determined to be the key priority areas improved considerably if the circumstances, expressed by government and a range of particularly the economic circumstances and the stakeholders in terms of aviation sustainability regulatory environment, are right. There is quite a challenges. Thus far, the topic of tranquil area noise bit more that can be extracted, even without the use has not come forward as an area that has been of high technology. specifically requiring research; however, that is not to say that it could not be addressed in the future. Clearly, as part of helping address the totality of the Q90 Chairman: Could you tell us if Precision Area sustainability challenge, where you are trying to Navigation can help to increase airspace? balance noise interests between urban areas and Dr Reynolds: I suspect that some of the other tranquil areas there may be some issues to be looked speakers who are in the air traYc management field at where academia could make a contribution. But I would also be able to answer that, perhaps better think we would need to see what the questions were than I could. But Precision Area Navigation (P- and see whether in fact it was felt that there was good RNAV) is really a way of making trajectories, work that could be done. It has not arisen yet. particularly arrival and departure trajectories, into and from airports more predictable, so that they can be programmed into the aircraft computer system, Q92 Mr Hollobone: To paraphrase what you have for example. One example is that some P-RNAV said—and please correct me if I am wrong—the approaches into any airport would be defined by a Government has not highlighted tranquillity as an set of way points which give fixed locations on the issue about which it is particularly concerned but ground and at those way points you could have other organisations have highlighted this and it is an altitude and speed targets that the aircraft should try area on which you would seek to concentrate, given to meet. That enables the procedures to be designed appropriate government guidance. specifically to accommodate some of these best Mr Gardner: I could not necessarily sign up to your practice techniques such as continuous descent first statement to say that in fact government has approaches—and there are some others, such as low said it is not a priority area. That I do not know. All power/low drag approaches. They can be designed I can say is that in the discussions we have had it has into the procedure and, as long as the aircraft has the not cropped up as an area where particular research technology on board to enable those procedures to is required. be programmed in, the aircraft is capable of flying those predefined procedures very accurately. That Q93 Graham Stringer: Professor Poll, you made the enables the full environmental benefit of those sensible point about the balance between safety and procedures to be obtained while also increasing the environmental issues. 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Transport Committee: Evidence Ev 13

21 January 2009 Mr Roger Gardner, Professor Ian Poll, Dr Rod Self and Dr Tom Reynolds any threshold whereby because people are more Q99 Graham Stringer: I take that point. concerned about the environment the planes that are Professor Poll: But if you have a nice long runway flying are less safe? I like the idea of my plane having ahead of you, you can take oV at less than full power, a lot of petrol in the tank. so you can use a bigger run, and if you are taking oV Professor Poll: No, I think I can be fairly certain that at less than full power then your noise footprint is the answer to that is no. smaller. Q100 Graham Stringer: Does that have safety Q94 Graham Stringer: How can you be so certain? implications if you are using less than full power? Professor Poll: Because, as Sir Roy McNulty was at Professor Poll: No. Because the safety implications of take oV are that if you reach the critical point pains to point out, safety is paramount. That is the where the aircraft is capable of flying but has not left first and foremost consideration as far as aviation the ground, you must be able to put the brakes on regulation is concerned. Having said that, aviation, and come to a stop before you reach the end of the like every other sector, has to do everything it runway. The pilot has to do a calculation to make possibly can to reduce its impact on the sure that he can get oV the runway at the right time, environment, either through emissions or through so if he did have to abort he still has enough runway noise or whatever. Basically, aviation has a very in front of him. That is part of the flight plan. That good track record in cutting out wastage. Wastage is subject to law, so that is necessary. has economic implications which operators would like to see removed. Traditionally there has always Q101 Chairman: Could you tell us what your view is been pressure to do the kinds of things which impact on NATS’ target to reduce CO2 emissions by 10% emissions; in other words, fuel burn reduction and per flight at 2020 compared with 2006. what-have-you, but that has always come behind the Professor Poll: Part of the Omega study reinforces need for safety. Aviation’s safety record is fantastic the view that there is 10–12% fuel burn wastage—I by any standards and that will not be compromised. will use that term—due to the extra distances flown, the non-ideal climb profiles, and the non-ideal ascent profiles. There is 10% to be had and it can be Q95 Graham Stringer: I do not know what the extracted by use of better technology. figures would be but if instead of carrying an extra 45 minutes’ worth of fuel you were carrying 25 minutes’ Q102 Chairman: You are confident that can be done worth of fuel, you must be reducing the safety without jeopardising safety. tolerances if something were to go wrong. Professor Poll: Yes—well, first of all, I am confident that it is there to be worked on. My colleagues may Professor Poll: Correct. have a view but I think the technology is there, it is a question of implementing it in a safe way into the air traYc management system to allow that wastage Q96 Graham Stringer: I am still not sure how you to be extracted. So, yes, I think the answer is that it can be so certain. I have been in aeroplanes that have is possible. I would not like to say how long it would gone wrong and they have had to land at other take but I do not think you need any new physics or airports for one reason or another and I have been anything to get it. very glad to have had a lot of petrol in the tank. Professor Poll: I can tell you that the good news is Q103 Chairman: NATS say by 2020. Is it going to be that carrying an extra 10% of reserve fuel only achieved? reduces the fuel burn per passenger seat mile by 1%, Professor Poll: It sounds good to me. They are the so carrying a bit extra has a very small ones with the money. The technology exists to be environmental impact. assembled to achieve that goal. Q104 Chairman: You think it is feasible. Q97 Chairman: That is reassurance. Professor Poll: Yes. Professor Poll: Yes. If it was the other way around Q105 Chairman: You are saying the technology is then you would be concerned, but it is not a bad there. thing to carry a little extra and nobody in their right Professor Poll: Yes. minds would risk a situation where they ran out of fuel. That is very serious. Q106 Chairman: And if they have put that date— Professor Poll: The wastage is there to be reduced, the technology is available to be implemented, and if Q98 Graham Stringer: Are take-oV speeds being they are confident they can do it by 2020, who are we changed because of the noise impact. to argue with them? Professor Poll: The take-oV speed is not changed, Chairman: We will end on that note. Thank you very because the speed that you achieve determines when much, gentlemen, for coming and answering our the lift equals the load. questions. Processed: 06-07-2009 18:36:56 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG1

Ev 14 Transport Committee: Evidence

Witnesses: Mr Rob Marshall, President and Chief Executive OYcer, Mr Mark Green, Vice President, Policy, Guild of Air TraYc Control OYcers (GATCO), Mr Andrew du Boulay, ATM Portfolio Holder for the Air Safety Group, and Mr Rob GiVord, Executive Director, Parliamentary Advisory Council for Transport Safety, Air Safety Group & Parliamentary Advisory Council for Transport Safety, gave evidence.

Q107 Chairman: Good afternoon, gentlemen. and military. We have good working principles Would you like to introduce yourselves, giving your where we share airspace, so flexible use of airspace name and your organisation for our records, please. means we have improved flexibility and capacity as Mr Marshall: Good afternoon. I am Rob Marshall, far as air space management is concerned. President and Chief Executive of the Guild of Air TraYc Control OYcers. Mr Green: Mark Green, Vice President Policy, Guild Q112 Chairman: What about the safety of Y of Air TraYc Control OYcers. commercial tra c using uncontrolled airspace? Mr du Boulay: Andrew du Boulay, Aviation Mr du Boulay: I think that is a major concern Consultant for Mott MacDonald and I am the Air because 70% of airproxes occur in uncontrolled TraYc Management Portfolio Holder of the Air airspace, so I think it has to be a priority for the Safety Group. CAA, for pilots, for NATS and for everybody Mr GiVord: I am Robert GiVord, Executive Director concerned to address. of the Parliamentary Advisory Council of Transport Safety, with which we have a relationship with the Q113 Graham Stringer: You said 70%. Is it on a Air Safety Group. level? Mr du Boulay: A level. Q108 Chairman: Could you tell us what safety concerns you have about the increasing complexity of air traYc control? Q114 Graham Stringer: So it is not increasing. Mr Marshall: We do not have any major concern Mr du Boulay: No. about safety. Our industry is a very safe industry and any changes to procedures and air traYc control would undergo a strict regime of safety management Q115 Graham Stringer: But the number of before any change was made. Our view, I think, is commercial aeroplanes flying in uncontrolled space that any changes that need to be made or are desired is increasing. to be made need first of all to go under a strict regime Mr du Boulay: I would imagine so, yes, but the of safety management. That is what we are assured proportion of airproxes that are in uncontrolled air will happen and we have no reason to doubt that. spaces has been roughly level at 70%. Mr Marshall: Our view about the provision of safety to flights outside controlled airspace is that the Q109 Chairman: Does anybody have a diVerent view safety should be assessed and if there is a risk there on that? that risk has to be managed. Our view is that if the Mr du Boulay: As I have highlighted in my risk is high enough, that risk should be managed by memorandum, our chief concern is the increasing the provision of controlled airspace. In the event of complexity of the air traYc controller task and how an increasing amount of activity in any area, our they are going to cope in an increasingly systemised desire would be to see controlled airspaces world where they are relying more and more on established to meet that demand. We do recognise, computers. That would be our main concern, I however, the other constraints on the provision of would say. controlled airspace—other airspace users, for example—and that would be taken into account Q110 Chairman: Is that a big concern? during the process of the CAA determining whether Mr du Boulay: It is a concern, because as the or not the provision of controlled airspace was controller relies more and more on technology, if the warranted in that event. technology fails then the controller has to revert to a manual mode of operation and that is going to be more and more problematic as they become more Q116 Chairman: Is additional airspace needed for and more reliant on the system. general aviation aircraft? Mr Green: At the moment, with some of the airspace Q111 Chairman: What about the interface between developments that are underway we are looking civil and military air traYc management? Are there where possible to return airspace to the general user. any issues there? There is always a conflict of interest for the amount Mr Green: I think with the civil/military co- of finite airspace that is available. With the current ordination we have a very good way in which we co- airspace developments we are trying to reverse the operate between civil and military at the moment. trend of taking airspace and, where possible, return There are well-worked out practices and procedures. airspace to the general aviation user, but, inevitably, For instance, military aircraft can already share civil with increased air traYc movements and increasing airspace. They come through assigned corridors commercial air transport, there is going to be a through the civil routes known as crossing corridors. pressure brought to bear on aviation users in In addition, in some instances we have an integrated general, highlighted by certain conflict points operations room, where we have civil and military between areas of controlled airspace, predominantly controllers working in the same ops room. It is in the South East of England, for instance between introducing better ways of working between civil Stansted and Luton. Processed: 06-07-2009 18:36:56 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG1

Transport Committee: Evidence Ev 15

21 January 2009 Mr Rob Marshall, Mr Mark Green, Mr Andrew du Boulay and Mr Rob Gifford

Q117 Chairman: Is there any better way of dealing field in terms of reporting of incidents across with those problems, these very big conflicts on the Europe. In the UK we look at our safety record and use of diVerent types of aircraft? say, “Yes, we think we are the best,” but until we Mr Green: I think that conflict will always exist in compare ourselves with other countries we do not terms of people wanting to use the same piece of know. To take civil/military incidents, for example, airspace. The current policy that is in place, the at the moment about 25% of airproxes are civil/ current procedures that we go through as far as the military incidents. Is that good or bad? I do not airspace change process is concerned, is in place to know. The good thing is that we have the data here try to ensure a fair and equitable use of airspace by and what we need to do is to analyse that data and all users. try, through the European mechanism, to get the Mr GiVord: Perhaps I could comment on both those other countries to sign up to incident reporting at the questions, Chairman. Is there need for more airspace same level as we do. for general aviation? I suspect general aviation would answer: “Yes, please.” It is, however, the case that many of the incidents, certainly those Q120 Mr Hollobone: Has that issue been pursued? If investigated by the Air Accident Investigation so, by whom and what is the mechanism to get the Branch, involve general aviation rather than other European countries up to the UK standard? anything else, so there is a need to ensure that in any Mr du Boulay: It is part of European regulations to debate about reallocation of airspace the General report incidents. Enforcing that and getting that in Aviation Safety Council is involved to get sensible place is proving problematic. In some countries if messages across to its members to ensure that safety you report an incident the controller becomes liable is not further compromised by their activities. for any mistake that he has made, so it is not uniformly implemented across Europe. Q118 Chairman: PACTS in its evidence says that the idea of an Airspace Master Plan is a good idea but Q121 Mr Hollobone: Before we hear from Mr not feasible. Why do you think they say that? Marshall, because we are laypeople could you say Mr du Boulay: In the way that airspace is planned what you mean by “airspace infringements”? today, NATS actually does quite a sophisticated job. Mr du Boulay: I am talking about where aircraft are Airspace demand and capacity projections are made meant to be staying within uncontrolled airspace out to 15 years and potential bottlenecks are infringe inadvertently into controlled airspace. They identified through that process of matching what the cross a border in the sky without realising it and they likely demand is against what is there in terms of are conflicting with commercial aircraft. capacity. Detailed airspace planning takes place, Mr Marshall: Perhaps I could follow up on two when that change needs to happen, within about five points, taking the latter one first: airspace years of it happening, so it allows time for consultation and everything else to make sure that infringements. I think the issue is that in some areas the airspace change is in place prior to its need. In the aircraft that are infringing that airspace are not trying to do anything in detail out to 2030, the life of equipped with modern equipment, so they do not the White Paper, to me would be a nugatory eVort have, for example, secondary radar transponders on Y because you are never going to know exactly which board, so the air tra c controller is unaware that airports are going to get new runways, where the that aircraft has infringed that area. There are airlines are going to want to place their aircraft, to developments in the UK system at the moment to try that detail out to 2030. Trying to design airspace out to make that infringement protection more robust. to that timeframe seems a waste of time. There has recently been a tool that has been developed and is now being used by NATS to detect, if you like, people being somewhere that they should Q119 Mr Hollobone: In terms of avoiding air traYc not. With regard to educating people to improve collisions, given your expertise, if you had to list one, their safety reporting of cultures, it is true to say that two, three, the main risk factors that could lead to an the UK is probably one of the leading countries not air traYc collision what would they be? Mr Green: We have the risk of level passes, so where only in Europe but in the world for reporting aircraft do not adhere to their assigned flight level. incidents. That is something that has grown over a We have the incursion into controlled airspace by period of time and has been enhanced by support general aviation. The third one is runway from other organisations, such as an organisation infringements, where aircraft enter a runway when called CHIRP which has been very proactive in there is conflicting traYc on the runway. If you are getting people to report, sometimes anonymously, asking for my top three, those would be my top three but to try to grow that culture of reporting, to not safety concerns at the moment in the air traYc apportion blame but to detect that something has management system. happened and have an investigation to find out the Mr du Boulay: You said airspace— causal factors and the contributory factors to that Mr Green: Airspace infringements is my second. occurrence. For ourselves, we certainly support Mr du Boulay: Yes, so I would add that my other work throughout Europe to try to grow that culture, concern is general incident reporting across Europe. if you like, in other European air traYc management Whereas the UK have a very good history of associations, and I am sure the pilots do likewise, reporting incidents, not all European countries are through BALPA and other organisations that work up to that standard and there is not a level playing in the same way that we do. 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Ev 16 Transport Committee: Evidence

21 January 2009 Mr Rob Marshall, Mr Mark Green, Mr Andrew du Boulay and Mr Rob Gifford

Q122 Chairman: How would you like to change the humans, humans sometimes fail. That is my answer draft airspace change guidance? There have been to that. The other thing is that, because stacks are some comments that it seems too “woolly”. necessary to fully utilise the runway, what you end Mr Green: When I said it is too woolly, I think at the up doing is minimising your inter-arrival times of moment the concern regarding airspace change is aircraft landing, say, at Heathrow. There must be a that the process focuses predominantly around the point at which that is no longer safe, but what is that environmental guidance that is available from the point? How do you work that out? Is two minutes Department of Transport. In the guidance from the safe? Is one and a half minutes between safe? Is it 2.3 DfT as far as airspace changes are concerned the minutes? How has the criteria been developed? criteria are not prescriptive. It basically says you need to take into account the environment, and you Q126 Ms Smith: Are you suggesting perhaps that the need to take into account, if I could illustrate the criteria for measuring that has not been developed? point, noise and emissions. You are meant to avoid Mr du Boulay: I think the work has been done but I over-flying densely populated areas. There is no am saying that there is not a set point where one definition of what densely populated is, but, by thing is safe on one side of it, so that at 1.9 minutes avoiding the densely populated areas, whilst you it is not safe and at 2.1 minutes it is safe. I do not avoid the noise impact on the ground you increase think that is true in reality. If somebody set a level, the emissions because of the additional track what is the risk either side? As the frequency of mileage. The guidance is there but it is very high level aircraft landings increase, should that safety level and it is open to interpretation, so each and every ever be changed? airspace change proposal is assessed after the proposal has been submitted. There is not clear Q127 Ms Smith: You are looking for guidance really. guidance when you are designing and developing the Mr du Boulay: That is my view. airspace as to what environmental criteria you are meant to be adhering to. There is some guidance but it is very high level and open to interpretation and we Q128 Ms Smith: Yes, on those grounds. In terms of would like more prescriptive guidance. addressing the issue of stacking, you would presumably be looking at something along the lines of better planning of use of airspace, taking out the Q123 Ms Smith: The ASG have said that stacking is wastage in the system, and perhaps extra runways. I necessary and that the consequent level of utilisation do not know. Perhaps you could tell me. of runways means that “inter-arrival times are Mr du Boulay: Part of my reply—and the recent reduced to a minimum thereby eroding the safety announcement about Heathrow is an example where margin for error.” I want to explore that a little with you could actually take action—is that the third you and ask if you are suggesting here that current runway has been given the go-ahead but at a reduced airport operations are now unsafe because of this capacity; that is, only another 125,000 movements practice. are planned for the three runways. That means you Mr du Boulay: I think the term “unsafe” is a very have a system with excess capacity in it, so rather Y di cult term because it suggests that something is than allowing all the runways to be filled up you can either safe or unsafe. I do not think that is true in real take out the stacks, because you do not need to be life. I think everything is a gradation of risk. You landing the aircraft every minute. You now have the have to agree that an airspace full of aircraft stacking very nice situation where you have excess capacity has to be less safe than an airspace without the for a time. The question is how you safeguard that aircraft stacking. There may be safe procedures to against the commercial pressures to use that runway cope with stacks but that does not mean to say that as much as possible. It is a golden opportunity, now that airspace is more safe with a stack in it than it is that you have given the go-ahead to the third not with a stack in it. I think there are levels of safety. runway, to say, “I am going to reserve some of that capacity to increase resilience of the whole Q124 Ms Smith: Why does stacking make it less Heathrow system.” safe? Mr du Boulay: Because you have more aircraft in a Q129 Chairman: Mr Green, did you want to come in small area near to each other. Any errors that occur on this? you have more chance of hitting another aircraft. Mr Green: Just on the issue of stacking. Stacking or airborne holding has been in place for many, many Q125 Ms Smith: Could that be scientifically graded years, so we must not lose sight of the fact that it is in terms of the level of risk that that represents? a day-to-day operation that happens every hour of Mr du Boulay: I think you could do a risk the day when Heathrow is operating. Heathrow has assessment. There is very little data in the public more airborne holding than the other airports, domain that looks at stacks and says: What are the purely because of the runway scheduling around risks? What have been the airproxes in stacks? What Heathrow. It is scheduled to 98%/99% of its capacity. is the situation today versus a few years ago or many As a result, you need a pool of aircraft fairly near to years ago when there were not so many aircraft the airport in order to provide throughput on to the stacking? I have not seen the evidence one way or the runway. You could stop airborne holding tomorrow other that says whether they are safe or not. People simply by reducing capacity. In the future, with a say they are safe because there is a safe procedure third runway, I agree that we could hold back on the that deals with them, but procedures are run by amount of capacity by which Heathrow is grown, in Processed: 06-07-2009 18:36:56 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG1

Transport Committee: Evidence Ev 17

21 January 2009 Mr Rob Marshall, Mr Mark Green, Mr Andrew du Boulay and Mr Rob Gifford order to improve the resilience of the Heathrow concept of an aircraft flying in circles or absorbing operation for a start but also to reduce airborne any delay that is needed during the en route portion holding. There are concepts that are under of the flight, for instance by path stretching. development at the moment that are looking at replacing airborne holds with alternative measure. Q132 Mr Hollobone: Are there any major diVerences For instance, there is something called Point Merge, in RAF air traYc control procedures to civilian air which is an airspace design concept where you traYc control procedures? eliminate airborne holding through the use of Mr Marshall: The answer, basically, is yes. There is applied Precision Area Navigation (P-RNAV) adiVerence in that, traditionally, civil air traYc procedures. Ultimately, in the longer term, this is our controllers have worked a sector of airspace and all concept where you hold the aircraft on the ground the aircraft within that sector are controlled by one prior to departure, something called the Network or more controllers acting in group. Traditionally, Y Operations Plan, will assist in reducing airborne RAF air tra c control has been more of the system Y holding. But, for the time being, whilst Heathrow is whereby an air tra c controller would look after an being run at that level where capacity for demand is aeroplane or two aeroplanes or three aeroplanes, there, then stacking is an unavoidable occurrence. depending on the workload and the complexity of that operation. He would control those aeroplanes wherever they may be, and so it is not sector-based, Q130 Ms Smith: In terms of potential reductions in it is more task-based for a particular aeroplane on a emissions that presumably reducing stacking would particular task. However, I think now the military achieve, how much of a contribution do you think it system is moving more towards the civil system, so could make? Would it be possible to measure the that military controllers are now working blocks of potential contribution towards reducing emissions airspace rather than specific tasks. There is still a from reducing stacking? diVerence but that diVerence is getting closer. Mr Green: There is an ongoing project at the moment looking at taking the level at which aircraft Q133 Chairman: Do you have any specific UK hold and taking them to a higher level. For every examples of significant safety issues because of thousand feet that you increase the height the delays in increasing airspace capacity? aircraft is holding, the studies show that you reduce Mr du Boulay: I have not, no. It is a point I made in fuel burn by 2%—that is the fuel flow per hour gets my submission that the protracted process of doing reduced by 2%. Instead of holding, for instance, at an airspace change—similarly with an airport 7,000 feet, if you hold at 11,000 feet there is a capacity consultation too—means that you must potential 10% reduction in the fuel flow and end up with a period where the existing system has therefore in associated CO2 emissions. to cope with more and more planes until such time as that change occurs. To me, you are inherently ending up with a system that is more full of planes Q131 Ms Smith: But not holding at all would than it would have been if the change had occurred presumably increase the impact. and created extra capacity. To me, there is inherently Mr Green: The alternatives to holding could, for a reduction in the safety margin but I do not have instance, be path stretching, so that rather than any data or statistics to back that up. having aircraft flying a direct track, you had slightly Chairman: Thank you very much for answering our increases track mileage by the aircraft flying a questions. I am sorry that we kept you waiting. further distance. There is a trade-oV between the Thank you very much. Processed: 06-07-2009 18:37:27 Page Layout: COENEW [SE] PPSysB Job: 412381 Unit: PAG2

Ev 18 Transport Committee: Evidence

Wednesday 25 February 2009

Members present

Mrs Louise Ellman, in the Chair

Mr David Clelland Sir Peter Soulsby Mr Philip Hollobone Graham Stringer Mr John Leech Mr David Wilshire Mark Pritchard Sammy Wilson Ms Angela C Smith

Witnesses: Mr Tim Johnson, Director, and Ms Laura Simpson, Policy Coordinator, Aviation Environment Federation; Mr Lawrence Wragg, Chairman of Aviation Advisory Group, and Mr Michael Nidd, Technical Adviser to Aviation Advisory Group, Campaign to Protect Rural England; Mr Colin Stanbury, Aviation Adviser, and Councillor Serge Lourie, Leader, London Borough of Richmond upon Thames, 2M Group, gave evidence.

Q134 Chairman: Good afternoon. Welcome to our it was far too complicated for a lot of local authority Committee. Could I ask our witnesses to identify so-called experts to understand. NATS refuse to themselves, please, for our records? attend public meetings, although they did come to a Mr Johnson: Tim Johnson. I am director of the public meeting when we asked them to come to the Aviation Environment Federation. London Borough of Richmond upon Thames. The Ms Simpson: I am Laura Simpson. I am policy consultation did not apply even the CAA guidelines. coordinator for the Aviation Environment There were no alternatives given. For example, the Federation. possibility of stacking aircraft beyond the coast. Mr Wragg: Lawrence Wragg, chairman of the Finally, the CAA guidance itself is out of date, using Aviation Advisory Group of the Campaign to old research. Having been through it, the fact that it Protect Rural England. is going to be repeated suggests that that is right. Mr Nidd: Michael Nidd. I am a technical adviser to Mr Stanbury: They are the main points. The only the Campaign to Protect Rural England’s Aviation other point that I could amplify on that is that NATS Advisory Group on aviation matters. used local authorities around particularly Heathrow Mr Stanbury: I am Colin Stanbury. I am technical for the last airspace consultation almost as a clearing adviser to the 2M Group of local authorities on house for undertaking the consultation process. aviation matters. There were huge amounts of documentation Councillor Lourie: I am Serge Lourie. I am the leader delivered to local authorities with an expectation of the London Borough of Richmond upon Thames, that it would be distributed to local libraries and speaking on behalf of 2M. points of information. The problem with that of course is that the local authority oYcers themselves Q135 Chairman: Thank you. I would like to ask the were often not suYciently expert in the matter to 2M Group a question to start with. You suggest understand what was going on. The real diYculty giving ultimate responsibility for airspace change was when NATS were either not equipped to or were decisions to the Secretary of State rather than to the unwilling to attend public meetings to come and face CAA. How would this improve the quality of the people that were going to be aVected by these decision making? changes, to be on hand to explain the technical Councillor Lourie: At the moment the process is very, issues. That was the really diYcult point about the very closed indeed. We think there is a lack of last consultation. democratic accountability for airspace change decisions. Certainly the last consultation was a good Q137 Mr Wilshire: On this issue of how complicated example. Airspace changes are very significant in is the process, I notice that when pressure groups are that they aVect millions of people. Decisions of this trying to frustrate the improvements to an airport magnitude should really be subject to parliamentary they will regularly say that they have not been given scrutiny.The only way of doing that is to ensure that, enough information. Now we have the same sort of rather than the director of airspace policy making pressure group coming along and saying, “We are those decisions in private, they should be made by given too much information.” Which way do you the Secretary of State. What we want to do is to bring want it? the whole thing out into the open. Councillor Lourie: As a local authority leader—I see there are one or two former leaders here—it is very Q136 Chairman: How could NATS improve its diYcult getting the balance right. You do need to consultation process? provide full information. There are mechanisms for Councillor Lourie: We have been through the recent getting full information. It needs to be helpful, easily consultation and we found that it was really very digestible information. It is a complicated area. I do unsatisfactory. Colin is the expert so he may want to not dispute that, but I think the NATS consultation add to this, but the documentation was far too that we went through could have been simplified and complicated for a lay person to understand. Indeed, explained better. Most importantly—this is the point Processed: 06-07-2009 18:37:27 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG2

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25 February 2009 Mr Tim Johnson, Ms Laura Simpson, Mr Lawrence Wragg, Mr Michael Nidd, Mr Colin Stanbury and Councillor Serge Lourie about democratic accountability—we feel it is very taken into account when NATS submits airspace important that the people who know, in this case the changes. The question we ask is whether they have NATS oYcials, should put themselves above the relevance to today’s debate. We come up with the parapet and go to public meetings. We have a answer that they need to be expanded quite number of groups in our areas that are real experts dramatically. It is probably not appropriate for the in this subject and it is important that they can CAA or NATS to define those limitations or those question properly. environmental targets themselves. They have to be derived at a central government level and that is Q138 Mr Wilshire: I would not quarrel with you on what we would like to see. the question of attending public meetings. I think that is but a single issue out of all of this. As a former Q140 Chairman: Is the UK’s guidance on noise very V council leader, I know the frustrations you refer to. di erent from current practice elsewhere in Europe I have been there and got the t-shirt for that. This or in the States? whole issue of, “It is complicated. We must somehow Mr Nidd: It is our own. It is being brought into line reduce it to a level that, dare I say it, council leaders, with European practice as a result of the European MPs or Secretaries of State understand” is capable Noise Directive which I think was 2002/49. That of compromising all sorts of things, not least safety talks a lot about mapping environmental noise in and security. The very fact that it is complicated and respect of airports which have more than 50,000 air has to be in that form of huge amounts of detailed, transport movements a year and agglomerations, technical, expert information is probably the which is a lovely European word. I think they mean strongest argument I know for not letting politicians conurbations initially above 500,000 households V anywhere near it, because the analysis we will use and in 2012 down to 100,000. The di erence between will be based upon the way politicians think, which our current practice and the practice that will be is to humour the electorate, I suspect, rather than to required as a result of the European Noise Directive ensure the whole thing is safe and secure and is that all noise is mapped and characterised. The producing maximum eYciency. Have you not just noise which arises in the evening is measured, argued therefore that it is so technical that technical characterised and increased by a weighting factor of, experts are the sensible people who should be I think, four to allow for the slightly increased allowed to take the ultimate decisions? annoyance propensity. The night noise input has an Councillor Lourie: Absolutely not. I would entirely even larger factor added to it of 10 to indicate the refute that. One of the problems about experts is they even worse potential for sleep disturbance and the do get very expert and techy and talk in techy terms. health consequences that has. Here, there is no These are decisions that aVect millions of people. My requirement across all UK airports to measure night view of the consultation that was undertaken by noise at all. Some do. Heathrow certainly does, but NATS is that it could have been more not all airports are yet required to measure the noise understandable. More time and resource could have disturbance contours for night. They take a 16 hour been spent in explaining to eminent people like Colin day. That is what the book says and that is what Stanbury and others, who are techy people. It could they do. have been done much more simply and explained much better and it was not. It was unfortunate. The Q141 Graham Stringer: Which airports do not? point I made about decisions being taken by the Mr Nidd: London City certainly does not. Secretary of State, which was your original question, is a very important one. I do not think it is Q142 Graham Stringer: These are airports that have appropriate that decisions that aVect millions and night flights, are they? millions of people should be taken behind closed Mr Nidd: Yes. Sorry; City does not. City has a doors by experts. curfew at night.

Q139 Chairman: The Aviation Environment Q143 Graham Stringer: Which airports have night Federation have put forward a proposal for flights where the noise is not monitored? accepted thresholds for environmental impacts Mr Nidd: Most of the provincial airports. The big which, if exceeded, would invalidate airspace change three in London—Heathrow, Gatwick and proposals. Who do you think produce those Stansted—do. My own friendly, local airport does accepted thresholds and how would that work? but it does so on a voluntary basis. Mr Johnson: Without a doubt I think that is a role for the Department for Transport in taking advice Q144 Graham Stringer: It is doing it? from relevant other government departments, Mr Nidd: It is doing it but nobody,apart from the big including DEC, Defra and the Environment Agency, three I believe, is required— on their areas of expertise. In a way, it follows on very nicely from the point about the Secretary of Q145 Graham Stringer: I am not interested in the State having control. You need someone who is requirement. You made a statement that said some democratically elected. What is wrong with the airports do not monitor noise apart from 16 hours a current process is that you have perhaps out of date day and those airports have night flights in the other and limited guidance from the department to the eight hours of the day. I just wanted to know which CAA on the environmental impacts that need to be they are. Processed: 06-07-2009 18:37:27 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG2

Ev 20 Transport Committee: Evidence

25 February 2009 Mr Tim Johnson, Ms Laura Simpson, Mr Lawrence Wragg, Mr Michael Nidd, Mr Colin Stanbury and Councillor Serge Lourie

Mr Nidd: If it will help the Committee, we can whatever the line is, and Colin is much better at certainly send you in some written evidence about explaining it, but it just seems to me that there is a that. lot of evidence that people no longer will accept as tranquillity what was accepted as tranquillity previously. Colin, do you want to add to that in Q146 Graham Stringer: That would be helpful. Can technical terms? you tell us about your tranquillity maps? Mr Stanbury: You did ask was our noise Mr Nidd: Yes, a little. That particular area is in my measurement the same in Europe and, if you would general knowledge rather than in my specific like some more detail on that, I will try and assist the knowledge. I can tell you how they were derived, Committee. The answer to that is that, in a way, it is which may help. Tranquillity to CPRE does not just evolving. Our system of noise assessment is not the mean quietness. We are talking about all the other same as in Europe and Europe is tending to do its contributions to what the public perceive as being a own research, of which of course we take notice and tranquil scene. We are talking about landscape are aware, but we are very much still steeped, I fear, character, intrusions into it, manmade largely, of in policy which relies on social surveys and which noise is one. The work was done for us largely assessments that were done getting on for 30 years through some experts in the University of ago. This is one of the points that my colleagues here Northumbria, who interviewed literally tens of were making, that the benchmark, if you like, of the thousands of people. I suppose to an extent they CAA’s guidance in terms of when airspace changes might have been self-selected people because most of may be significant or not is actually rooted in the the interviews were done in places where you would results of social survey work that, as I say, goes back expect to find tranquillity, Areas of Outstanding over 30 years, and perhaps one of the most Natural Beauty, local view spots and so on. They unfortunate things that has happened in recent times were asked the simple questions: do you think this is is that a very far-reaching study that was a tranquil spot? How could it be made more commissioned, the ANASE Study, which my tranquil? What would be happening to make it less colleague on my left here referred to, was published tranquil? We got a whole range of answers from and the Department for Transport are unhappy, those ice cream vans over there. “Why is the place seemingly, with the way that that study was surrounded by car parks?” and, “It would be nice if undertaken. fewer people were here.” Out of that, this spot-by- spot-by-spot over the country,this mapping exercise, was done. Q150 Chairman: It had a very bad peer review. Mr Stanbury: And the peer review, that is absolutely Q147 Graham Stringer: That sounds to me like a the case, was not entirely favourable, but what it process that allows CPRE or anybody else does appear is that there are parts of that study that producing a tranquillity map just to say, “This is an can be in fact relied upon, and what the 2M Group area we don’t want any noise in”, so it sounds very is actually saying, and I am sure my colleagues here subjective to me. In your list, you did not list any will share this view, is that those parts of the study really objective criteria like decibels or frequency. that are considered to be in tact and robust should be Mr Nidd: I think there is quite a good reason for that reconsidered by the Civil Aviation Authority and the because what we are talking about is what is the Department for Transport in setting forward perception of the general public, not a specialist set standards for the future in terms of, if you like, of perceptions. response to noise, particularly aviation noise, because it is very much a step forward in terms of the current perceptions of people and their reactions to Q148 Graham Stringer: So it is subjective? aviation noise. Mr Nidd: Of course. Chairman: But it did get a bad peer review.

Q149 Graham Stringer: Just let me give you a bit of Q151 Mr Leech: First of all, can I, just for safety’s background. I have been involved in two or three sake, declare a non-pecuniary beneficial interest in a debates on the floor of the House of Commons piece of land at Heathrow, just to be safe. around discussing noise in Nottinghamshire and Mr Lourie: Perhaps I should have done the same! Leicestershire associated with East Midlands Airport and what the Members of Parliament say is, “Yes, there is less noise here than over Nottingham Q152 Mr Leech: I would like to talk about the CAA or Leicester, or Manchester for that matter, but this decisions and the appeals process. The 2M Group is a rural area and you notice every aircraft”. That have said that the judicial review process is limited in just seems to me to say that you should never fly an scope. What do you mean by that exactly? aeroplane over the countryside and that it is a Mr Lourie: I think that what we are saying is that, if subjective measure. the decisions which are currently taken by the Mr Nidd: I think there are some objective measures Director of Airspace Policy at NATS were taken though relating to the ANASE Study and the way more openly, at the moment to challenge a decision that the 57 decibel contours, it is not a contour, by the Director of Airspace Policy requires us to go Processed: 06-07-2009 18:37:27 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG2

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25 February 2009 Mr Tim Johnson, Ms Laura Simpson, Mr Lawrence Wragg, Mr Michael Nidd, Mr Colin Stanbury and Councillor Serge Lourie to court and have a judicial review and that is Mr Johnson: There is a very good model actually in actually quite a diYcult process and courts get quite France, an organisation called ACNUSA that sits confused. Mr Wilshire made the point about the between the Government and the aviation complexity and even courts get quite confused about community and provides advice to the Government these things and, at the moment, the JR is very much on just these sorts of issues, so they take evidence a theoretical tool for us. In other realms, like from industry and from community bodies and they planning or whatever, there is an appeal mechanism take those and make their own assessments. It and there are ways in which you can challenge comprises largely academics and independent decisions. experts and, although they do not have any decision- making powers, they have some powers of enforcement and they have some mediation powers Q153 Mr Leech: Can you make any specific and they do actually, as I say, make representations proposals for how you would like to see changes to the French Government on particularly large introduced? airport expansion decisions or on airspace Mr Lourie: Well, we have. In the email that was sent expansion decisions, and that would be something to you by my colleague, Eddie Lister, the Leader of that would be worth looking at. Wandsworth Council, he did make some suggestions on the lack of democratic accountability, and it was a point that was raised earlier, Chair, by your Q156 Mr Wilshire: This really leads on to where I questioning about who was the appropriate person want to go, this question of ownership of airspace. to make the decision, whether it should be made in CPRE suggested that the whole issue should be put some democratic form, and I know Mr Wilshire did in the careful hands of the Environment Agency, but not agree with that, but I do think there should be the issue that you just raised, Mr Johnson, of a some parliamentary scrutiny of decision-making mediation role, I suspect even I would be on your and, as far as I can see, and you may know better side on mediation on enforcement, a long way from than me, the best way of doing it is to get the decision-taking, and I think that is the key point. We Minister to make the decisions. had the issue, did we not, of one minute there is too much information, the next minute there is not Q154 Mr Leech: Have these representations been enough information, and we have heard again from made to the Department though and to ministers 2M that “collusion” is the word they wanted to get and, if so, what sort of response have you had on the record, though they say they did not really from them? mean it— Mr Lourie: We have made the representations to Mr Lourie: Sorry, I did not mean it. I really did not, your Committee and we thought that that was the so I apologise. appropriate way of doing it. We have not made immediate representations. We find that the Q157 Mr Wilshire: We have a situation there where Y Department is quite di cult to deal with, I have to one minute the Department for Transport talks to tell you. They always seem to be, and this is a point the people who own airports and that is somehow which was raised in the very good document improper and, if they do not talk to them, it is produced by the House of Commons Library, that somehow stupid that they have not consulted the there is a lot of, I would not use the word people who own airports and know more about “collusion”, that is the wrong word, but there is a lot them than anybody else probably, so we keep of to-ing and fro-ing between the Department, BAA coming back to that. We now get to a situation with and others and it does look to me as if there should the ownership of airspace where the CPRE is saying be some independent scrutiny of the decision- that it should be taken away from the experts and making. Certainly, at NATS we would like to see handed to the Department for the Environment. some external control preferably, I think, through Could the CPRE tell us what decisions would be your Committee or through Parliament. diVerent? What would be decided diVerently and what diVerence would this make in the future? Q155 Mr Leech: The Chiltern Countryside Group Mr Wragg: In terms of technical decisions, the suggested possibly introducing an ombudsman. decisions will be made the same way and will have Would you support that or would any other panel the same output. The issue that we see is that members support the introduction of an airspace, at the moment, is treated almost as a ombudsman? private good for the benefit of a limited number of Mr Lourie: I will not give you a quick answer, commercial interests, and we think that that is a superficially it sounds attractive, but we would have mistake and, when we argue that it should be owned to think about it. What we would like to do is to have for the benefit of the community as a whole or that some mechanism, and we are talking about airspace the Department for the Environment might be a policy.We would like to see some transparency in the suitable home for it, it is simply to bring a wider decision-making and some ability to question the perspective on the use of airspace so that it does not decisions with some independent body, and it may fall into the hands of people that you might regard well be that an ombudsman would be appropriate, as experts who simultaneously have a commercial but I have not really thought about it until now. interest. Processed: 06-07-2009 18:37:27 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG2

Ev 22 Transport Committee: Evidence

25 February 2009 Mr Tim Johnson, Ms Laura Simpson, Mr Lawrence Wragg, Mr Michael Nidd, Mr Colin Stanbury and Councillor Serge Lourie

Q158 Mr Wilshire: You say that it is for the benefit is simply that, at the moment, the motivation for of a limited number of people, but is it not the case proposals can be 100% commercial for people who that the people who benefit from the best use of are providing the travelling public with aeroplane airspace are the travelling public who want to do it services, and we are saying that there are more issues as safely as possible, as conveniently as possible and to be taken into account than simply operational as cheaply as possible? Are they not the people, eYciency for a limited number of airlines. ultimately, who matter? Mr Wragg: The answer to the first part of your question is yes, the travelling public does indeed Q165 Mr Wilshire: I would find that the argument benefit from it, but it imposes costs on the rest of the had a bit more credibility if it were an argument community which are frequently overlooked or, if about the planning process because, at the moment, they are not overlooked, they are not given the you hand over the decision-taking on the use of appropriate value. That is the reason. airspace to somebody else and yet you leave the arrangements in place where people can say, “You can build an airport, you can build a runway”, then Q159 Mr Wilshire: If you were to have your wish along later on comes somebody else who says, “Well, granted and the Environment Agency took this over, you built it, but you can’t use it because we’re not how would you be able to persuade me that the going to let you use that airspace”. Now, is not your Environment Agency would not compromise safety? way round, and I can see what you are trying to get Where would they get the expertise from to make the at, but is not this way of doing it the wrong way? final decision on any safety argument? Mr Wragg: We would very much like to see an Mr Wragg: I believe that the expertise on safety is integration between the use of airspace decisions and there. the planning process and we think it would be very sensible, for example, if somebody wanted to expand Q160 Mr Wilshire: In the Environment Agency? an existing airport, that they made sure, before they Mr Wragg: No, in the existing organisations, such as started putting various plans into an application, the CAA and NATS. that the airspace that would be needed as a concomitant were to be available. Mr Lourie: I wonder if I could comment on that Q161 Mr Wilshire: But they,at the moment, have the because it was an issue that we encountered in our right to say yes or no and you would be taking that away from them. dealings with NATS on the consultation, which we Mr Wragg: They would be given a better overall found very interesting. We were being consulted on directive as to the environmental consequences of the terminal control north proposal, but, because at what is being done than they have now, and this has the time we were in the height of the debate of the already been alluded to. At no stage do we or, I third parallel runway at Heathrow and the sixth suspect, anybody sitting here suggest that anything terminal and all that, we did ask if they could tell us should happen which would compromise safety. what was going on in terms of providing the airspace required for the massive expansion of Heathrow that was being proposed, and it was quite clear from the Q162 Mr Wilshire: But handing the decision-taking response that no work had gone on. I think one of over to the Environment Agency and taking it away the issues is that the White Paper and the way the from the CAA, would that not in itself put it in the Government operates does encourage a piecemeal hands of non-safety experts? expansion of a number of airports without reference, Mr Wragg: It was to make sure that things like particularly in the South East, to the amount of getting alternative proposals put forward to be airspace capacity, and it does seem to me that it is considered at the same time would happen when it putting the cart before the horse to say, “We will has not happened as it should have done recently. expand this airport or that airport” when there is a lot of pressure in the South East without actually Q163 Mr Wilshire: Who would decide which is the looking to see whether the airspace is available safest alternative if several alternatives were put under present technical conditions. forward—the Environment Agency? Mr Wragg: I do not want to speculate, but I would hope that nobody from NATS or the CAA would Q166 Mr Wilshire: That argument is again slightly put forward a proposal that was unsafe. flawed in that the Government’s policy decision on expanding Heathrow is but a policy decision and there is no planning application. Q164 Chairman: But it is a question of who is going Mr Wragg: Indeed. to make a decision and who is going to assess that, and the question Mr Wilshire is putting to you is why you think the Environment Agency is fit to be able Q167 Mr Wilshire: And, when the planning to do that. application comes to be considered by whoever Mr Wragg: The Environment Agency would not be considers it, then airspace issues will become part of deciding on safety issues because it has the CAA that planning process, so to suggest it is the cart there to do it, to provide it with the expert before the horse just is not fair. NATS make the information and, therefore, judgment. The question argument that to do the preparatory work until Processed: 06-07-2009 18:37:27 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG2

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25 February 2009 Mr Tim Johnson, Ms Laura Simpson, Mr Lawrence Wragg, Mr Michael Nidd, Mr Colin Stanbury and Councillor Serge Lourie somebody comes forward with a definite proposal withdraw it, but there is an issue about how these rather than a policy statement is not the way they decisions are made and the balance between want to work, but they certainly will do, and are economic benefit to the country and environmental doing now, the work for the planning process. This benefit. brings me back to the point I was making that the Environment Agency really I cannot see is the body Q171 Ms Smith: I was not talking about economic to safeguard some of these issues which, I accept, and environmental, I was talking about the reduced you are rightly concerned about, but surely it is the environmental impact of dealing with the amount of planning process? time that aeroplanes are circling in the air and Mr Lourie: My understanding, and I may be wrong stacking around an airport, reduced CO2 emissions and you may well be right, and I apologise if that is which can result from making better use of airspace the case, but my understanding, and I will turn to my through having perhaps an extra runway, but the colleague on my right here, is that airspace issues are downside of that may be increased noise levels not part of the town planning process, as we because of new flightpaths and so on. understand it, in local government and that that is Mr Lourie: Those balances which, rightly, the something entirely separate and is not considered as Government should be making and Parliament part of the planning process. Certainly, in all the ought to be monitoring. planning inquiries that I have been involved with, the airspace issues have never been part of it and it Q172 Chairman: Mr Nidd, would you like to give an does seem to me that it is putting the cart before the answer on that point? horse, that you expand an airport and then see Mr Nidd: Only perhaps to help Ms Smith or to whether you have got the capacity in the South East inform Ms Smith that one of the things we have been to do it. urging on our NATS colleagues for a long time is that the way they handle the air traYc is a bit short- Q168 Chairman: But NATS say that it will be too term and it is as though it suddenly pops up over the expensive to do that with every proposal. radar and it is there. They have just started doing Mr Lourie: At the moment, in south-east England, something which we have urged them to do which is as I understand it, the airspace is very limited. It is to, in eVect, take ownership of an incoming flight absolutely chock-a-block, although I understand miles and miles from the airport at which it is from colleagues that the recent reductions in air intended to arrive and to say to it, “If you carry on Y tra c have actually made things easier, but certainly like this, you’re going to arrive too soon and we will a year ago the airspace seemed to be very full. have to stack you. Back oV a bit and then you can fly straight in”. Q169 Mr Wilshire: I have just one last question on Ms Smith: I do not think I need any help on that! this point and then I will leave it alone, Chairman. Would you not accept, irrespective of what the Q173 Chairman: Mr Johnson, can you add to what legislation may or may not say on town and country has been said? planning, that Ferrovial, for example, are not going Mr Johnson: It is precisely on your point about the to part with £15 billion until they are entirely global versus the local tensions and whether you can satisfied that they can actually use the airspace for have both. You have got diVerent constituents out the new runway we need. there and the community will always be interested in Mr Lourie: Well, clearly, but you made the point noise. Increasingly, the Government will be about safety and clearly safety is paramount, but interested in the emissions side, airlines will there are disbenefits to people on the ground and increasingly be interested in the emissions side, and those are issues which, at the moment, do not get the inclusion of aviation into the Emissions Trading considered in the whole issue relating to airspace, Scheme will make sure that airlines will be saying to V and there are people who su er from aircraft noise NATS, “Design us a system that gives us the most and that is actually something that needs to be eYcient routes in and out”, but you have got to try considered. and reconcile that. I think, precisely because you have these diVerent pressure points, that the CAA Q170 Ms Smith: I just wanted to ask about the two and NATS taking that value judgment about which diVerent aspects of environmental impact which, I to prioritise over the other is inappropriate. It is think, need to be put on the table, first of all, that exactly why we argue that you have to have very eYcient use of airspace can lead to a reduced “sophisticated” guidance, I suspect, is the word from environmental impact, but it can though also lead to the Department for Transport, something which is an increased impact in terms of noise levels on local not just narrowly defined as, “This is the answer on populations, so, in the end, is it not a balanced view noise” and does not say very much on emissions, that we have to take, that the Government has to something which actually says that, in diVerent take, in terms of which environmental impact has to circumstances at diVerent times of day, there are be given the greater consideration? diVerent areas and there are diVerent environmental Mr Lourie: Absolutely, and that is why we think the pressures that have been brought to bear, and it Government ought to be making the decision. I used requires the Government to interpret that, taking the word “colluded” and then withdrew it, but advice from all of those outside bodies. The actually I notice it is in the report, though I still tranquillity point, Mr Stringer, is not just something Processed: 06-07-2009 18:37:27 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG2

Ev 24 Transport Committee: Evidence

25 February 2009 Mr Tim Johnson, Ms Laura Simpson, Mr Lawrence Wragg, Mr Michael Nidd, Mr Colin Stanbury and Councillor Serge Lourie that the environmental organisations advocate, it is which they have actually got no political guidance part of the EU Directive, but unfortunately they do on where they put those priorities and, for that not define it and they do not define high noise levels reason alone, we feel the Department for Transport for us either which requires the Government to has to be more forthcoming and actually telling both actually say, “What does that mean in a UK organisations what they have to achieve when context?” but there are a lot of environmental issues considering airspace changes. that NATS and the CAA are struggling with on Chairman: Thank you very much for coming and which they have no numerical outputs to put and for answering our questions.

Witnesses: Mr Christian Dumas, Head of Sustainable Development and Eco-eYciency, Airbus; Mr Kevin Brown, Vice President and General Manager of Air TraYc Management, The Boeing Company; and Mr Bruno Esposito, Director of Civil Air Transport, Society of British Aerospace Companies (SBAC), gave evidence.

Q174 Chairman: Good afternoon, gentlemen. Sorry performance with better schedule performance and to have kept you waiting, but I hope you found the fuel burn, and we have big programmes, like previous sessions of interest. Could I ask you please SESAR and in the US NextGen which are to identify yourselves. important, but we have capabilities on aeroplanes Mr Brown: Good afternoon. My name is Kevin today, like required nav performance, which have Brown and I am employed by The Boeing demonstrably shown that the system can be Company where I currently serve as Vice President improved today. One example is that we, Boeing, in and General Manager of Boeing’s Air TraYc partnership with the FAA and NASA and United Management Initiative. Airlines in the United States have been piloting a Mr Esposito: Good afternoon. My name is Bruno technique called “tailored arrivals”, trajectory- Esposito and I am the Director of Civil Air based flight arrivals where the aeroplanes come Transport for the Society of British Aerospace down at flight idle in very precise nav corridors. We Companies. have shown repeatedly that a 747 arriving at San Mr Dumas: Good afternoon. My name is Christian Francisco from top of descent will burn 2,800 Dumas and I am Vice President of Environmental pounds less fuel than a traditional stepped V A airs of Airbus and previously I was in the job approach with the very prescriptive approach of Project Director for the SESAR definition phase. corridors that are used in today’s system, so we are Mr Wilshire: Not a British subject among you! resolute in the belief that there is opportunity today and we are committed to supporting it. Q175 Chairman: Well, I did not like to mention that! Mr Esposito: The fact is that the business is Q177 Chairman: How do we compare with other global now. countries? Mr Brown: In the UK, I work very closely with NATS and I am very impressed. They are a very Q176 Chairman: We are glad that you think that Y progressive air nav service provider, they are very this is su ciently important to be here with us. In interested in not only improving the operational the evidence from Boeing, you do say there is scope utilisation of the system, but improving their own for improving the operational performance of internal performance by being leaner and more Britain’s airspace, as there is for many countries cost-eVective. We have diVerent challenges. In the around the world. Are you suggesting there that the US, our challenge is weather in the summertime, UK’s performance is worse than other countries’, principally, that disrupts our system. Your or what were you actually getting at there in the comment you made that there is scope for challenge, as I view it, here in Europe is that you improving the operational performance of Britain’s have a very fragmented system with 27 air nav airspace? service providers and a very small footprint, the Mr Brown: That is precisely my job for The Boeing harmonisation of civil and military airspace, and Company. You will notice that I called it an London Heathrow, in particular, being an airport “initiative”, not a business. My focus is outcome- that is tremendous in terms of its capacity driven to try to advance the state of the art of air operating out of a footprint which, I think, is of traYc management and not necessarily derive profit the order of about 4.2 square miles, to compare that from it. It is born out of our corporate belief that with the Washington Dulles Airport whose the travelling public fly because they believe it is footprint is 42 square miles. As a result, I think our safe and that we have an obligation to our airline costs per operation in the US are lower and I think operators and the communities to try to help make our flow management techniques, because we the system as operationally eYcient and as manage air traYc all the way across the Continent environmentally progressive as possible. We believe of the United States, puts us in a somewhat better this is a win-win-win opportunity where one can position in terms of the stacking that you have higher capacity and yet better environmental experience here at London Heathrow, so it is a very Processed: 06-07-2009 18:37:27 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG2

Transport Committee: Evidence Ev 25

25 February 2009 Mr Christian Dumas, Mr Kevin Brown and Mr Bruno Esposito complicated ecosystem and there are complexities emissions per flight by 10%. That being said, I agree everywhere that need to be considered, but lessons that, if the growth of traYc continues, the 10% on a we can learn. per-flight basis, it is not global, but still we have to do this and we have to improve air traYc control Q178 Chairman: In the evidence from SBAC, the permanently if we want to maintain sustainable Y Society of British Aerospace Companies, you seem growth of the tra c, but we will never compromise to be cautious about the introduction of continuous- safety. climb departures. Can you tell us more about that Mr Brown: If I could expand, and, Christian, thank and what assurances you would be looking for? you, I have been with Boeing for 30 years and it is Mr Esposito: I think that the whole topic about engrained in every employee’s DNA that the public aviation is to be replaced not only at an airport level fly based on a contract of trust that the system is safe, in terms of arrival and departure, but also with the and I am glad to see during my career, and I have airspace itself that needs to be managed. In order to enjoyed time spent on the 777 design development have a continuous-climb or descent approach, you programme, NextGen 37, and I have never seen a need actually to have a very eYcient and lean system decision made that addressed a safety item where the which is, what could be considered, data network- company did not commit to doing the right thing. centric where the flow of information is shared by We would be spoiling ourselves to do so. With regard many stakeholders and this form of information will to improving profit, we are dotcoms, both Airbus optimise not only the arrival and departure, but also and Boeing. I have to say to you candidly that we the airspace system, and that is where we are a bit have never mourned at the win of a sales campaign cautious. We are a bit cautious on the fact that one and we do look at aviation and, given where market has to avoid decoupling, as part of a whole system pressures want to drive it, aviation does want to that is needed on a global basis, one segment of the grow globally, but we recognise that, in order to do system because the eYciency and the optimisation that and to be both responsible and not subject to that you would get can only be there if actually all external constraints, we absolutely have to partner the players are able to contribute in an eYcient way. to address environmental and operational eYciency issues both with our products where we compete with Airbus viciously, but also in the operation of Q179 Mr Wilshire: I think it would be helpful if I, for our products in the global air traYc management a moment, played devil’s advocate and put to you system where actually Christian and I have known three arguments that are often levelled against not each other for seven years, are good friends, only aircraft manufacturers, but the people who colleagues, and collaborate on an advancement of operate them, just to explore this. There are the ATM solutions. We may compete as aircraft cynics who say that all you are really interested in is manufacturers, but we do not believe it serves improving your profits by making these sorts of anyone in the aviation community to not see the airspace changes, there are the nervous who say that whole advance in terms of the more eYcient, more what you are really going to do when you are trying repeatable, safer operation of our products in the to increase your profits is compromise safety by system. making these changes, and then there is the anti- Mr Dumas: There are three areas where Airbus and everything brigade who say that what you are, Boeing do co-operate and these are safety, air traYc ultimately, going to do by doing this is to increase management and environment where we really co- emissions, increase pollution, et cetera. Those are the operate. We signed an agreement, for instance, with arguments put against you. I am sure you have got them last years in Geneva. answers to them and it would be quite helpful to Y hear them. Mr Brown: On safety, air tra c management and a Mr Dumas: Safety is paramount for aviation. We little on the environment, we think we have got some could not even consider wanting to do something ways to do it a little better. that was not safe because this would actually spoil Mr Dumas: Yes, you can always do better! our business. Everything in terms of a safety problem is bad for our business, for aviation, and we Q181 Mr Wilshire: What is wrong with air traYc would never do anything that would spoil safety or management in the UK, which is what we are diminish it in any way. focused on, but also in Europe, if you like? What is wrong which needs improving? Q180 Chairman: You would not be tempted to Mr Esposito: Can I please go back to your initial save costs? question because I gave the floor on that. First of all, Mr Dumas: No. For us, safety is really the basis of I think that, as a conclusion of what my two the business. If I take, for instance, air navigation colleagues said here, I would like myself to add that service providers, their original mission is to ensure there is a tremendous need, in my opinion, to safe supervision of the aircraft. This is what they actually educate the public at large. Aviation is not used to do for decades and decades. Now, with the just going fishing, it is a way of life, it is a business growth of aviation, they have to provide better and culture and I can assure you that, as a pilot, each more eYcient services because they have to consider time I take an aircraft, safety is the key to the other aspects, such as making flights more eYcient, successful outcome of any mission, be it commercial more direct and less polluting, and I would remind or general aviation. The second aspect that I wanted you that one of the objectives of the SESAR to bring into the debate is the fact that yes, there is a Programme, Single European Sky Research, is to cut trade-oV, but the industry as a whole is investing a Processed: 06-07-2009 18:37:27 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG2

Ev 26 Transport Committee: Evidence

25 February 2009 Mr Christian Dumas, Mr Kevin Brown and Mr Bruno Esposito great deal, millions of pounds, on an ongoing basis descent approach or a steep approach or also one to actually accommodate and improve any eYciency that we call “low power, low drag”. The eYciency of that one can see, and that is around the climate this approach can only be applied and accommodate change parameters that you were speaking about what we are speaking about if the fragmentation, which are attached obviously to the eYciency of which I spoke of before, if there were a better use of doing a certain type of trajectory at a certain time the diVerent airspaces that we have to work in. To and even in certain weather conditions. In essence, I give you an example of that, because I can see a believe that, one, we need to educate people and, gentleman that is agreeing with that, if I were, as a two, the industry is making a great deal of pilot, arriving from France, I have two points of investment in order to ensure that what we are doing entry and I can only start my descent from flight level complies with the existing regulations and will even 250, so 25,000 feet, at a precise location when I am go further than the existing regulations in terms of handing over from the French air traYc control to climate change as we stand, and, last but not least, I the UK air traYc control. The optimisation of what believe that, if one key word could be extracted as I am speaking about is that I could actually start, still part of the aviation sector in any compartment of with the French, my descent, not touch, as a pilot, general aviation, commercial or military, it has to my power setting, reduce the noise, improve and be “safety”. optimise my drive by putting down my landing gear and my flaps at the optimum moment and also Q182 Mr Wilshire: I will go back to the second reduce the fuel burn, so a great deal can be achieved Y if we were to have a less fragmented airspace with question I asked, which is what is it about air tra c Y management in the UK and in Europe that needs less players and a better and more e cient flow of information in between all the stakeholders and not dealing with, needs improving? What is the problem? Y Mr Esposito: I would like just to state here that, just between the air tra c controllers, but the pilot unlike in the States, as Kevin has just observed, we on board and the airport as well on the ground. have to deal with what is still a completely fragmented approach. We have 27 nations, or more Q184 Mr Leech: So what model would you like to actually, that have their own service providers, their see introduced then to stop that fragmentation? own way of dealing, their own procedural way, and Mr Esposito: Well, I would like to use the model their own systems. If we want to be eYcient, if we which is currently under development, which is the want to optimise the route in traYc in terms of not SESAR model. The problem I have with the SESAR only capacity, but reducing CO2 emissions, I would model myself is that it will take too long to like to quote here that, if we were actually to apply, accommodate what the industry needs today. what we call, a “continued descent approach” in a Mr Dumas: If I may go a little bit further, the Y positive way on all the tra c in Europe only, we problem we have is that, if we want to reduce noise would save per year 492,000 tonnes of CO2 and if we want to reduce CO2, we have to find the emissions, so, because of the fragmented approach right trade-oV at every airport, every airspace level, that we have in Europe compared to other parts of et cetera, which means that, one way or the other, if Y the world, we are not optimising the flow of tra c, we want to move more traYc as well, we will have to and that goes also for the fact that, if were in the bring in much more automation to the ground SESAR Programme, and we will address that in systems and to the aircraft themselves. This cannot time, in planning better not only the departure and be done at the local level, which means that there the arrival, but the route trajectory, we will be also must be a global agreement, so Europe, but the US able to optimise a great deal not only the climate and more widely as well, to determine how we are Y change aspect, but also the tra c growth and going to introduce this automation into the ground accommodate it. and airborne systems. This is what we have tried, and achieved, through the SESAR Programme Q183 Mr Leech: What impact would those changes through the definition phase to bring all the have on noise? stakeholders together and to say, “Okay, guys, what Mr Esposito: In terms of procedure to address noise do we want to do?” and, I agree, it is a little bit late, abatement, you have several aspects to consider. The but we say that we can do it by 2020 and, until then, first is the climbing aspect when the aircraft leave the we shall do some short-term fixes here and there, but, ground, and of course the problem here is that you by 2020, we must have this not fully automated, but have the full power setting, for obvious reasons, and a much more automated system which will actually it is a factor of a lot of the aircraft. Traditionally, allow each airspace-user to fly the so-called what we tend to do today is to start the climbing, “preferred user trajectory” and that will deal with then to do a step where you stop your climbing and noise and that will deal with CO2. then to climb again and so on and so forth. If we Mr Brown: I think, Mr Wilshire, you asked the were to actually climb and use the energy of the question of what is wrong and Bruno responded, I aircraft in a better and leaner mode all the time think, appropriately with functional airspace instead of doing the step, we would reduce the noise reorganisation as necessary, but not suYcient, as and we would also optimise the eYciency of the Christian tried to draw out. Part of the problem is energy and, therefore, reduce also the fuel burn. On that the system operates today on 1950s’ technology, the arrival side, because I am assuming that we are radar surveillance of aeroplanes, voice speaking of close to the airport, to go back to your communication between ground air traYc control question, you have either to consider a continued and aircraft and fundamental assumptions that, Processed: 06-07-2009 18:37:27 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG2

Transport Committee: Evidence Ev 27

25 February 2009 Mr Christian Dumas, Mr Kevin Brown and Mr Bruno Esposito because of that, the system really does not know everything until the gate where you arrive. The where those aeroplanes precisely are, so there are problem, if I may say so, on airports, such as very prescriptive routings and separation standards. Heathrow, for instance, but Heathrow is not the only What SESAR anticipates and what we, as a one, is that the more you operate at full capacity, if community, can start moving towards today is in the process you have just a little something that relying on the fabulous navigational capabilities that comes to perturb your flow of traYc which is close are on commercial transport aircraft, and we have to saturation, this little something will have a greater talked about required nav performance and impact, so, although I agree with the management continuous descent approaches, and migrating expectation from an airline perspective, I also have towards a more information-centric system where to say that sometimes the airline knows that the pilot ground automation and aircraft automation, will start the engine and leave the gate on schedule ultimately, interact with each other. This is not going and something will happen and then you have to to be a flip of a switch and, with some of the pilots I basically manage a diVerent type of expectation. have alluded to that we have worked with with Airbus in and with the FAA in San Q187 Ms Smith: That will always happen, but the Francisco, it shows a little glimmer of what is point I am making still is that, at the moment, the possible today to start us on that journey and to key emphasis of the industry and the expectation of Y address some of the e ciency and environmental the passenger base is always the time of arrival at the concerns that exist today, so it is the combination, airport and the time of departure and, very organisational and technological; it all has to come frequently, to expect delays in terms of arrival and on. wait in the sky, stacking, for instance, around Heathrow, but would the new approach that we are Q185 Ms Smith: Going on from that, and I think talking about not shift the emphasis towards when that is absolutely right, that, ultimately, would lead you depart rather than when you arrive in terms of to a focus on arrival time rather than necessarily possible delays and so on? departure time in the future because the key thing Mr Dumas: I think it would shift it everywhere will be to have aircraft landing according to the because what we want to achieve is to have this schedule prescribed by the controllers and according network-centric system that will basically give all the to the information of that approach which you have stakeholders all the data regarding each flight, which just described. Would that not put a fresh onus on means that, when an aircraft has one hour to land, the airlines to manage much more successfully the we are able to slow it down a little bit or accelerate, expectations of their passengers? At the moment, the I do not know, or make a selection. If we have 10 expectation is purely about lifting oV and it is not flights queuing, why should this one land and not the about when they are coming down on the ground, so other one? Because it is the first, but we can change there would be a completely diVerent mindset and this by saying that this aircraft should land first culture in terms of how airlines function and how because it has some other priorities, commercial or they interact with their passengers. Is that not the whatever, compared to others. Through this case? permanent picture of data between the airport, the Mr Brown: Today’s system is very tactical. Airspace airspace and the airlines, we can improve the system. is divided into segments, you have a controller who Just to give you an example, you say that passengers handles the aeroplanes in that segment and then he are very geared to landing on time. Well, sometimes hands them over to the next controller. What I am I land earlier than expected and I am furious because talking about in this broadened information-centric I have to wait 10 minutes until the gate opens. This paradigm is that you push the planning and the should stop just by telling the airport to do better control out farther ahead. You will hear people talk planning and, if you get the data, you know when the about flow management, and flow management, aircraft is going to land. ultimately, for an aircraft will be gate to gate, and we will start driving the surprises down. If you look at Q188 Chairman: So you are looking for more London Heathrow, a very highly utilised airport, the integration? aeroplanes bank into Heathrow in surges from Mr Dumas: More integration of network-centric North America on the overnight flights and what I external data. am talking about is smoothing that out. Q189 Graham Stringer: I wonder if the problems Q186 Ms Smith: Well, that is exactly what I am that our previous witnesses were talking about and talking about. What I am saying is that the we have been discussing would be alleviated if you consequence of that is much more of an emphasis by made quieter aircraft. How close to the technical the airlines, surely, on smoothing the system out, but limits are you in making aircraft, both the frames it will mean managing your relationships with your and the engines, quieter? customers much more successfully because, at the Mr Esposito: That is a very good point actually, if I moment, they just expect to take oV when the airline may say. First of all, as I said earlier, the industry has tells them they are going to take oV and they face the been investing billions of pounds for years in order problem at the other end. to accommodate this aspect. Indeed, and Christian Mr Esposito: If I may say, not really. When you start is probably better-placed than I am because he is an engine at a gate, you start an engine at a gate from Airbus, but, if you look at the performance because you have got that part of your flight plan, achieved on the Airbus 380 in terms of reduced Processed: 06-07-2009 18:37:27 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG2

Ev 28 Transport Committee: Evidence

25 February 2009 Mr Christian Dumas, Mr Kevin Brown and Mr Bruno Esposito noise, it is simply staggering, and I do not lose sight not know how far we can go, but, if you look back of Boeing working equally on this type of aspect, so over the last couple of decades, I can think back to I believe that, from a technological perspective, we the 1960s of four-engine DC8s and clouds of black are actually looking at noise abatement as part of the smoke, low bypass ratio engines and water injection, airframe, as part of the propulsion, the engine, and if you want to go far enough back. We have made as part also of reducing the touch points with the tremendous progress continually on the engine landing gear. You know, the noise is simply an eVect front. As airframers, we made real advances in the of the drag that an aircraft will create while landing 1970s and continue today with each new product as at a certain altitude, given certain conditions, so a lot to how to package that power plant. I think you are of things have been done and a lot of money has going to see adaptive technologies, you are going to been, and is still being, invested and I believe that see chevrons on the cells of our 787 and those will with the latest development, if you look at the UK, become active in order to further reduce noise, and actually we are leading and we are at the forefront on I think we are becoming much more savvy on the big the technological development roles of the engine integration issues. Bruno talked about landing gear with what we call the “open rotor”, and that is not and we have been looking at putting fairings in there said enough. We have, as part of our own industry, a and how we can fix leading-edge wind noise and how leadership position which has to be maintained and to integrate the propulsion system with the airframe developed further in order to actually comply with, and optimise that as a package, so we have come a and accommodate, these types of needs with the tremendous way, and again noise is a diVerentiator limitations that we are facing. in sales campaigns. We invest heavily in it, I know Airbus does, and I think the push will continue. Q190 Graham Stringer: I accept that there have been terrific improvements made over the last 30 years Q191 Sir Peter Soulsby: I want to return briefly to with both the engines and the frames in the reduction something we touched on earlier about the benefits of the noise, but how much further is there to go? of the next generation of ATM and SESAR, which Mr Esposito: Well, from my perspective, I think it is obviously you all have considerable hopes for. I a trade-oV between how green one can be and what would just like to get clarification from you about implication it has on safety, and that is where the the extent to which it is possible to get those benefits trade-oV has to be, as long as one evaluates clearly through collaboration and agreement between the and analyses positively what we all want. You know, multiplicity of controllers that there are within the aviation sector is always depicted as people who Europe, to what extent it is dependent on integration do not care about climate change, but, if anything, of control within Europe to actually get those I believe that actually our industry is one of the top benefits, whether agreement and collaboration will industries in the world which cares very much and get at least some of the benefits and to what extent we are investing in doing that, so it is not just words. we have to have full or fuller integration to get all I believe also that safety is paramount, and we said the benefits? it before, so one could push further the boundaries Mr Esposito: From my perspective, I would like here of the latest technical development up to where you to restate in answer to your question before my start to aVect the safety issues. colleagues take the floor that there is a gap here, as Mr Dumas: I do not know where the limit is, but I far as I am concerned, which is that we have the just know that, if I had been told 20 years ago, “This SESAR Programme and that is bringing the is where you will be in 20 years’ time”, I would have technology that is necessary to accommodate the said, “Oh, my God, it will be diYcult”, but we needs and the requirements of our time, and then we achieved it. What I am saying is that in Europe we have another aspect which we should not, I believe, have the ACARE research objectives which are to lose track of and that is the regulatory reduce fuel burn and CO2 emissions by 50% implementation, the European Single Sky. Here, I compared to 2000 and noise by 50% as well, and we see a gap myself between what the industry would are working on those objectives. Whether we will like and could achieve and what, as part of this achieve them or not, well, this is in 10 years’ time, but fragmentation that we have in Europe, to target just we are working on them, and on the other side of the our region, we have to face. The fact remains that Atlantic they have similar objectives and engine today we have a gap in between how far one is manufacturers have an equivalent objective as well. willing to push the political will to accommodate This is our business to reduce noise and to reduce what one can demonstrate we could achieve and I fuel consumption and then CO2 emissions, and one think that, if we were to have a bit more political will kilogram of fuel on board a plane means as much and to push further on the regulatory aspect, what payload less and it is as much a cost for the airline, we would be able to deliver on the technical aspect so we have to work on this. This is part of normal would be saving time and complying a bit better with business. the needs of the industry. Mr Brown: That is a really important point. The direct operating costs of our products is one of the Q192 Chairman: When you say “political will”, are key diVerentiators in a sales campaign and this is a you talking about governments or European win-win for the industry because we understand that organisations? every pound of less fuel burned is lower operating Mr Esposito: I am speaking about both levels. I am costs, it benefits the environment and it is really a speaking of the European level obviously, but I am sweet spot. Relative to your comment on noise, I do also speaking of the national level, that the Processed: 06-07-2009 18:37:27 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG2

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25 February 2009 Mr Christian Dumas, Mr Kevin Brown and Mr Bruno Esposito

Government should actually perhaps emphasise a particular issues here, advanced terminal airspace bit more what we can achieve from a technical design and procedures. Again, I think there is a real perspective, and we have demonstrated a few things. opportunity to act locally and have a broader global If we are to achieve our target, we need actually to impact by continuing to press on with some of the have better compliance from the fragmentation that advanced technologies that we have talked about we were speaking of in terms of systems, procedures here, and I think step one of that is to find out how and so on in Europe, and that would actually assist to extract the value out of the capabilities of today’s the industry in being able to fulfil the targets. aeroplanes, and that is environmental and Mr Dumas: In Europe, we have the Single European operational, as there is fruit to be harvested. Sky Package 2 which, by the way, includes SESAR as one of its four pillar, so those go together. When Q195 Mr Wilshire: This issue of what opportunity the states can get rid of the SS package part, and this there is, I know I am risking putting words into is already done, they just need the agreement of somebody’s mouth, but am I right in thinking that SESAR through NextGen, but what I would say is the message that I am getting is that there is more that yes, we need some political support, especially capability in the aircraft you are now building than at this time of crisis because, for the time being, we existing air traYc control is making use of and that are looking a little bit at the short-term savings that air traYc control, if changed, could do more with we could achieve here and there, for very good what you have already got in the air? reasons and I am certainly not diminishing the Mr Esposito: Yes. impact of them, but we need to think a little bit Mr Dumas: Yes and no. ahead and develop our vision for 2020 and so on, Mr Wilshire: You would make a politician! which was done, so this is at the finishing phase with the so-called “2020 Concept”. We need some countries, some governments, to exercise some Q196 Chairman: Which is the yes? leadership, as was done in the definition phase where Mr Dumas: The yes is that short-term you are we, the consortium, went three or four times to meet perfectly right. There are a number of functions on the UK CAA, and discuss how we can get more board the plane that are not fully used or exploited involvement and more push from the UK because by air traYc control. Now, talking about the longer- you have got one of the most complex airspaces in term solution for 2020, the current aircraft, most of Europe and you are the bridge, in terms of air traYc, them, cannot do it. between the USA and Europe and we really need Mr Brown: I fully agree, but there are things we can political support from the political process to push do today. and not simply look at what will happen over the Mr Esposito: The problem we have is that we should next three or four years. We need to develop this, have a more pragmatic approach. what I call, “grand Victorian vision” for 2020. Q197 Mr Wilshire: Are the existing aircraft that Q193 Chairman: So it is vision and political cannot do some of these things “retrofittable” with leadership that you want? equipment? Mr Dumas: Yes. Mr Dumas: Yes, it is possible. Mr Brown: Yes, and I would also suggest, and this may be a little unpopular, that we need to migrate Q194 Sir Peter Soulsby: Are you actually optimistic from an air traYc management paradigm, the that that can actually be achieved? historical paradigm, which was first come, first Mr Dumas: What I would say is that some people at served, to a paradigm which says, “Best equipped, the time of SESAR said, “You are not ambitious best served”. I think there will be levels of service enough”, and to say we were not ambitious enough, based on the sophistication of the aircraft. there were some technical solutions and political Mr Dumas: If we do not do that, we will have real solutions that we dropped because they said, “No, diYculties in modernising the fleet because you will we have no chance to achieve this by 2020. What we have a mix of 6,000 aircraft, some equipped, some need is a date, so forget about technical solutions not, so what would be the incentive for airlines to and concepts, but we need to have planning, a invest in modernising their fleet or their cockpits? programme that this is what can be done by 2020”, and whether it will be 2020, 2021 or 2022, I do not know, I care less, but we are on the way, if I may say. Q198 Mr Wilshire: I would just ask one last one, if I Mr Brown: I resonate with Christian’s comments, may, to take advantage of the fact that we have three that the risk today is that we will all see the economic people here who are not British and, therefore, do decline, the reduction in capacity of aviation and the not have to automatically leap to our defence! We community will relax and this is no longer on the keep being told by people like NATS and others that front burner, but it needs to be on the front burner. British air traYc control systems are probably a I hope that Christian would agree with me that we notch ahead of everybody else’s, that we run one of are not moving fast enough and we were not moving the best systems, and it, therefore, aggrieves me to fast enough before this crisis hit. We talked about the have to say that we ought to give more power to big grand information-centric system of systems, Brussels because I am quite keen to take a lot of it and I think the opportunity for the UK is that the away, but, if we do this, if we do go down the route UK has one of, I think, the foundational work of some European integration, is there any risk that packages in SESAR and it is relevant to your we are going to dumb down what we currently do, or Processed: 06-07-2009 18:37:27 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG2

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25 February 2009 Mr Christian Dumas, Mr Kevin Brown and Mr Bruno Esposito are we right to be thinking, as Brits, that we do it from a manufacturing point of view, the UK is quite well and will other people listen to us if we start actually installed currently in a leadership role. joining in? What SBAC would like to see is actually us not Mr Esposito: I happen to believe that yes, the UK losing our key leadership position which could be industry on several fronts should be seen as leaders. over time fading away, if you allow me to use this From a regulatory point of view, NATS, in my expression, and taken on board by the newcoming opinion, is doing terrific work, and the UK airspace markets, such as China and others, so I believe that is one of the most saturated in the world, to keep the it is paramount that we do not give away to Brussels level of safety that we have, and let us not forget that some of our know-how just to sign a blank page aviation is one of the safest modes of transport, and here, that we participate and that we carry on the we go a long way by being innovative and applying ongoing dialogue, and that could be achieved a great deal of skill in achieving that. On the UK’s through pressure put on the political level with the capabilities in terms of manufacturing, we spoke Government and also all the stakeholders from a about what we are doing on the propulsion side, the manufacturing point of view or from an operational engine, but let us not also forget that Airbus in the point of view. UK is actually working alongside another very Chairman: Well, thank you very much. I think you important key player, which is Bombardier, on what have given us some excellent evidence, so thank you we call the “advanced material”, the composite, so, very much. Processed: 06-07-2009 18:38:01 Page Layout: COENEW [SO] PPSysB Job: 412381 Unit: PAG3

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Wednesday 4 March 2009

Members present

Mrs Louise Ellman, in the Chair

Mr David Clelland Ms Angela C Smith Mr Philip Hollobone Sir Peter Soulsby Mr John Leech Graham Stringer Mr Eric Martlew Mr David Wilshire Mark Pritchard

Witnesses: Captain Dean Plumb, Manager Technical Developments, British Airways, Mr GeoV Clark, Head of Flight Operations Regulatory AVairs, Virgin Atlantic Airways, and Mr Gerry O’Connell, Assistant Director, Safety Operations and Infrastructure, Europe, International Air Transport Association, gave evidence.

Chairman: Good afternoon, gentlemen. Can I ask a blip in the downturn for a 3% to 4% growth in members if they have any interests to declare? demand—so, largely speaking, a doubling of Mr Clelland: Member of Unite. passenger demand by 2030. Mr Martlew: Member of GMB and Unite unions. Graham Stringer: Member of Unite. Q202 Chairman: The evidence from British Airways, Ms Smith: Member of GMB. Captain Plumb, says that Heathrow is unfairly Chairman: Louise Ellman, member of Unite. discriminated against in the day-to-day Sir Peter Soulsby: I am a member of Unite as well. management of airspace. Could you tell us what that Mr Leech: Given the nature of the inquiry, I should means and what action you think should be taken? declare a non-pecuniary beneficial interest in a piece Captain Plumb: Certainly. I would like to answer in of land around Heathrow Airport. two parts, if I could. The first part is around what we would describe as avoidable disruption at Heathrow and the second part focuses on the actual Q199 Chairman: Gentlemen, could I ask you to management of the airspace in response to that identify yourself, please, for our record? disruption. The core of our concern is that Heathrow Captain Plumb: My name is Captain Dean Plumb, operates at 98.5%, largely, incapacity on a normal and I am Manager of Technical Development at day.It is incredibly vulnerable to any disruption and, British Airways. therefore, any pressure in the system, any Mr Clark: GeoV Clark; I am Head of Flight Y V ine ciencies in the system, really strike at the Operations Regulatory A airs for Virgin Atlantic operation at Heathrow itself. What we have seen Airways. historically is that a number of what we call minor Mr O’Connell: My name is Gerry O’Connell, disruptions would have occurred and have occurred representing the International Air Transport because of things such as flight paths, ad hoc use of Association, 230 member airlines, and based in the airspace which seemed to fail to recognise that Brussels. Heathrow has got such a constrained and such a pressured operation, and so we feel that actually Q200 Chairman: Thank you very much. Your there are some issues that we could address around industry is facing major problems at the moment, Heathrow airspace which would recognise more particularly in relation to large reductions in formally just how critical the operation is there. At passenger numbers and with high oil prices. Do you the other end of the scale are events such as the think that the Aviation White Paper’s forecasts for Presidential visit last year. That had an impact on the passenger growth will actually be fulfilled? operation which lasted for three days. It had a Mr Clark: Although you are quite right, I think we significant impact on both cancellations and delayed are seeing some extraordinary times at the moment, flights, a significant number of passengers were aVected and, of course, there is the cost to the airlines we feel that in the period of the White Paper, which as well, and with that extreme of disruption to such looks ahead to 2030, the projections still feel right to a pressurised airport, we feel that, potentially, there us and this is seen as a temporary phase. The is some opportunity in the future to look at other industry has always been cyclical, and this one is airports that might be better able to deal with that somewhat diVerent from the other cycles, but I think type of visit without having the same knock-on we feel content that the overall projections in the eVects. So that is the point in terms of disruption, White Paper are right. avoidable disruption. I wanted to come on to talk about the way that the airspace is managed, but I Q201 Chairman: Is that view shared? think there may be a couple of questions. Mr O’Connell: Yes. Captain Plumb: Yes, the same position for BA as Q203 Chairman: No, I would like you to answer well when our projections go out. We are expecting that. You have put in the written evidence problems considerable recovery of the current what we see as about the way airspace is managed, saying that Processed: 06-07-2009 18:38:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG3

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4 March 2009 Captain Dean Plumb, Mr Geoff Clark and Mr Gerry O’Connell

Heathrow is discriminated against. I would like to Q205 Chairman: That is the channel that you have know who you hold responsible for that. Is it NATS got, with NATS rather than anywhere else? or is it Eurocontrol? Captain Plumb: Yes, and, as I say, we are not in the Captain Plumb: Let me give you the background to same ground at the moment, but this is an impact on why we have made that statement. There is a Heathrow specifically and has a knock-on eVect to technique used in airspace management called a the local airspace, or perhaps in reverse in the way I “minimum departure interval” (an MDI). An MDI have described it. is an incredibly useful tactical tool, and what we are most definitely not calling for is the removal of that Q206 Mr Leech: If the airspace was managed to tool. However, to give you some background on how optimum capacity, what impact would that have on an MDI works, if you can imagine either weather or capacity on the ground at Heathrow? intense pressure on a sector of airspace causing some Captain Plumb: Heathrow on the ground is running pressure and causing bunching, what an MDI does more smoothly now, so Terminal Five seems to have is it slows down the rate of departures from an bedded in for us. The operation is still subject, airport, it deals primarily with weather and however, to a number of ground delays. It is at its bunching in the immediate airspace around an maximum capacity. Our take is that the airspace has airport. If that were to apply equally across the some historical ineYciencies. We could manage the whole of the London area, which logically should be airspace better, but there is no limitation in terms of aVected by airspace pressures and by weather the airspace, if I understand your question correctly, pressures in the same way, you would expect an even which stops us actually making best use of dispersal, but, looking back at the numbers for last departures from Heathrow. summer, we have got a very diVerent picture across the Heathrow Airport area and the other London Q207 Mr Leech: So there would be no impact on the airports. I have got an example, if I could share that actual capacity at Heathrow by improving the with you. Last July, which is the worst month in airspace. Is that the view you take? terms of amplifying the point, there were at Luton Captain Plumb: There probably is a link. It is quite only 12 MDIs imposed. You have got to remember detailed, and there would be, technically, quite a that an MDI is eVectively putting your thumb over Y complex link between the two. What I would say is a running tap in terms of the tra c flow; so whilst it that in terms of holding, stacking, at Heathrow, that stops the flow temporarily and eases the pressure in is a facility. Whilst we would like to avoid holding one area, actually what it creates is a lot of pressure wherever possible, what that does is that primes the on the airport itself; it creates backward pressure. So pumps at Heathrow in terms of getting a very Luton had 12 MDIs, Stansted had 29, Gatwick had eYcient landing rate, and actually your point in that 59, but Heathrow had 152 MDIs. If the principle is area is bang on the money: because if you have got true that this is a technique that is employed in the an eYcient flow of aircraft readily available in the immediate airspace and is not airport specific, then stacks to feed into Heathrow, then you get the most it seems to be a recurring pattern over the evidence successful landing rate. we have got here in terms of the last 12 months, it seems to be the same proportion of MDIs applied at Heathrow. Our take on this is that Heathrow has Q208 Mr Leech: Do the whole panel share that view? such a large proportion of the traYc in the south-east Mr Clark: In general, yes. Virgin Atlantic did not of the UK that it leads the decision-making process make the specific point in our written submission, to say that one quick hit at Heathrow can remove a but I think the points made by Dean are very lot of the pressure from the south-east. relevant and germane. What I would add to that is Unfortunately, the implication for that is that that, clearly, there are issues with the ground Heathrow is the single airport that is least capable of infrastructure at Heathrow which generate, for dealing with this backward pressure into the airport, example, holding following landing where there are so we do feel that there is disparity in terms of the use not enough stands and gates available for aeroplanes of MDIs. Our next concern around that is that, an to dock, and we know that it is an issue, and if we MDI being a tactical tool, we have very little can increase the airspace utilisation and increase the visibility about when MDIs are used. Certainly that movement rates, the ground infrastructure would has improved over recent months and is something inevitably be one of the choke points that would we are very grateful for, but in terms of a review have to be dealt with. process and in terms of repeated use of MDIs, we can see some patterns forming as well which kind of Q209 Mark Pritchard: You mentioned the suggest there are other problems with the airspace disruption at Heathrow due to the last Presidential that we are not really getting to the bottom of visit from the United States. Given that we have got because we do not have this review process. the G20 heads of government coming up on 1 and 2 April, people coming in from all over the world, (1) is there a working group between NATS, yourselves Q204 Chairman: Have you made any complaints as leading airlines and BAA and (2) even if there is about this at the CAA? not, what action has been taken to try and mitigate Captain Plumb: We have been in discussion with a repeat of the past? NATS. We have got a great relationship with NATS Captain Plumb: In terms of any working groups, I and we work, we believe, very eVectively with them, am not aware of any specific group. What we have but this is an area where the debate is still open. taken the opportunity to do is highlight the impacts Processed: 06-07-2009 18:38:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG3

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4 March 2009 Captain Dean Plumb, Mr Geoff Clark and Mr Gerry O’Connell of the Presidential visit last year, and that has been operational level be working with those agencies to fed into the DFT, is my understanding as well. try and minimise the disruption, but clearly it is not Clearly, NATS and BAA are aware of that and have an enviable position that we find ourselves in when their own data on the impacts as well. In terms of such events take place. what can happen for the future, I think we absolutely need to get the stakeholders involved and have a look at some alternatives. The Presidential visit is Q212 Mr Clelland: Can you explain why, on a high- unique, because the implications of the way the profile occasion like that, these high-profile visitors President moves has a number of knock-on eVects to should be coming into Heathrow anyway? Why do any airport he visits. It may be that the G20 is they not go to Brise Norton or somewhere like that? something that Heathrow is capable of dealing with. Captain Plumb: That is exactly the question we My initial reaction, though, is that I would have would ask, and we would support a view that says thought it would put the same sort of pressures on those alternatives should be looked at. the airport and that an alternative location may be Mr Wilshire: The three submissions you have made, better for all the parties involved. if I can summarise them like this (I think I am reasonably accurate): you do not like the strategy, you do not like the planning, you do not like the Q210 Mark Pritchard: Given that we are only a few decision-taking and you do not like the regulation weeks oV, is it likely that an alternative location is seems to be a theme from all of it. What does the going to be found? Certainly if there is not a working CAA and NATS do right? group, there could be, but, by definition, you would think the disruption is going to be greater, having 20 heads of government rather than just one, although Q213 Chairman: Who wants to answer that one? that 20 does include, of course, the President of the Throw us something positive. United States. It is not for you, really, it is for Mr O’Connell: If I could start, Chairman, on behalf transport ministers and for the stakeholders in of IATA. We are a global organisation, of course, but Heathrow, but you are the UK’s largest airline—it we recognise the airspace in the United Kingdom is does have a massive impact on you, of course, probably one of the most complex in the whole of depending on where Presidential aircraft actually Europe, and NATS does a very good job in lands—but can you give a guarantee that the managing the traYc volume. The CAA has very travelling public over 1, 2 and 3 April are not going important statutory responsibilities on safety and to see a repeat of the disruption that they saw on the these are discharged very eYciently. I think the point last Presidential visit, and perhaps Mr Clark might we are trying to make is we are looking at the want to comment as well? Transport White Paper at 2030 and we have to plan Captain Plumb: No, I cannot give that guarantee. head. It takes a long time to get the planning process What we would say, very strongly, is that we, like the right, and I think perhaps there are opportunities to travelling public, are a customer of Heathrow smarten up the process for changing airspace in the Airport and very much a customer of the service that United Kingdom, particularly in the south-east is provided there. We have a very strong view that we where the demand will rise as new runways are should not be disrupted, and we would stake the actually built. So our approach is not to be too same standpoint as the customers in that respect. I critical, our approach is to perhaps smarten up the was not aware of the timescale for the G20, nor am activities of achieving airspace changes safely and I aware of their travelling arrangements, so I do not more cost-eVectively. know what the impacts would be, but we would look to mitigate that in the future with every opportunity Q214 Mr Wilshire: Shall we hear from Virgin and we have got. BA? Mr Clark: Certainly.You made the point that I think Q211 Mark Pritchard: We do not have a transport you believe there are a number of negatives or things minister here, but, Mr Clark, if there was one here, that the airline or the industry does not like. I think what would you be saying in relation to what I the things that we do like are the professionalism of have said? the organisations as well. NATS are a very Mr Clark: I think what we would be saying is that we professional organisation, the CAA is a very would like to work with all parties, and that would professional organisation, and we have known that obviously include, in terms of Heathrow, BAA, it from working with them for many years and I think would involve working with NATS and the other in no way is that being challenged. What we are airlines, plus, perhaps, with MoD in terms of any challenging is the processes that bring all those military activity in terms of military aircraft together, whether that is consultation processes or movements, but I think what you are saying is what whether it is the way that, for example, the Director can we do to minimise that impact, and certainly it of Airspace Policy might work at the CAA or would be diYcult for me, sitting here today, to say whether it is the way that NATS might ultimately that passengers will not be impacted during the implement procedures, but when you bring all of period of that visit, assuming all the traYc is through those parties together and all of that activity Heathrow. Will there be disruption? Inevitably, I together, what we find ourselves with is an airspace would imagine, there will be, but we would want to change procedure that does not seem to be able to work very closely and I think (I hope I would speak cope with the demands of what we are asking it to for the majority of the operators) they will at an cope with and, particularly looking ahead over the Processed: 06-07-2009 18:38:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG3

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4 March 2009 Captain Dean Plumb, Mr Geoff Clark and Mr Gerry O’Connell next 20 years or so, will it actually meet the not need to go forward to consultation because they requirements, and I think that is where our concerns would not receive support. So, ultimately we would lie, certainly where Virgin Atlantic’s concerns lie. want to see positive change. We think we can do Captain Plumb: I would again echo the comments more right now. We are very happy with the people about the professionalism of the organisations we we are working with in the UK but actually we do are working with. We have had a very good believe we can move the processes on. experience with both NATS, CAA, in fact UK Military as well, which we mention in our submission. Where we are in terms of our view is that Q215 Mr Wilshire: Can I put to one side for a minute we look at the UK airspace as being incredibly the more general looking to the future. Let us stick complex, it is under pressure and it has grown kind with the little bit you said about the professionalism, of organically over many years and has some because in my mind I can see two things: what is historical ineYciencies. So, whilst the structures in going on now, which we need to be clear about, and terms of airspace change that we are working with then what happens for the future? Is there anything are populated by energetic and professional and that you want us to consider that your pilots are forward-looking individuals, what we do not accept concerned about? Forgetting it could be improved, is that we can improve the airspace or that we cannot but in terms of safety, security and professionalism improve the processes that we use, and actually, I of the moment is there anything that we should be think, in terms of the airspace change process, as an concerned about? operator we are sometimes frustrated. We know we Captain Plumb: At the moment, now, I have a high can do more but some of the airspace and some of degree of confidence in both the safety and the the change processes do hamper us slightly. There is security of UK aviation. You are asking a broad a slight irony that those processes are there to make question; it is a very broad, general answer. There are sure that change is carried out for the right reasons. no key airspace related issues that have a particular An example I would draw on would be most of my concern. Where I think our concern is as an time over the last couple of years has been working organisation is that we see current pressure and with airports on things such as noise disturbance, actually growth in demand which is going to put and I have worked along with . more pressure on the airspace, and that is why we are Manchester is one of the most forward-looking turning our gaze more to the future rather than the airports that I have had the pleasure of dealing with. current position. They take an evidence-based approach, they are forward-looking in terms of their engagement with airlines and what they have managed to do is to seek, Q216 Mr Wilshire: I want to come to back in a with their stakeholders, some very positive changes. One issue that even Manchester has suVered with: moment to that future, I just want to clear the decks there is a particular departure from runway 05, so it on the current situation if anybody does have a points to the north-east and requires a turn to the left concern. Mr Clark, do you? back towards the Wirral. It is called the Wallasea Mr Clark: Not around the safety piece at all. We are departure. The problem with that is it was drawn more than happy with that. We are only as safe as we many decades ago at speeds that aircraft simply do are today, but we do not have any concerns on that not fly at now. So for an eYcient departure, airlines front. I think it is really around where can we Y and pilots have to employ special procedures just to improve e ciency, where can we improve the be able to stay within the limits of that departure throughput of the system and what can we do? I track. It is the consultation process, is my know a lot of people have spent a lot of time trying understanding, and some of the processes around to work with the infrastructure that we have. We changing the ground track of that departure which know we only have a certain physical airspace to are causing a problem in terms of making what we work with, we know we have a certain number of would suggest would be a very positive change in airports and runway capacity to work with and we allowing that profile to be flown more easily and know what the aeroplanes in the modern fleets can more consistently. So we would point to the do, and many minds have been looking at that, but suggestion that says actually there is quite a it is really about squeezing the extra amounts out technical depth of information that you have to go that we can, whether it is making routings more through in terms of consultation processes. I know direct, whether it is reducing time in the hold prior to that many people are concerned at the level of landing, whether it is stopping ground delays at technical detail that has to be waded through. We Heathrow, Gatwick, Manchester, or wherever it would see a process that would be slightly more light might be. It is really about trying to maximise the of foot, which would see stakeholders involved and system that we have at the moment whilst, at the understanding that a pilot or a trial flight departure same time, having one foot and one eye in what is was being used and then we would go, at the end of projecting forward and what is going forward. We all the trial, into a consultation process that actually know that hopefully before many years have passed had some evidence, you understood the impacts and we will see more integration within the European you could actually see, with first-hand experience, airspace—and perhaps we will talk about that later whether the trial had met the aims that it set out to on—but at the moment we are really concerning achieve. Actually, I suspect we would find that some ourselves on where can we maximise what we are trials would not be successful and that they would currently working with. Processed: 06-07-2009 18:38:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG3

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4 March 2009 Captain Dean Plumb, Mr Geoff Clark and Mr Gerry O’Connell

Q217 Mr Wilshire: Can I stick with the current Q219 Mr Wilshire: One question on what you have situation for half a second? Is the relationship not just said, this question that our British air traYc now with the companies but with the pilots? Is the control system plays a big part. One of the concerns relationship between NATS particularly and your that has been expressed in previous inquiries and that pilots satisfactory,open and accessible to both sides? one hears from time to time is the possibility that Mr Clark: I would say certainly,and I think we have a going for common European standards might result very good working relationship at a pilot level in us dumbing down our existing standards. Is there between the pilots and the air traYc control oYcers. I any substance in the argument that the European think there is a good understanding. I think that standard will be lower? understanding has also built up over very many years Mr O’Connell: No, there is absolutely no evidence of where you have established bases—Gatwick, this. On the contrary, the process is to raise safety Heathrow, Manchester, as far as our operations are standards across the whole of Europe. If you look at concerned—and there is this very great trust in each the performance of other States, there are several other’s capabilities and each other’s way of working. shortfalls these are known by the authorities and Certainly we are blessed in the UK with a very require rectification. The objective of the Single proficient and professional air traYc control European Sky is to bring these states up to higher organisation. standards,standardswhich existhereinthe UKatthe Captain Plumb: We absolutely echo that. We run moment. So I see no evidence of dumping down familiarisation flights for air traYc control oYcers as standards. they run through their training, we take them into the simulator, and they reciprocate by taking our airline Q220 Mr Wilshire: Is that something that Virgin and pilots down to their ATC simulators. There is great BA agree with? mutual respect and it is an incredibly valuable Captain Plumb: Absolutely. exchange.Sowedonothaveanyissuesthereatall.We Mr Clark: Yes, we would. have an excellent relationship at a working level. Q221 Ms Smith: Mr O’Connell, the IATA has said that a national airspace master plan would be highly Q218 Mr Wilshire: If I move on to the broader issues beneficial. Why is an airspace master plan so of the future and ask the same question, what is the important? working relationship like between the airlines and Mr O’Connell: I think it is important for several NATS and the CAA when you come to discuss these reasons, one of which was mentioned in the White Y more forward-looking issues: friendly, di cult, Paper 2003, that there should be a master plan, and relaxed, or what? clearly the parties are working on that. I think the Captain Plumb: I would summarise it as professional. importance for this (and this is IATA’s submission), We accept that we do not always have common we favour a top-down approach, a forward looking ground, but we work on it in a professional way to strategic approach, which puts in place the projects to focus on the facts and move forward constructively, plan the capacity of the future. If we had this master and you would expect nothing less from an plan and the Airspace Strategy, we would then have organisation such as NATS and the CAA. I think the framework including the resources then we are in there seems to be a consensus growing to be a critical a very good shape to actually ensure that British mass which says actually our future in terms of UK airspace is fit for purpose in terms of the demand airspace is very heavy dependent on a successful which we predict will exist at 2030. It takes a lot of Single European Skies framework. We absolutely see time to actually do this. that if the UK is going to achieve its environmental and flight eYciency target, we really must be able to Q222 Ms Smith: In terms of a British national deliver on that, and actually we see a lot of support airspace master plan, how wouldthat dovetail in with from NATS and within the CAA for that. a Single European Sky? Mr O’Connell: If I can add, Chairman, yes, in Mr O’Connell: It would tailor in very well, because I Brussels the UK is very active in promoting safe and think the UK CAA and NATS are very active in cost-eVective Air traYc management, and it is very Europe. Indeed, they are a driving force for substantially engaged in all the programmes at the harmonisation of many developments in Europe. We technical,operationaland regulatorylevel.Wherewe would like to see this actually continued, because at do have to make improvements across Europe is in the end of the day my members (230 airlines) just look the environmental domain. Safety is very good; at Europe as one large block of airspace and, clearly, security is very good; however, there is a shortfall in the safety standards have to be the same throughout the environmental performance and we are looking all of Europe. So there are important connections forward to all the Member States coming up with including mechanisms which need to be made more eVective processes to design airspace, between the national master plan and the European harmonised at a European level, so that we can get airspace plan. I am comfortable that this can be done. similar procedures in use in most of Europe’s airspace, which is very congested and very complex. Q223 Ms Smith: NATS has begun scoping work on a So we wouldlike to see theseprogrammes accelerated future airspace strategy for the Civil Aviation and Single European Sky introduced perhaps even Authority. Are you satisfied that that work will meet faster than the dates which are being proposed at the your expectations for a national airspace master moment. plan? Processed: 06-07-2009 18:38:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG3

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Mr O’Connell: Before I hand over to my colleague, are designing airspace to the same criteria and with a perhaps, who have more local knowledge and view to introducing the new technologies which will experience of this, this activity is fundamental. We actually help us, these can only be introduced if there know that the design of airspace at the lower is a more holistic and more harmonised approach airspace levels has been done very eVectively, with across Europe. I do not know if my colleagues want Ministry of Defence and NATS experts designing to add anything. airspace. That is an essential component to making Mr Clark: Adding on to that, all I would say is that airspace safe and obtaining a fair use of airspace you mention the NATS Airspace Strategy. I do not between the various competing users oe. Indeed, this intend this to be a criticism of NATS, but from our is a model we would like to see rolled out across the point of view I do not think we have necessarily yet whole of Europe, but, again, Europe is not very been privy to that plan and that strategy—it may be Y smart at designing airspace e ciently at the network that this is still to come—and so I think it would be level, which is why one of the core elements of Single diYcult to comment on that at this stage. All I would European Sky II is the network manager approach, say, though, is we do support the master plan where we begin to move away from national concept, because otherwise we will continue with airspace. We must begin to design airspace at a more this piecemeal, fragmented airspace planning, holistic level of the network and, to take on board all potentially, even under the Single European Sky the demands which exist at six or seven major airport regime. We realise we have got to work towards this hubs including the congested airspace in Europe. master plan era, and it is still a plan, obviously, and Our view is this is the way forward and I have no there will still be aspects that will need to be changed doubt the UK will be very active in securing the and amended, but if we have a master plan which we correct balance between the network and the local use of airspace. can all work around, whether it is the operators or whether it is NATS themselves or whether it is DFT or CAA, or whoever, we all know which direction we Q224 Ms Smith: Are you suggesting that the UK are working in and I think it would dovetail in with could lead in terms of breaking down the barriers in what is trying to be achieved across Europe. terms of integrating European airspace? Captain Plumb: I would echo that. As yet, we have Mr O’Connell: What I am saying is there are some very good practices in the UK, which could be not, as part of British Airways, become involved in copied across the rest of Europe, which would those discussions around future strategy. We are actually help Europe to address very complex issues aware that some work appears to be going on in the about how we share airspace and design it safely. So background. We are mindful of the timescale. The there are opportunities, yes. requirement was initiated in 2003 and we still seem to be looking forward to another two to three years of scoping before we get some substantive output, Q225 Ms Smith: Do you believe that other EU countries, the rest of Europe, are prepared, are ready, and we would like, as a major stakeholder, the in fact, to work on this integration? airlines being major stakeholders in the use of the Mr O’Connell: I would certainly hope so. I know airspace, to be involved in a relatively short that the Single Sky Package II will place obligations timescale, and that engagement has not happened on the Member States to ensure that this is done yet. So we would echo that actually an overall more eVectively than the way we have done it in airspace master plan is a good thing for us to the past. achieve. It would allow us to set-oV the competing priorities for the airspace and the competing users of Q226 Ms Smith: There is clear evidence that this is the airspace and would give us an opportunity to the case. align with Single European Skies. Mr O’Connell: I think so, yes. Q228 Ms Smith: One last question. I understand that Q227 Ms Smith: What kind of things must be you think an airspace master plan is very important. included in the strategy to include airspace However there are risks in terms of achieving that, management, do you think? What do we need to see the obvious risk being lack of co-operation between in the master plan? V Mr O’Connell: Certainly the way we share airspace, the di erent European countries, lack of leadership, the way we look at congestion points. The south-east lack of identification of who the leadership of such a of England, is the second most complicated airspace planning process should be. How critical is the in the whole of Europe; so there are particular delivery of a master plan to the future use of problems in that area which can only be addressed airspace? What is the risk of not delivering such a by the experts who are familiar with the airspace. So master plan? when we are proposing more centralised Mr O’Connell: I think it is absolutely essential in management of airspace in Europe, we are not terms of the provision of capacity, safely and timly. saying, “Oh, Brussels is telling people how to design It is absolutely essential that this master plan is a airspace safely”, no, we certainly want a bottom-up robust master plan and is supported by the national process to actually secure the right expertise approach to the way we manage airspace. This enhancing the capacity into Heathrow, Stanstead element, together with the technical content of the and to Gatwick. This has to be done within a top- Airspace Strategy and including the necessary down process where, across the whole of Europe, we resources, is the basis for planning the whole of the Processed: 06-07-2009 18:38:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG3

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United Kingdom’s airspace up to 2030, which I Q233 Mark Pritchard: Two brief questions, the first think was the view adopted in the White Paper in one to Captain Plumb and Mr Clark. Firstly, the 2003. interface between civil and military aircraft use of airspace in this country.I would be interested in your Q229 Ms Smith: As professionals, what do you think comments on whether you think that is working the consequences might be if we fail to deliver? well, and talking about European integration and Captain Plumb: My view on that would be that we co-operation, Mr O’Connell, whether you think would simply stifle the growth. We would not be able some of the military restrictions over mainland to meet the demand in growth for Europe over the Europe airspace should be a little bit more flexible, next 20 years. We take a view that actually it is not the French military being an example, and, Mr the number of passengers that create pressure on the Clark, crowded airspace. Yes, there is an economic air traYc system and infrastructure, it is actually the downturn, but we have seen a sharp rise in the use of number of flights. They are broadly indicative, but it private commercial jets over recent years. That may is specifically the number of flights. We are expecting come back in the medium term. I do not know how the demand for flights to get up to between 18 and many private movements are out of Heathrow, but if 20 million flights per year by 2030. We do not have they were to be put in other airports, or designated the capacity to deal with that at this current time airports, or even non-major civil use airports, would with European airspace, so the status quo will not it be helpful or unhelpful and would it have a meet the demands for the future, probably not even revenue impact on somebody within the airport for the next five to 10 years, if the truth be known. family? Captain Plumb. Captain Plumb: I think your question to me was Q230 Chairman: And the impact on safety? specifically around the military civil interface. I am Captain Plumb: We would never actually an ex-military pilot, so I would absolutely support compromise on safety. We would rather a flight did the position that says we must invest in providing not launch rather than compromise on safety; so highly eVective training opportunities for our actually the backward pressure would be that we military pilots. Where we do come back to is that the would simply fail to grow our operations; we would UK airspace has grown up organically and there is a fail to meet the demand. natural jarring and competition for the use of what are limited airspace resources between general Q231 Chairman: The Competition Commission says aviation, military and civil. We have got some that the major problem at Heathrow is from over examples of where the interface maybe does not scheduling of flights by the airlines rather than work quite so well. We have numerous examples NATS. Do you agree with that? Very briefly, do you where individuals within the military are very agree with it? professional in their approach to the use of airspace Mr Clark: From Virgin Atlantic’s point of view, and actually give us back danger areas, for example, obviously we only have access to a comparatively to ease pressure on the system, but the structure that small number of slots at Heathrow, but we will we all work within has these historical problems, and maximise the use of those. We operate large so the examples I would give would be: we connect aeroplanes, for example, solely on long-haul routes, to the UK as a very important stepping stone for but it really is about working with both the airport transatlantic flights, and the organisation of flights operator, BAA, and NATS to try and ensure that we across the Atlantic is changed every day, there are can use every available second or every available spare inch of Heathrow to maximise the throughput. some set tracks. Those actually try to follow the best Clearly, we do not operate in isolation; we can only wind conditions and so are relatively flexible from operate to the requirements as laid down by both the day-to-day.What we do find is that UK civil aviation CAA, NATS and by the airport operator BAA; so is concentrated on the spine of the UK and actually we are operating within those confines, as the other there are a number of danger areas, and the Welsh operators do. Is it busy? Yes. Is it congested? Yes, but military training area, which, actually, given a blank it is safe, and I think we all learn to cope with the piece of paper, we would choose to fly straight foible that is Heathrow Airport. through those areas to get access to the most eVective and eYcient North Atlantic routings. So it Q232 Chairman: Captain Plumb, very, very briefly, is really important in terms of fuel and do you agree with the Competition Commission’s environmental performance because these are the Y conclusion in that respect? most e cient routings for the flights. We understand Captain Plumb: I would echo everything that GeoV why those areas are there, but my personal view is has mentioned. There is a partnership, so BAA plus that if you had a military planner, a civil planner and airport users and NATS actually decide on the a general aviation planner in a room and gave them capacity for Heathrow. We do see a time when the UK to carve up today, you would end up with actually any extra capacity that is added at some airspace that would look very diVerent from Heathrow, some of that should be garnered back for where we are now. So we are entirely happy with the what we would call resilience. We see instability in way that military airspace is given back and there is the operation because we are operating so close to some flexibility around that, but actually there is an capacity, and so, as additional capacity is added, a opportunity and a need to reinvigorate the work to proportion of that we would support being held see if there is anything else we can do to release some back for resilience. of these pressure points. Processed: 06-07-2009 18:38:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG3

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Q234 Mark Pritchard: Given the time, we will let the airspace is controlled airspace and uncontrolled French oV the hook for a change in this space. Mr airspace, and some of these barriers will break down Clark. with the new technology because to develop capacity Mr Clark: I think your question was relating to the safely we have to have certain capabilities in both the private jet operations, if I understood you correctly. air and the ground. Everybody who uses the network I think, certainly at Heathrow and airports like must have a certain capability to enable safety to be Gatwick, the larger airports, over recent years there assured, and as these concepts are rolled out into has been a dwindling in the number of private jet Europe up to 2020, we think technology has a huge operations and I think they have been squeezed out. role to play, not only increasing capacity and not I guess we are not necessarily against that. The issue only improving the environmental eYciency, where for us really has two parts. One is what is happening we have some diYculties at the moment, but also at the airports, and, clearly, we would advocate that addressing more optimum use of airspace, which we a valuable airport slot is best used by a larger think it is fundamental. aeroplane rather than a small executive jet type aircraft to maximise the throughput at the airport. So the airports are one aspect and, obviously, by Q237 Mr Clelland: Where is the problem here? Is it taking out those smaller movements, you do free up NATS? Are NATS failing to invest correctly? those slots for larger aeroplanes to use. However, if Mr O’Connell: I do not think, with respect, it is a you displace those business aeroplanes to the more case of any one air navigation service provider not regional airports, or airports that perhaps surround investing. One of the problems we have with the the London area—Farnborough, Biggin Hill, for absence of the Single European Sky is that there are example—they are still going to require airspace to 38 air navigation service providers in Europe. operate in and out of those airports, and so what we Consequently, there are 38 investment programmes finish up with is you are moving the problem perhaps in Europe, and, if all these investment programmes from a ground congestion or airport congestion are not aligned properly,we get the mismatch that we issue, in the south-east in particular, into an airspace have in Europe, which introduces many congestion issue. Those aeroplanes are still having to ineYciencies. This results in the unit cost of flying in arrive and depart from those smaller, more regional Europe 70% higher than in the United States. Of or business orientated airports, so moving them course, this is the reason why we urgently need a around moves the problem, it does not take the Single European Sky initiative to harmonise and problem away. integrate some activities as regards airspace management in Europe. Q235 Chairman: Do you agree with the Ministry of Defence, who say that uncontrolled airspace is being Q238 Mr Clelland: So systems are more eYcient in squeezed? other countries than they are here? Mr Clark: Can I pick up that question first? I think Mr O’Connell: I think, to be honest, it is diYcult to probably from a Ministry of Defence point of view, answer that question, because each of the 38 air I can see how it is being squeezed, because I think, in navigation service providers has their investment fairness to the Ministry of Defence, they have given programme. The importance of the SESAR project up more and more airspace to allow civil operations, is we begin to move towards a single concept of whether that is on a temporary basis or a permanent operation which means all the investment basis. I think the other thing is that there are certain programmes which will follow will be aligned at a parts of airspace in the UK where commercial flight fixed point in time, and I think there we will get the through uncontrolled airspace is carried out, all be it benefits in the future, but in the meantime we have to certain requirements, but I guess there is a to use the models we have, which in 38 Member sympathetic view towards the MoD’s position that States, I can assure you, it is a very complex actually they are being squeezed. We might argue operation managing the network in Europe. they are not being squeezed enough, but I can see why they might feel they are being squeezed, yes. Q239 Mr Clelland: Do you think that perhaps the Q236 Mr Clelland: I have some questions on new public private partnership in NATS is causing a lack and emerging technologies. You suggested that of long-term thinking? airlines could use technologies and techniques to Mr O’Connell: I do not think there is any evidence improve flight eYciency were it not for the outdated of that. NATS is engaged in its capital expenditure air traYc control procedures. What improvements planning and it responds to customer requirements can be made? for more eYcient airspace and, as a good air Mr O’Connell: There are a lot of developments navigation service provider, it will address the needs underway. There are certain navigation equipment of our members flying into Europe. capabilities, indeed, facilities we have on the aircraft Captain Plumb: I would add to that that our recent which could help the controller by more precise first-hand experience has been quite the opposite to navigation, particularly in terminal airspace, but the position you fear, which is actually NATS has there is also a very important SESAR project which some strong leadership, it has got some clear focus is now starting, and it is moving away from an and strategic focus and seems very energetic in its airspace based approach to a trajectory based eVorts to invest wisely in technology in the future, approach. The way we have historically used and the level of engagement that we have seen with Processed: 06-07-2009 18:38:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG3

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NATS on those subjects, in quite some detail, leaves that we can use airspace in a more environmentally us with a great deal of confidence that they have got friendly way with the use of this technology. I would their eyes on the horizon. hope that this programme could be rolled out across the whole of Europe. Q240 Mr Clelland: Can I ask about precision area navigation. Who or what has prevented the benefits Q243 Mr Clelland: Will future technological of P-RNAV being achieved in nuclear airspace? advances mean that you may have to change the Captain Plumb: P-R Navigation—eVectively it is traditional fixed departure time model you operate using technology that is already on the aircraft, and in order to improve flight eYciency? most Western built aircraft over the last 20 years, I Mr O’Connell: To improve flight eYciency many would suggest, are capable of these navigation things have to be done of which use of equipment is standards. What we have seen over the last 20 years one. CDAs is another aspect. Eliminating is an increase in navigational accuracy but most of congestion points in the network at European level our air traYc and routing regulations are not given means a more harmonised approach to the design. credit for that. We have been slow to take full All of these elements have to be done in a sequenced, advantage of this increasing capability but now new packaged way. We want a single set of operating standards have emerged so we have a standard in P- procedures for our pilots when they fly across RNAV which allows for arrivals and departures at Europe. I do not know if you want to add anything? airports an accuracy—it sounds bad—of only plus Captain Plumb: I did not quite hear the question. or minus a mile. The demonstrated accuracy is much Was it fixed departure times or points? more accurate, especially with GPS equipped aircraft. You are talking about accuracy in tens of Q244 Mr Clelland: Yes. Would the traditionally fixed metres. The promise that P-RNAV has for us for the departure times you operate at the moment have to future is that you remove reliance on ground based change in order to improve flight eYciency? navigation aids and infrastructure. It is much more Captain Plumb: The fixed departure times that we flexible in terms of being able to redesign, make run on our schedule at the moment are just a small and more frequent changes to procedures to statement of intent. The reality is the operation is Y try to fine tune the e ciency. It allows the pilots to incredibly flexible. start thinking in 4D which is positions and times over specific geographical or weigh point features. The promise is of more eYcient use of airspace with Q245 Chairman: What makes it flexible? We were P-RNAV. told by NATS that technological changes would mean that take oVs may not be able to happen until landing slots were known to be available. Is that the Q241 Mr Clelland: Should the operations at major reason that there is flexibility now or is it airports be limited to those aircraft which have top something else? quality navigational systems? Captain Plumb: That is a development that I have Captain Plumb: There is certainly an argument that not been aware of. says there is a minimum standard, a threshold below which an aircraft should not operate into congested airspace. There should be a mixture of both safety Q246 Chairman: That was the point that was put to systems and navigational systems and ultimately us when we visited Swanwick last week. communication systems with ATC as well. Most Captain Plumb: I am sorry; I do not have anything western built aircraft fit those criteria quite easily to add. and indeed most European and east European Mr Wilshire: I find it fascinating that what I have aircraft as well these days. Those standards are very always believed to be a timetable is nothing more well monitored by the CAA and I do not think there than a wish list according to the evidence we have are too many aircraft that would fail to meet those just heard. Have you any plans to retitle it and stop requirements. calling it a timetable?

Q242 Mr Clelland: Should the CAA insist that Q247 Chairman: Let me ask you about the airspace airspace designs must make optimal operational use change process. All of you in your evidence make of this equipment? suggestions about changes in the way in which the Captain Plumb: The opportunity here is to use P- airspace change process is dealt with. Could I ask RNAV much more widely. It is a very flexible tool. you all very briefly to say what is the most important Our own area is getting to grips with P-RNAV and change you would like to see? all the opportunities that that oVers and there is an Captain Plumb: From the BA perspective, we think increasing roll out of P-RNAV procedures. We there is positive change that we can make right now. would like to see that accelerated and we would like We feel that there should be greater ability to access to see much greater emphasis on it because of the pilot schemes, trial routings and do those with flexibility of it. stakeholders, who then do those ahead of any formal Mr O’Connell: At the European level the SESAR consultation. We feel it is a more logical sequence of master plan which we hope the Transport Council events to achieve. will adopt in Brussels at the end of this month, has a first implementation package where PRNAV will be Q248 Chairman: Mr Clark, is there any one thing one of the elements, this will give us the assurance that you would highlight? Processed: 06-07-2009 18:38:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG3

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Mr Clark: We would like to see the process which that was first mooted is now largely obsolete because involves the consultation activities and how that is the environment is much higher on everybody’s then carried through in terms of how that is agenda within the industry. In terms of the Secretary ultimately managed. We find the process complex. of State, perhaps in the most diYcult of decisions We observe it to be complex. Clearly there have to be there is a place for that role. I would be concerned safety regimes in place to make sure that it is though. Why are we looking at airspace change adequate but we feel a lighter touch could be used in policy? We are trying to get the best, most eYcient the way that airspace changes are introduced and change possible. What I would be concerned about planned, so a lighter touch and less complexity is an attempt to use a tool to stifle change. That should be possible. would be my concern about the wrong approach or Mr O’Connell: I would like to support my the wrong level of decision making. colleagues: more of a top down managerial approach, evidence based, which gives you the Q250 Chairman: Do any of you have any additional assurance that not only is safety being met but thoughts on changes you would like to see on the environmental eYciency can be improved. We have relationships between the military and civil aviation to make a bigger eVort here. to improve route eYciency? Is there any specific thing you would like to see? Mr O’Connell: There are very many good practices Q249 Chairman: It has also been put to us that the which exist in the UK at the organisational level and CAA’s decision making responsibilities should be in the way civil and military work together to design transferred to the Secretary of State for Transport or airspace so they can meet their own needs. This is a to the Environment Agency. Do any of you agree model which could be rolled out across many parts with that? of Europe where such proximity does not exist. It is Mr O’Connell: This is such a specialised area. The very important to get the environmental gains. We Civil Aviation Authority has built up a lot of need the experts to sit down to design airspace in a expertise in managing and changing airspace. It is a professional way. This is an area where Europe could complex area. It involves interfaces with general make lots of improvements. Also, within the United aviation, the military authorities etc., and we would Kingdom itself, as we move towards greater like that to be retained. Obviously it is a centre of environmental requirements and shorter routes, we expertise. If we were to go into parallel processes have to have a smarter process in place for airspace outside of that, there is a risk of complicating changes and use certain certain capabilities, both in decision making and not getting the improvements general aviation and in military and commercial we would like in terms of a smarter airspace change aviation, so that we are all assured that the highest process. IATA’s view is that probably the Civil safety standards can be maintained. That requires a Aviation Authority is best equipped to manage lot of planning and a lot of support processes. these issues. Captain Plumb: In terms of military airspace used, Mr Clark: I think it should stay with the CAA. there have been attempts in the past to try to get a Captain Plumb: The point, as I understand it, for the better balance and meet the needs of both military Environment Agency becoming involved was a and civil aviation users. We would welcome any concern that airspace decisions are 100% eVort to reinvigorate that and also for the structure commercially biased. Our view is that that has never and framework around that and a national airspace been the case. We have always had this balance to policy and strategy would be a useful vehicle for strike between commercial decisions and safety that. We would be entirely satisfied that that would decisions. Over the last two years airlines—Virgin be a good formula for being able to strike those and BA and also airspace providers such as NATS— balances. have taken on formal, public commitments towards Chairman: Thank you very much for coming and their environmental aspirations. I believe the reason answering our questions.

Witnesses: Air Vice-Marshal Tim Anderson, Assistant Chief of the Air StaV, and Air Commodore Mark Wordley, Director, Defence Airspace and Air TraYc Management, Ministry of Defence, gave evidence.

Q251 Chairman: Good afternoon, gentlemen. Could Q252 Chairman: The written evidence you have I ask you to identify yourselves, please, for our submitted gives us the impression that you are very records? well represented in airspace policy making and in air Air Vice-Marshal Anderson: I am Air Vice-Marshal traYc control. Why do you feel that you have Tim Anderson, Assistant Chief of the Air StaV, concerns? Do you feel that you are not represented Royal Air Force, and also the Secretary of State for enough or that decisions are taken away from the Defence’s representative in the Civil Aviation areas that you are involved in? Authority as a non-executive member of the CAA Air Vice-Marshal Anderson: I would not wish the board. evidence to suggest that we have concerns. I think Air Commodore Wordley: I am Air Commodore the balance would be more in the other direction in Mark Wordley and I am the head of the Defence company with the evidence you have just had. We Airspace and the Air TraYc Management would regard the relationship we have with the other Organisation. stakeholders in the aviation community, particularly Processed: 06-07-2009 18:38:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG3

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4 March 2009 Air Vice-Marshal Tim Anderson and Air Commodore Mark Wordley in terms of airspace and air traYc management with particularly in security terms. The role of the the Civil Aviation Authority and with NATS, in a military in this area is basically to facilitate to the very positive light. If there is concern it is more that best of our ability and within the resources we have the direction of travel, if you like, of air transport available that movement. Direction will come from and aviation in general will inevitably place stresses government, the Foreign OYce, but not directly on airspace and on airspace structures and we would from the Ministry of Defence. In the majority of clearly wish to ensure that our say in how these cases, we are basically a supporting act here. In terms structures are developed is maintained at the sort of of could the aircraft land at Brise Norton, physically level that it is at the moment. The level it is at, at the yes, it could. Would that meet all of the various moment, I think is very satisfactory. requirements of a visiting head of state? Would it meet the requirements in protocol terms and so on of Q253 Chairman: Are there any changes in our own government? I am not at liberty to comment institutional and consultative arrangements that you on that. would like to see? Air Vice-Marshal Anderson: No. The structures at Q255 Mark Pritchard: In airspace terms, would it the moment are better than fit for purpose. The disrupt military operations? It certainly seemed to Ministry of Defence is integrated across the disrupt civil aviation operations. hierarchy of policy and regulatory bodies in the Civil Air Vice-Marshal Anderson: I think it would be Aviation Authority.Our relationship with the licence reasonable to assume that it would by virtue of the holder, with NATS, is exceptionally good. We are nature of the flight and the procedures that we would already involved quite eVectively in Europe and put in place. increasingly so. We have good visibility of developments in terms of policy in that area. I could Q256 Mark Pritchard: You are the Secretary of not point to anything at the moment which I think is State’s representative on a lot of transport issues, as a critical flaw in the structures or which we feel we you outlined in your introduction. In principle, are not being adequately represented in. That does would you have any objection if there was a working not mean for a second to suggest that everything group set up for future heads of government goes our way or we always get what we want, but I certainly when they are coming en masse to look at think we have rarely ever come away from a decision other locations and minimise impact on the point thinking that we have not been fairly heard. travelling public? Air Commodore Wordley: To complement that, I Air Vice-Marshal Anderson: In principle I have would say that we are seeing signs that our military absolutely no reservations in supporting whatever requirement and position is being taken into account the government requirement is. to an even greater extent. The example I would give is the development of the Functional Airspace Q257 Mark Pritchard: I am sure the Secretary of Block, one of the European initiatives. From the State for Defence has noticed that as well. Moving NATS perspective and the UK perspective, civil on to wind farms, I am aware that wind farms clearly side, there was an immediate recognition that a lot of have an impact on radar and the Ministry of Defence the work would not be able to be moved forward do from time to time object to planning applications without military representation. I have been invited for that very reason and perhaps others. I just and I sit on the management board of the UK/ V wondered whether you could think of an example Ireland FAB and a number of my sta sit on the where an application that the MoD has objected to various working groups which inform the MoD’s has subsequently been approved and what training requirements but also contribute to the wider debate and/or operational impact that has had on your to ensure that the UK’s interests in the European operations. agenda are met as far as possible. Air Vice-Marshal Anderson: As far as prior objections being removed, that is a factor of the Q254 Mark Pritchard: First of all, a personal particular environment that you are describing. The comment. The RAF are very welcome in Shropshire. eVect that wind farms have on radar and other parts RAF Shawbury neighbours my constituency but of the environment is not a well understood science. with landing zones in my constituency. We welcome It is something which the UK has taken a lead in. We you there in the county. We heard earlier from one of were the first to identify that this phenomenon the witnesses that the visit by the American President existed. To the extent that relatively limited last year caused huge disruption at Heathrow and a resources have allowed, we have explored the impact lot of it was covered in the media. One of my of wind farms on radar capabilities. Whilst that colleagues suggested perhaps moving that sort of body of knowledge has been building and whilst we flight, with the G20 summit coming up and the have been able to develop particularly the scientific potential for more disruption. Is there any military basis of that body of knowledge, in terms of national reason why visiting heads of government could not security the principle has been “better safe than land at Brise Norton and therefore minimise the sorry”. In other words, where there is a doubt about disruption to travelling passengers at Heathrow? the eVect a wind farm might have for example on the Air Vice-Marshal Anderson: I think the movement of airspace picture for the United Kingdom, we have any VIP, head of state, etc., depending on who they tended to seek more evidence or suggest that this are and under what circumstances they are moving, would not necessarily be a sensible thing to do at this will have a multi-faceted equation to solve, stage. Having said that, particularly recently in the Processed: 06-07-2009 18:38:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG3

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4 March 2009 Air Vice-Marshal Tim Anderson and Air Commodore Mark Wordley last 18 months or so, I think things have moved anywhere near the point yet where we can release forward in a very positive vector, partly because the these things into the airspace and assume that they degree of understanding—the scientific basis and so will be able to look after themselves and not bump on—is being enriched by some of the work we have into anything, but there are some pleasing results been doing and partly also by an increasing coming out of that work which would give one willingness, not to take risk, but to at least confidence that the move from totally segregated acknowledge the very real imperative of the airspace into a more integrated approach within government’s renewable energy targets and so on controlled airspace for example is not the stuV of and the role that wind energy will play in that and the pipe dreams but is something which is potentially fact that we all have to exist on this island together. within reach. Operationally, it is of little We have been more relaxed, shall we say, in terms of consequence to us because normally, when we are some of the restrictions that we would put in place operating as the military with unmanned air recently. systems, they are in operational airspace and the rules and constraints are somewhat more relaxed in Q258 Mark Pritchard: Given that the Ministry of that environment. Defence has not necessarily won every argument in every case, surely that has had an impact? Otherwise, Q261 Chairman: Could you tell us what percentage logically, you would not have made the argument in of UK airspace is currently available to the MoD as the first place. Therefore, what impact has it had? class G? Air Vice-Marshal Anderson: I may have Air Vice-Marshal Anderson: It is quite a diYcult misunderstood your question. I thought it was a case question to answer. Some 60% of the United of us putting an objection in and then rescinding it. Kingdom’s airspace is controlled airspace. I use that There are occasions where we have done that. 60% in the two dimensional sense. Of course, it being the air environment, there is a third dimension to Q259 Mark Pritchard: No; where you have lost the take into consideration and outside of the controlled case. airspace there are local areas of airspace that are not Air Vice-Marshal Anderson: There are examples of class G. For example, the restricted zones round an that by virtue of, in some cases, not being aware that airport or some danger areas or even some areas of a wind farm application was being approved locally particular natural significance. It is certainly no or whatever. We have been visited with wind farms more than 40%. It is probably considerably less and on our doorstep which we have had to take also not all class G airspace is the same. By virtue of mitigating action about. In the cases that I am aware the topography as far as the military are concerned of, this is more local disruption, having to amend and what sort of training we get there, by virtue of traYc patterns around an airfield because a some of the other environmental phenomena, not particular area in the vicinity is troubled by wind least the weather factor, there is better quality class farm interference. What we have not experienced is G airspace than others. any degradation from a national security perspective in the overall airspace picture in the UK. Where Q262 Ms Smith: Are any sections of airspace ring these impacts have occurred, they have been fenced so that they could not be converted into relatively local. I would not wish to diminish the controlled airspace under any circumstances? impact but it is manageable. Air Commodore Wordley: No. I do not think that is the case. The UK takes the position from a Q260 Mark Pritchard: Finally, UAVs. It is not only government endorsed joint and integrated approach Y military Unmanned Aerial Vehicles, but also a to air tra c management that we look at the growth in civilian use for mapping purposes and airspace as inclusive, for anybody to use. In the other purposes. I just wonder what your view is on extreme case, it could all be controlled airspace or it the growth of UAVs and what impact, if any, it has could be completely the other way. on your operations, both military and civilian UAVs. Q263 Ms Smith: Given what you have just said, in Air Vice-Marshal Anderson: The growth is your written evidence a statement was made about happening before our eyes. It does not mean to say the initial balance of conflicting priorities and that that the skies are full of them yet but we are moving these should first and foremost be in line with to a point in the not too distant future where we will nationally agreed strategic priorities. You quote the see more of them because of the benefits they bring example of perhaps economic priorities as opposed in terms of eYciencies and cost. The critical issue is to national security interests. At the end of the day, how you integrate them into airspace given that you a balance has to be struck. What is your view as to do not have people in them and therefore some of the what the priorities should be? What kinds of sensors, not least the mark one eyeball that is usually nationally agreed strategic priorities should take relied upon for deconfliction and so on, are not priority in the end? there. A lot of work has been done recently by an Air Vice-Marshal Anderson: It is diYcult, industry/government grouping under the term particularly for members of the military, to envisage ASTREA, which is looking at sense and avoid, how that national security would be anything other than we introduce into our systems the same degree of the top priority in a real sense, if you take it to the safety and collision avoidance that we would ultimate degree, but I do not think anybody, least of normally expect in manned systems. We are not all the military, would in any way counter the Processed: 06-07-2009 18:38:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG3

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4 March 2009 Air Vice-Marshal Tim Anderson and Air Commodore Mark Wordley singular importance of the economic dimension to squeezed over recent times and indeed how you look the nation’s priorities. Rather than trying to to the future, maintaining enough uncontrolled determine what a singular priority is, the key thing is space for you to use. to get a policy and regulatory framework which Air Vice-Marshal Anderson: I will hand over to my involves all of the key stakeholders in a constructive colleague to talk particularly about airspace changes manner, whereby the various priorities can be that have taken place and the degree to which we identified and accommodated in whatever is seen to have been engaged in them. I appreciate that you are be the best way at the time. I think that exists today. perhaps simplifying the point about 40%. I do not I do not think it is so perfect that there are not want to lose the point that it is not quite 40% of developments and improvements that we can make, freedom. There is 40%1 which is in class A controlled but the way in which we, as the stakeholder airspace for civil air traYc but there is a variety of community in aviation, currently sit around the diVerent airspace blobs, if you like, around the rest table metaphorically and rationalise these of the environment which limit the availability of competing requirements for airspace usage is, as I training areas for example for the military or even think you heard in your previous evidence session for recreational flying for the general aviation here, arguably a model that others should follow. community. The vector is in the right direction. Air Commodore Wordley: Throughout the airspace change proposal wherever it is, we are engaged Q264 Ms Smith: You seem to be suggesting that throughout that process so we are able to have our more often than not this approach can resolve voice heard this is the absolute model which you reasonably well some of the interests that could have heard previously that should be followed and potentially conflict if this approach were not to be sustained for the UK. There have been a number of taken. areas where we have seen some impact on our ability Air Vice-Marshal Anderson: Absolutely. or we have had to compromise. The move of the London TMA north into East Anglia was a good Q265 Mr Martlew: My constituency is next to the example where some of our bases—particularly the Lake District. For many years we had the issues of American bases at Lakenheath and Mildenhall— V low flying aircraft. The issue seems to have died were a ected to a certain extent, but again with the down. Perhaps the numbers of low flying exercises appropriate consultation and compromise we were have reduced or perhaps it is being shared more over able to overcome those. The other area which has the rest of the country. What is the situation? almost crept up on us is the growth of some of the Air Vice-Marshal Anderson: I think it is a regional airports. Many of them ironically are ex- combination of all of those factors. First and military, of course. They have been developed for foremost, there has been a reduction overall in the good reasons from a commercial point of view into amount of low flying. That is predicated on a a commercial going concern but then of course with reducing number of aircraft within the military that generates either a zone or some sort of other inventory and on a variety of diVerent capabilities airspace put around the airfield. In many cases there which we now develop and train, including is also a growing argument that there should be capabilities at higher levels, higher altitudes. controlled airspace joining that airfield to the en route sector. That is where from an MoD point of view we argue that our own air traYc control system Q266 Mr Martlew: Is this because the threat of war can and does handle that civilian traYc such that our has changed? military crews can continue to operate with the Air Vice-Marshal Anderson: I do not think it is tactical freedom that they require, but at the same because the threat has changed. The sorts of things time we are also contributing to the national eVort to that continue to drive us to train at low levels still ensure that the commercial and economic side of exist, but we have brought into our defence that element of development is taken forward. It is, capabilities or armoury a number of other almost like the wind farm question, in isolation not techniques and ways of doing our business, which really an issue. It is the cumulative eVect of all of mean that we do not solely rely on low level flying to those aspects where we are increasingly having to do all that we need to do. There is a more eVective take more and more notice and perhaps come up use of the low flying areas as well. There has been a with slightly harder compromise arrangements. very conscious eVort within the military to spread our activities around and make sure there are no hotspots that are there merely by dint of us not Q268 Sir Peter Soulsby: Are there particular paying attention to what we are doing or trying our regional airports that cause you concern? best to ensure that the training is spread around. Air Commodore Wordley: Only from the point of There are a number of factors that have resulted in view of the geography, where the majority of the what has definitely manifested itself as a reduction MoD’s flying bases are, down the east coast of overall in low flying. England. They are in certain cases I do not say creating diYculties, but they require a certain Q267 Sir Peter Soulsby: You very helpfully gave us amount of extra attention. Again, because of all the an estimate of perhaps some 40% of airspace being interfaces we have at every level, I believe that safety uncontrolled. We understood the diYculty of has not been compromised. The operational estimating that. I wonder if you can give us a description of how that is changing, how it has been 1 Note by witness: this should be 60%. Processed: 06-07-2009 18:38:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG3

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4 March 2009 Air Vice-Marshal Tim Anderson and Air Commodore Mark Wordley eYciency of the commercial operation and indeed pilots. At the end of the day, there is not a diVerent the MoD operation has not been compromised. set of rules for each community. We are all, military Other areas of the country where recently we have or civil, applying airmanship and adopting the same handed over control of RAF St Mawgan down at rules. Our operations may lead us to operate more in Newquay to Cornwall County Council—that is an class G airspace where there is not such a restriction area of the country, save for the Royal Navy on what you do and how you do it, but the way in establishment down at Culdrose, which is not hugely which we get there, the way in which we conduct populated with military airfields and therefore the ourselves in that airspace, particularly when we are impact from our point of view is not quite as keenly joining our civilian colleagues in the route structure, felt. It does depend very much on which part of the is by the same principles and the same sort of country we are talking about. doctrine. I know you were not suggesting this but I would hate anybody to think that we had a Q269 Sir Peter Soulsby: Is there an argument for completely diVerent perspective on how aircraft putting a cap on the growth of traYc at some of should be operated in the airspace. I would like to those airports to cover the issues you have raised think that both communities operate to the same there? levels of professionalism. Air Vice-Marshal Anderson: I do not think that we Air Commodore Wordley: Whilst both communities would advocate at this stage, if you will forgive me, are called “air traYc controllers”, if I can put it very something as crude as putting a cap on. I think we crudely, perhaps the driving of airlines down an would be much more interested in continuing the is much the same as a lorry driver driving a dialogue that we currently enjoy and also looking truck down a motorway; whereas the military is forward to technological advancements or eYcient driving the Ferrari which needs to zoom in and out use of airspace, more intelligent use of airspace, so and do all sorts of other things. At one level—I think that we can learn to grow together. The previous you saw this at Swanwick—we literally have military discussion on SESAR and the opportunities that controllers sitting next to civil controllers. That that might bring, albeit it will not be tomorrow, give enables the military task, which is more dynamic, in some hope that if we continue to talk and manage many cases more demanding because of fuel our respective requirements in a mature manner then pressures, sortie constraints and so on, to make we perhaps avoid something as emotive as a cap. If maximum use of their time and their fuel and I go to Robin Hood Airport and say, “We intend to training opportunities on one side of the country or put a cap on your movements”, I doubt if I would get the other, depending on a number of diVerent a very favourable reception. factors. The military controller has an innate understanding of what the military air crew need to Q270 Sir Peter Soulsby: There are not any examples achieve to fulfil their training or operational where you have not reached reasonable agreements mission. There is the overall understanding that first and compromises? of all the safety of the airspace is absolutely Air Vice-Marshal Anderson: There are plenty of paramount. As ACAS has mentioned, everybody examples where we have not reached a conclusion knows the rules are exactly the same, but it is just a that is exactly what we set out to reach and we have diVerent way of discharging that particular role. not enjoyed the full freedom or benefit of everything Again, the relationship from my point of view we try to achieve but, no, I do not think there is between military and civil controllers is really very anywhere where we have walked away and thought good. we have been really hard done by there. We recognise that there are competing requirements. In some cases there are higher priorities and, as long as we can Q272 Mr Wilshire: It could be argued that a civil continue to have this sensible dialogue, I think at the aircraft flying in uncontrolled airspace is less safe end of the day we will all end up with the correct than one flying in controlled airspace. Do you have answers. evidence that that contention is untrue? Air Vice-Marshal Anderson: I would be looking for Q271 Mr Wilshire: There is an inevitable conflict I evidence to say that it was true and none is apparent suppose—it might be too strong a word—between to me. A civil aircraft operating in uncontrolled civil aviation where its pilots understand that they go airspace is operating under the same rules of the air where they are allowed to go, when it suits somebody in class G airspace under see and avoid, but they else’s idea of when they should go and your pilots have available both on board technical systems and who want to go where they need to go—I am not traYc alert systems. They have access to airspace criticising them—when they judge it to be necessary. radar services. It comes back to the point earlier on That is a fundamentally diVerent approach. To that about how the military and civilian air traYc extent, what is the relationship on a day to day basis? communities operate together. As you are well In Swanwick, one senses an entirely diVerent feel aware, it is a joint and integrated airspace structure between civil air traYc control and military. How do so we have military air traYckers providing radar they interface? EVectively, or is there pressure? services both inside and outside controlled airspace Air Vice-Marshal Anderson: The expert on how they to civilian aircraft. We take civil air traYc services interface is sitting on my right so I will defer to him from NATS or from the military. I do not think there in a moment. I appreciate the caveat you placed on is anything that suggests to me that any aircraft is the distinction between civilian pilots and military more vulnerable or at risk than any other operating Processed: 06-07-2009 18:38:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG3

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4 March 2009 Air Vice-Marshal Tim Anderson and Air Commodore Mark Wordley in any of these types of airspace. There is nothing Q276 Chairman: Have there been any occasions that I would identify as being a significant risk when the Assistant Chief of Air StaV has referred factor. CAA airspace change decisions to the Secretary of Mr Wilshire: I am about to leave. I just want to make State? sure the witnesses do not think I am walking out in Air Vice-Marshal Anderson: No. disgust in view of their answers. Q277 Chairman: In relation to the SESAR Q273 Chairman: On what basis are you concerned programme, what impact will that have on the UK that future airspace strategy will be biased towards military? commercial interests? You say that in your written Air Vice-Marshal Anderson: Two potential impacts evidence. Why do you think that? at least. The first is that we will benefit from what it Air Vice-Marshal Anderson: I would amend that delivers if it does what it says on the tin. It is clearly element of the written evidence slightly in response not going to happen overnight. There is a fair to that question. I do not think there is a concern amount of technology development required. In my that it will be. I think there is a concern that, if the own opinion, I have some questions about the structures that we currently have in place or if the degree of resources that will be put to it. Concepts relationships which we currently enjoy were, for are easy to develop but funding them and developing whatever reason, to be distorted or changed, the them can be more problematic. In the positive sense, relative priorities given to defence and national we would look forward to SESAR as part of the security may not merit the same attention as they do modern airspace structure delivering benefits for all today. There is no question about the economic airspace users. The only other potential impact of imperative and the degree to which we need to course is that, by virtue of what that technology V accommodate that for everybody’s benefit. It is o ers, regulation or policy that subsequently merely that we maintain this balance. We requires airspace users to adopt that technology will understand that there is no one single priority at any have a price tag associated with it. It will therefore be one time. There is a variety of priorities and they a challenge for me and quite likely my successors to change over time. They are dynamic and if we ensure that those resources are made available from continue to have the dialogue then we are able to the Ministry of Defence. accommodate that. Q278 Chairman: Do you think you will be able to find those resources? Q274 Chairman: Do you think that airspace change Air Vice-Marshal Anderson: I cannot answer that documents should have a specific reference to question until I know the scale of the challenge. I military matters? Is that necessary? know for a fact that there is no extra money sloshing Air Vice-Marshal Anderson: Our involvement in the around, just waiting for an orphan bid, but the airspace change process in the positive light that I strength of our budget process is that we rank the have described it thus far suggests to me that priorities and we fund those that we identify as whenever an airspace change document is issued our critical to our business or of high importance. I have concerns are either already accommodated in it or to assume that that process will take care of SESAR will be as a result of consultation and so on. Again, when the time comes. I would not really ask for special treatment here. Q279 Chairman: Does that mean you expect to be Q275 Chairman: You do not see any need for any able to meet the requirements of the programme? specific change? Air Vice-Marshal Anderson: I cannot expect to meet Air Commodore Wordley: I do not think so, no. The them unless I know what the requirements are. I history of the various airspace changes that have expect to want to be able to but, until I know how taken place indicates that our views have been heard big the cheque is I cannot make a comment now on and, in some cases, taken account of. As long as that whether or not I will be able to sign it. arrangement continues, we would not argue for Chairman: Thank you very much indeed for coming special treatment. and answering our questions. Processed: 06-07-2009 18:38:30 Page Layout: COENEW [SE] PPSysB Job: 412381 Unit: PAG4

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Wednesday 18 March 2009

Members present

Mrs Louise Ellman, in the Chair

Mr David Clelland Ms Angela C. Smith Mr Philip Hollobone Sir Peter Soulsby Mr John Leech Mr David Wilshire Mr Eric Martlew Sammy Wilson Mark Pritchard

Witnesses: Mr Daniel Calleja-Crespo, Director of Air Transport and Mr Sven Halle, ATM Expert, Directorate-General for Energy and Transport, European Commission; Mr Alex Hendriks, CND Deputy Director for Network Development and Mr Bernard Miaillier, CND Deputy Director for SESAR, Eurocontrol, gave evidence.

Chairman: Good afternoon. I would like to welcome runway. This means that the number of aircraft will you here and to thank you very much for agreeing to be in a holding pattern. We try to keep that as much come at short notice. We were hoping to meet all of as possible to the minimum: by oVering en route you in Brussels but, as you know, because of delay; by air traYc flow management; and, of parliamentary duties, we were unable to come. Do course, now with the SESAR programme—which members have any interests to declare? Mr Calleja can talk about more—we hope to be able Mr Clelland: Member of Unite. to have more technology that will see to it that Ms Smith: Member of GMB. aircraft will flow from airport to airport, gate to gate, Chairman: I am a member of Unite. without any interruption and land precisely at the Sir Peter Soulsby: A member of Unite. time they are scheduled to land. Mr Leech: Given that we are talking about airspace, I will declare a beneficial, non-pecuniary interest in Q282 Chairman: Mr Calleja? a piece of land around Heathrow Airport. Mr Calleja-Crespo: To complete Mr Hendriks’ reply, I would like to stress how significant the cost is which Q280 Chairman: Gentlemen, could I ask you to European industry is paying because of the present identify yourselves for the record, please? fragmentation in air traYc management. According Mr Calleja-Crespo: My name is Daniel Calleja. I am to the studies we have, fragmentation of the air the Director of Air Transport of the European traYc management results in additional costs of up Commission, and it is a privilege to be with you to ƒ2 billion for airspace users. We think that if we today. improved the European network design, which is Mr Halle: My name is Sven Halle. I also work in the presently an amalgamation of national routes, our Air Transport Directorate of the European flights could be more eYcient. We could even have Commission, in the Single European Sky area. savings of an additional ƒ1.4 billion per year. We Mr Hendriks: My name is Alex Hendriks. I am could also have significant environmental benefits. Deputy Director for Network Development in We could save up to 4.8 million tonnes of CO2 Eurocontrol. emissions per year with network improvements. Mr Miaillier: My name is Bernard Miaillier. I am Finally, we also think that we could have significant Deputy Director for the SESAR contribution in results in reducing delays, which cost ƒ1.3 billion per Eurocontrol. year. There is therefore a significant challenge in improving the European air traYc management Q281 Chairman: You have given us evidence which system, and there can be very important benefits in points out the extent of flight ineYciencies in terms of fewer delays, environmental benefits, less Europe. Do you think that those ineYciencies could cost, better performance and, at the end of the day, be resolved by improved airspace management? a more eYcient European air transport system. This Who would like to give a view on that? is the challenge and the purpose behind the action at Mr Hendriks: Perhaps I may be allowed to kick oV. the level of the European Union and at the level of Flight eYciency is basically composed of a number Eurocontrol. of elements. We are talking about the eYciency with respect to fuel; we are talking about the eYciency Q283 Chairman: In the evidence we have received with respect to the environment; but we are also from the Commission you state very clearly that you talking about the eYciency of the ATC system. The feel it is to do with individual countries looking at two normally may not be aligned 100% with each their own networks that creates this problem. Is this other. This is where the SESAR programme comes a special problem in the UK? in, to develop new technology that will enable that Mr Calleja-Crespo: I think that to understand the to happen. Perhaps I can give you one brief example, issue you have to realise the evolution. In Europe we Chairman. In order to make full utilisation of have a single European aviation market. We runway capacity, you need to have available a liberalised aviation and, since 1992, every carrier can certain volume of aircraft in order to be fed onto the fly freely from any point, from one country to Processed: 06-07-2009 18:38:30 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Daniel Calleja-Crespo, Mr Sven Halle, Mr Alex Hendriks and Mr Bernard Miaillier another, with no restrictions. We have common rules Chairman. I would like to endorse fully what Mr on slots, on ground handling, on airport charges; but Calleja has said. It is an evolutionary process. in air traYc management we do not yet have a Single Whereas in the 1960s and early 1970s the states and European Sky. We have a situation where air traYc the service providers, to the extent that they existed management has evolved from a national then, were very much inclined to plan their airspace, perspective, and the European Union only started the route network and the systems purely on a working in this area in 2004. This is the first Single national basis, we have moved away from that. I can European Sky. One of the main elements of the list six examples for you, if I may, of where we have Single European Sky is the Functional Airspace been quite successful in Europe in the last few years, Blocks. What is Functional Airspace Blocks? It is not least through the active and very positive countries working together. The UK has been one of participation of UK CAA and UK NATS. For the most active countries in this area. The instance, the introduction of 8.33 kHz spacing for Functional Airspace Block between the UK and radios, making more frequencies available for air Ireland is a way to tackle more eYciently the control sectors, thus enabling us—and when I say challenges of fragmentation. In relation to the UK, “us” it is Eurocontrol and the service providers—to therefore, I think that the initiative of the Single create more sectors and therefore more capacity. European Sky and the initiative of the FAB can RVSM, reduced vertical separation minimum, bring very significant benefits. You should not forget where we moved from 2,000 feet vertical separation that the UK has significant traYc flows to the above 290—above 29,000 feet—to European mainland: 41% of traYc goes to or from 1,000 feet, creating six additional flight levels in the France; 25% to or from the Netherlands; 11% to or level of airspace where most jet aircraft would like to from Belgium; and, through Ireland, you have all the operate. Europe was the first continental airspace in oceanic and transatlantic flights. We believe that, at the world to achieve this, and this was done on a the end of the day, participating actively in the single day, at exactly the same time, for all of the European initiative of the Single European Sky, by European countries. The third example I would give working together with other countries, by pooling is route network development. Whereas initially resources, by managing the airspace more eYciently, states and service providers were doing the route will bring significant benefits. The London-Paris- network development purely by themselves, to a triangle has both Europe’s densest certain extent co-ordinated through ICAO, we now traYc and the busiest airports. There is huge have a process in place where all the service providers interdependence between the UK airspace and the work together with us, and us with them, to come to European airspace. We are speaking about a a truly pan-European airspace. Air traYc flow network, and we need to have a very eYcient management has been centralised in Brussels, with network. Any problem in one part of the network— the co-operation of all the states. RNAV has been even if it is a small part—has a knock-on eVect on the introduced, allowing aircraft to navigate, rather network. That is why we think that the UK has a lot than from radio beacon to radio beacon, to any to gain, like all the other Member States, by actively geographical position. It is like GPS in all aircraft— building upon the European initiative of the Single enabling us to come up with a much more flexible European Sky. airspace. It was in fact a British and a French idea to come up with the flexible use of airspace. In other Q284 Chairman: Do you think that the CAA and words, let us not treat airspace as civil airspace or NATS are eVective organisations? military airspace but, to the extent possible, let us Mr Calleja-Crespo: My personal opinion is yes, I say that we have airspace, and civil and military think that we are impressed. The UK Civil Aviation demands must be accommodated there. Those Authority is a very active participant in the Single initiatives have enabled us to create significant European Sky Committee. NATS was one of the capacity in Europe in the last few years. Now we first organisations in Europe to move forward with move to the next phase, which is SES—the Single modernisation. In a way, some of the schemes which European Sky. Package no.2 has just come out, are being developed in the UK—the performance which will create more incentives and perhaps also scheme—have brought inspiration for the European introduce new technology. With respect to your system; but, having said that, the Single European question regarding CAA and NATS, I can only say Sky is a challenge for all the civil aviation that from a Eurocontrol point of view we have V organisations. We believe that we can do better and excellent relationships. The di erence between CAA that we can implement more eYciently if we and NATS—one being the regulator and one being continue building upon the Single European Sky. the service provider—has been an example for many This is why, as you probably know, we are discussing states to follow. It is therefore very positive. right now what we call the second Single European Sky package, to make even more progress for the Q286 Mark Pritchard: Sr Calleja, you mentioned the future. Single European Sky. You also mentioned environmental benefits but also dealing with delays Q285 Chairman: Mr Hendriks, did you want to add through better, more improved air traYc something to that? management. I wondered what your view was, and Mr Hendriks: I can perhaps add to what Mr Calleja that of the rest of our guests today, on the UK has said, if I refer back to the previous question and Government’s decision to build a third runway at then come on to your last question, Madam Heathrow. Processed: 06-07-2009 18:38:30 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Daniel Calleja-Crespo, Mr Sven Halle, Mr Alex Hendriks and Mr Bernard Miaillier

Mr Calleja-Crespo: You have to understand that the particular in the UK which is one of the densest European Union works with respect to the principle traYc, from a technical viewpoint the answer would of subsidiarity. It is impossible for us, from Brussels, be that we need new airport capacity in Europe and to manage all the decisions taking place in the we need to planify the future. Of course, this new diVerent airports in the diVerent Member States. We airport capacity has to be established, respecting the believe that it is up to the local authorities, up to the environmental and all the other legitimate concerns. national governments—it is the principle of However, the EU has no competence in planning proximity—in order to deal with these issues. What infrastructure. This is very important. Member we try to do from the European side is to agree the States have very clearly said that this is not a matter basic principles with the Member States and to for Brussels. What the EU can do is to draw establish the guidelines, the directives, which it is awareness to the needs. Last year, we established the then up to them to observe. Every time there is a European Airport Capacity Observatory. This is a decision to build a runway in one country of the new and very important institution, where the European Union, you have to reconcile two Member States meet with Eurocontrol, the conflicting principles. On the one hand, there is the European Commission, the representatives of principle of capacity. In the next 20 years we will be European airports, airlines, consumers, regions, and facing very serious problems of capacity in Europe. where we will discuss the issues related to airport In spite of the present crisis, the forecast is that we capacity. It has just started its work. One of the first will have an increase of traYc which could be of 200 things we will do is an inventory on existing airport to 250% from here to 2030. Europe needs to work on capacity in Europe. Each country has its own having more capacity. This is why the Single inventory; we do not know what the actual situation European Sky is so important; it is why having is. We will analyse the evolution of traYc and we will airport capacity planifying in advance is a very then be in a position better to assess the situation. important issue. On the other hand, there is also the This Observatory will not replace the national principle of environmental protection and how you decisions by countries, because that would go reconcile the need for additional capacity and the beyond the principle of subsidiarity, which we have need to take into account the environmental to respect. concerns, which are extremely important and legitimate and which also form part of the European Q289 Mr Wilshire: I cannot resist the temptation, Y priorities, which we are defending in very di cult before I get to questions, to say how thrilled I was to conditions on the international scene. What we have hear someone from the European Commission agreed in the European Union, following ICAO— say—and I wrote it down—“It is impossible for the International Civil Aviation Organization Brussels to manage everything”. I am thrilled to hear standards—is to follow the balanced approach. that. I will hold you to it as well. Every time there is a need to have some measures Mr Calleja-Crespo: It is true. which have an impact on capacity, you have to do it taking the circumstances into account: the needs of Q290 Mr Wilshire: I want to move away for a the local population, respect for environmental moment from environment, delays, capacity and concerns, and consultation. These are the issues those issues, and to ask you some questions about which Member States, at the right level—the safety. One of the requirements of Eurocontrol is to national government and the local authorities who have standardisation of arrangements across are responsible for airports in many countries—have Europe, and that obviously means harmonising to fulfil. The European Commission does not have standards between individual countries. Again, one the power in this area. of the objectives of the Single European Sky is to create a single safety framework. We, being Brits, Q287 Mark Pritchard: You may not have the power, have long since persuaded ourselves that, between but I am sure that you have a view. In relation to them, the CAA and NATS, as far as standards and reconciling dealing with capacity with safety record are concerned, are amongst the best in environmental issues, do you believe the decision by the world. Do you agree with that? the UK Government successfully reconciles those Mr Calleja-Crespo: Yes. divergent points? Mr Calleja-Crespo: I could not answer this question, Q291 Mr Wilshire: Yes is the answer—fine. When because I have not followed in detail the you standardise and when you create a single consultation, the process, or to what extent. I think framework, therefore, can you assure us that under that it would not be professional on my side to do so. no circumstances whatsoever will any of our standards be diluted, to get your common policies Q288 Mark Pritchard: But you are the Director of across the European Union? Air Transport within the directorate and, regarding Mr Calleja-Crespo: Yes, and I will explain why. One the Single European Sky, you have set those issues of the main pillars of the Single European Sky out before us today. Surely you have a view whether second package is the safety pillar. We have the the new runway would advance the principles of the capacity pillar, we have technology,and we also have Single European Sky or not? all aspects of performance. Safety cannot be Mr Calleja-Crespo: As I said, in view of the compromised. You can have many parameters but challenges we have in terms of capacity and in view the absolute objective of safety has to be preserved— of the congestion in some parts of Europe, and in not only preserved but it has to be enhanced. We Processed: 06-07-2009 18:38:30 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Daniel Calleja-Crespo, Mr Sven Halle, Mr Alex Hendriks and Mr Bernard Miaillier would not be launching the Single European Sky Q295 Mr Wilshire: Yes, but they are the highest process if there were to be any consequences for ones. I am not going to name names, and I am sure safety. Not only do we think that it will not be that you do not want to name names, but you are diminished but we also believe that it will be very aware that some of the air traYc control reinforced because, when you discuss safety issues standards and systems across Europe leave a fair bit with experts, the key element is to have a total safety to be desired. You can set whatever standards you approach. What does this mean? It means that all the like, surely, but if the same people are going to elements of the network have to have the highest enforce them what is going to change? standards. If you have a breach in the system, you Mr Calleja-Crespo: So that you understand the logic will have a weak element in the chain and you will that we are proposing for the European side—and then have a problem. What is the situation in this is a very important point—we will have, through Europe? In Europe you have Member States with the Single European Sky 2, a certain number of key very eVective levels of aviation safety. You performance targets that will be discussed by all the mentioned the United Kingdom and I said that I Member States and established at European level. agreed. I also agree that we cannot manage Amongst them, we will have flight eYciency, everything from Brussels, as I said! Coming to the capacity, environmental and safety standards. These issue of safety, what is very important is what the safety standards will be implemented at national European Commission is now proposing: that we level. It will therefore be up to the national will have the European Aviation Safety Agency in authorities to ensure the achievement of these Cologne, which will do something that does not exist standards; to enforce these standards. In this respect, now. It will establish uniform, binding safety there should be no doubt that the whole approach is standards throughout the EU. Why? Because we to level-up the existing situation. The advantage have a single market and we need to have the highest compared to the present system is that we have the safety standards in our market. Having said that, possibility also for the European Union to check what the Agency will do will be to establish binding whether the standards are enforced or complied with standards; but these binding standards have to be at national level. The European Union has the legal implemented at national level by the civil aviation power to act and, if these standards are not met in a authorities. Therefore, I have no doubt that there particular Member State, we can start proceedings in cannot be a reduction in the safety standards. On the relation to this country and legally require this contrary: we will have something that we do not country to enforce these standards. have now. Now we do not have common, binding safety standards. This will be enacted in all the elements by the European Commission, following Q296 Mr Wilshire: If you start from the premise that the technical recommendations of EASA. EASA— I did, however, that British standards and British the European Aviation Safety Agency—is composed safety are amongst the best in the world, it clearly of all the Member States and it will deliver follows that some are not amongst the best in the recommendations that afterwards will be enforced world. I am quite sure that you are not going to throughout the EU. This is a great improvement on employ only Brits who come from the CAA and air Y the present system, the Joint Aviation Authorities tra c control through NATS to set your standards system, where you do not have that. This is the or to create a framework. Therefore, if you are going added value that the European community can give. to employ people who are not from amongst the best We can have binding and enforceable safety in the world, what steps will you take and who will standards throughout the EU, and this is crucial do the training before you let these people loose on for safety. telling us what we should be doing in the future? Mr Calleja-Crespo: To continue the description of how the system will work—in order to establish Q292 Chairman: So it is a levelling-up, not a these standards, the Commission will base itself on levelling-down? the national plans arriving from the Member States. Mr Calleja-Crespo: It is a levelling-up—exactly. We will receive the standards from the United Kingdom. The United Kingdom will say, “These are Q293 Mr Wilshire: If I heard you correctly, you are the standards which I intend to implement”. These arguing that it will be standards set centrally and standards will be established at European level and standards enforced locally. then implemented by the United Kingdom. I think Mr Calleja-Crespo: Yes. that there should be no concern in this respect, therefore, but I think that my colleague from Q294 Mr Wilshire: I am thinking back to instances Eurocontrol can complete this answer. where things have gone wrong. It is often the Mr Hendriks: I would like to go back very briefly in enforcement that has caused the trouble and the history, if I may. We are convinced in Brussels, standards across all the various national whether it is the Commission or Eurocontrol, that arrangements in Europe. Why can you persuade the United Kingdom has the highest safety levels. yourself that it is sensible to allow enforcement to be We are very much aware of what is going on. I am in the hands of people who are not as good as the not sure whether I am historically correct but, since CAA and NATS? Clapham Junction, a lot has been done and you are Mr Calleja-Crespo: I think that there is some in the forefront of running the safety programmes. misunderstanding, because it will be the CAA and In the past, in making the safety case for some of the NATS which will enforce the standards. programmes that I mentioned before, we have used Processed: 06-07-2009 18:38:30 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG4

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British companies because they were in the lead in still designed along national borders rather than making the safety case and proving, before traYc flows. Air traYc control centres are below implementation, that the system was safe. I believe optimum economic size. We have duplication of that the higher level, as Mr Calleja indicated, raising systems, piecemeal procurement, high contingency, the bar, will be the European norm. It is a matter of training and administrative costs. An aeroplane the safety oversight programme, which again is flying from Athens to Helsinki on average does 50 through EASA, through the Commission, that it will kilometres, and in some cases 100 kilometres, more be assured that the level will be applicable to all of than it should because of the fragmentation of the the states. European airspace. It does not follow a straight Mr Calleja-Crespo: I would like to conclude the path; it has to follow a very complex route because point by saying something very important from the of the fragmentation. This is why one of the ways to European side. It is very good to have the highest address this ineYciency, which is harming our safety standards but, please, no complacency. The system for all the reasons we have said—delays, moment you believe that you have the highest safety environment—is to achieve a more integrated ATM standards and you are the best, you start to have European system. problems. Safety is a permanent challenge and safety V requires a big e ort, intervention on the part of all Q298 Ms Smith: Do you believe that ineYciencies the actors, and constant monitoring. We are can only be improved if there is a centralisation of air ensuring this through the European system, because traYc control in Brussels? we have auditing of the Member States through Mr Calleja-Crespo: No. We think that problems EASA; we have annual reporting; and we have which are complex require complex solutions. It another safety committee which also protects our would be very easy to say, “You just create a central citizens through the “black list” process, which we . . . .”—no. The problem has to be addressed, in our are establishing at European level to take out of view, in four diVerent ways. I would add a fifth one Europe those airlines which do not have the at the end, which is the most important one. First, appropriate safety standards. It is very good to have performance. We need to increase the performance the highest safety standards, but we have to continue of the European air traYc management system. It is working and monitoring them permanently. not performing as it should. It is below average. We Chairman: I can assure you that there is no want to have the highest standards in safety and also complacency. What we are trying to establish is how in air traYc management performance. Second, the European institutions will improve standards for safety. We have discussed the total safety approach everybody. That is what we are trying to identify. that we would like to put in place. Third, we need to have more capacity in the air traYc management Q297 Ms Smith: I want to ask the panel what are the network; not only in the air, through the Single main causes of flight ineYciencies in Europe? European Sky, but also on the ground. That is why Mr Hendriks: I think that I should turn the question it is so important to develop additional airport round, if I may. We have been trying to build a capacity. If we do not have more capacity on the system that fully meets the capacity, the ground, increasing the capacity in the air will not requirements, for a number of flights to be work. The fourth element is the technology. In the accommodated in the European system. That was future, technology has to deliver more significant the prime aim. Now that the fuel price is up, the benefits for us. We will have more capacity; we will Y emphasis is shifting from demanding capacity—now also have more e ciency. The fifth element, that we have enough capacity—to capacity with however, which is more important than the other better eYciency and taking the environmental four, is the human factor. The human factor is Y aspects into account. We are now shifting to critical. The training of air tra c controllers, the accommodating the flight profiles that are much involvement of the social partners, trying to do this more the optimum flight profile, thus enhancing the in partnership—not only with the Member States eYciency of the system. For that we need ATC tools but also with the whole industry, the airports, the Y and we need to be able to make use of the avionics airlines, air navigation service providers, air tra c on board the aircraft. I believe it is true to say that control—are essential. If we do not have the five historically the avionics on board aircraft have been pillars, these five elements working together, it will years ahead of ATC capability. In that sense it is very not work. good that we are now going into the SESAR programme, because the SESAR programme Q299 Ms Smith: I can see the point you make about Europe-wide—there is also a close link with the the five pillars, but I still do not see how the United States’ NextGen system and Mr Calleja was establishment and sustaining those pillars, if you at a meeting with the Americans yesterday, so that it like, will be achieved unless you have some form of could be a global system—is raising the bar for the co-ordination, some form of direction, from ability of the ground system to provide flight- somewhere. I think that the question remains, eYcient profiles in addition to capacity, making full therefore. How will that be done? How will that be use of the avionic capability on board aircraft. achieved? Mr Calleja-Crespo: Perhaps I may add to Mr Mr Calleja-Crespo: There I come to what we call the Hendriks’ reply. One of the main reasons for flight network management function, which is one of the ineYciency in Europe is that, in the Commission’s elements we are taking into account. Through the view, air traYc management sectors and routes are Single European Sky 1 process we have established Processed: 06-07-2009 18:38:30 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Daniel Calleja-Crespo, Mr Sven Halle, Mr Alex Hendriks and Mr Bernard Miaillier what we call a “bottom-up approach”. What is this With respect to network management, we are aware approach? Countries are getting together, they are of the European Commission’s ideas; we support pooling resources, and they are managing their them; we are awaiting the formal request from the airspace. This is the Functional Airspace Blocks. We Commission to develop ideas and to put forward to now have in Europe—and Eurocontrol can provide the Commission how we should put that in place. you with more details—nine initiatives underway to For the time being we consider that there are a create nine FABs. In Amsterdam yesterday, the number of elements associated with that; so it is not Spanish and the Portuguese signed their South-West really a person but a function. The function will Europe FAB. The UK and Ireland were the first. In comprise network design, where, together with all June 2008 they launched the UK-Ireland FAB. Six the service providers, we provide a catalyst or a countries in central Europe—France, Germany, facilitator to create a truly pan-European airspace Belgium, the Netherlands, Luxembourg and design. There is a little caveat that I would like to put —are launching the Central Europe FAB. on the table: that, when you go into the specifics of We have in south-east Europe a certain number of terminal airspace design, the best experts are at the initiatives—Blue Med, the Balkans, Danube, the V national level. We must therefore make full use of Nordic FAB. All these FABs are a genuine e ort people at the national level. There are then network from Member States to do better and jointly to pool operations, which are the day-to-day operations of their resources. All this will provide an the network. Flagging up if there are inconsistencies, improvement, but we still need the network logic. if there are bottlenecks in the system, so that it can There has to be someone who has the possibility to be fed back to the network development. There is a have the overall vision; to reinforce co-ordination performance review that needs to be done, and an between the FABs; to assist the air navigation service providers in improving the overall eYciency; to independent audit function. Basically, those are the manage a certain number of technical elements—co- four functions that for the time being we see forming ordination of frequencies, management of scarce part of the network management function. It is the resources—and to have the overall vision of the intention that, once we receive the invitation from architecture and route design. This is why in the the Commission to put forward proposals, we will, Single European Sky 2 we say that there has to be a as we have done with any mandate from the network management function. Why? Because the Commission, carry out extensive stakeholder pieces have to fit. The logic of network is so strong in consultation prior to submitting those proposals to the Single European Sky that you need this function. the European Commission. Who could do this network management function? We have an organisation in Europe, Eurocontrol, which has the expertise, the technical knowledge, the Q301 Ms Smith: My final question is about any best experts—pan-European, not only EU-27 but 38 proposed accountability or governance for countries which have been developing this. The Eurocontrol, if it were to gain these very important European Commission’s proposal is to empower functions. The Single European Sky has great and strengthen Eurocontrol management powers, in political implications. Can you give me the latest order to make the system work. I am speaking about thinking on how Eurocontrol would be governed Eurocontrol and I should perhaps apologise, and made accountable for its functions? because it is Eurocontrol who could give you some Mr Calleja-Crespo: I think the question is for of the answers more directly—if you agree, Madam Eurocontrol but, from the European Commission, I Chairman. can say that we are watching very closely the programme of reform of Eurocontrol— Y Q300 Chairman: Yes, and could you tell us, Mr transforming Eurocontrol into a very e cient and Hendriks, how the network management function very active organisation. I think that there are also would change Eurocontrol’s role? improvements in the governance, with the Mr Hendriks: First of all, I would like to re- participation of the stakeholders and new emphasise what Mr Calleja has said: that the institutions. However, I think it is more for Mr Functional Airspace Blocks are a very important Hendriks to reply to this. initiative. To a large extent, it is a bottom-up Mr Hendriks: Eurocontrol is basically an approach, where the air navigation service providers intergovernmental organisation; so our owners are have taken a significant lead and have gone out of the governments. We are now in a situation where we their way to try to create an environment in which are transforming it, to give full recognition to the the aircraft can operate away from national borders. fact that at the national level air traYc control is now This was the idea of a Single European Sky, so that handled through independent privatised/ a truly European airspace could be developed. The corporatized—it depends a little bit on the UK-Ireland FAB is a good example of that. As Mr country—air navigation service providers. They are Calleja has said, there are others to follow. There is very important stakeholders. We have the air only one concern perhaps: that we must now ensure navigation boards, where the air navigation service that, whereas in the old days we had national providers actively participate and have a say in how borders which to a large extent dictated the ATM we progress, but we remain an organisation basically environment, the FAB itself should not become the of the governments, of the states. Our highest new border. We need a process, therefore, so that decision-making body is the Provisional Council—a there is adequate co-ordination between the FABs. body where ministers or DGCAs like Sir Roy would Processed: 06-07-2009 18:38:30 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Daniel Calleja-Crespo, Mr Sven Halle, Mr Alex Hendriks and Mr Bernard Miaillier sit—and, more and more, we are moving to a Q305 Ms Smith: Operationally. situation where we become the technical arm on Mr Calleja-Crespo: I am trying to think of what area ATC of the European Commission. or a specific case where we would overrule. I am trying to think of an example to give you. We have Q302 Chairman: Could the network management this manager of the network system who will function overrule the national regulators? overview the situation and, for example, there is a Mr Hendriks: Within the powers given by the disagreement with a national authority—this is the transport ministers to the European Commission, it kind of situation you are thinking of? Would the would be with the Commission. network manager function be able to overrule and impose a decision on the national authority? This is the question? Q303 Chairman: Can you tell us that, Mr Calleja? It is trying to work out what the respective power of the diVerent organisations would be. Q306 Chairman: This is one of the areas. Mr Calleja-Crespo: I think that this is a very Mr Calleja-Crespo: I do not think, in the present important point. In our scheme as proposed by the discussions with the Member States, we have Commission—the Commission proposes, then it has reached this level. to be discussed by the Member States, by the Chairman: So that has not yet been discussed. European Parliament and then, if the Member States and the European Parliament agree, this would Q307 Mr Wilshire: The answer is that you do not become legislation—the proposal would be that we know. would have this network management function. A Mr Calleja-Crespo: No. The answer is no, I do not very strong function, to co-ordinate the FABs, to think that the network manager could overrule, participate in the design, to contribute to managing because the network manager has functions of co- the whole network system. This is a decision that ordination. He does not have decision-making would be taken by Eurocontrol, who would be powers in relation to the national authorities. empowered to perform this function. Who is Eurocontrol? Eurocontrol is the Member States. It is Q308 Mr Wilshire: The national authorities can go the Provisional Council of Eurocontrol where the on doing whatever they like; so what is the point of Member States sit. Member States would have to setting up another bureaucracy? agree; would have to decide. We would have the Mr Calleja-Crespo: No, we are discussing two experts from the diVerent countries discussing the diVerent things. One is the management of the issues, deciding what are the best alternatives and, at system. The network management function will be the end of the day, there would be a decision. This able to co-ordinate; will be able to allocate the scarce decision would simply be a recommendation resources; will co-ordinate the functioning of the addressed to the countries, which they could follow FABs; but the network manager cannot say to a or not. It will remain a purely intergovernmental country, “This is not the right FAB”. The FAB is system. If we want a system to work more eYciently, created by the sovereign Member States. We cannot the proposal of the Commission is that there should say from Europe, “No, this is not the right FAB. The be an overall assessment of the way the system UK and Ireland cannot do their FAB”. This is not works. This is why, together with the network possible. management function, we would have the performance review body. This would be a body that Q309 Chairman: You are saying that it cannot would report regularly on how the European air overrule. management system is working—have we done Mr Calleja-Crespo: No. better this year and have the targets been met?—and which will provide recommendations on the system. Q310 Mr Leech: The estimated cost of implementing the SESAR programme is ƒ30 billion. Given the Q304 Chairman: How would it actually co-ordinate current financial climate in the industry, is there any with, let us say, NATS? Not in terms of assessing risk to the implementation? what has happened but in operations. Mr Miaillier: This cost of ƒ30 billion should be seen Mr Calleja-Crespo: Through the Single European as including not only the new capabilities that are Sky Committee, where you have the civil and proposed in the context of the SESAR programme military representatives from each country. It would and that have been proposed recently; it should also be the Single European Sky Committee which would be seen as including the cost of simply maintaining decide at the end of it. the current system capabilities and developing them Chairman: Do any of the other members want to ask as much as possible, in the light of the increasing a question on this topic? traYc. We have presented the ƒ30 billion as being Mr Wilshire: Yes, on this precise question. You were what the total bill for the development of air traYc asked a very straightforward and simple question. management to accommodate the future traYc Would you be able to overrule national regulators? demand will cost. If SESAR did not exist, quite What we got was a very longwinded non-answer. substantial investments would still be necessary That question is capable of the answer “Yes, you simply to follow the eVects of traYc, and maybe not would be able to overrule” or “No, you wouldn’t”. even be able to accommodate the traYc demand. Which is it? With SESAR, we will in fact have more eYcient Chairman: Can you help us with that? solutions. For example, with the generalised use of Processed: 06-07-2009 18:38:30 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Daniel Calleja-Crespo, Mr Sven Halle, Mr Alex Hendriks and Mr Bernard Miaillier the Galileo accurate navigation system, we can get and at the level of FABs, and “ . . . the above rid of part of the infrastructure, which is currently functions shall not involve the adoption of binding available and maintained on a day-to-day basis on measures”—I am reading—“or of general scope or the ground, of the more traditional navigation aids. the exercise of political discretion. They shall take By moving to SESAR, therefore, we can also reduce into account proposals established at national level current infrastructure costs and improve the overall and they shall be performed in co-ordination with cost eYciency of the system. the military authorities”. It cannot overrule, therefore. Q311 Mr Leech: I think that what you are saying is that ultimately it is a cost saving and therefore there is no risk attached, because these costs would Q315 Chairman: That is a definitive ruling, happen anyway. therefore. Mr Miaillier: Any decision in the context of SESAR Mr Calleja-Crespo: This is the text of the provisions will be subject to a business case that will consider which are now under discussion on the network the cost eVectiveness of a new capability, also its management function, and there is no intention that safety aspects, the environmental case and the it can overrule. Even to overrule the military—no, security case. This will therefore be the subject of the this would not be possible. It is not the approach. business case presented to the diVerent stakeholders, before the actual implementation decision is made. Q316 Mr Leech: I was going to go on to new Definitely there is a high cost, because it implies new technologies. Eurocontrol describes the application systems on the ground and in the aircraft. The of advanced navigation capabilities as a must. majority of the costs are on the aircraft side. Should operations at major airports be limited to However, we want to make sure that any decision to aircraft carrying top-quality navigational systems? go to a higher level of capability pays back in a Mr Hendriks: With respect to advanced navigation reasonable amount of time, so that it is aVordable, capabilities, more and more there is a move towards by the airlines in particular, and progress will be accommodating more and more flights into the based on cost eVectiveness. airspace. We are talking about terminal airspace in this case, but it is equally applicable to the onward Q312 Mr Leech: Are there any contingency plans in airspace. Under the old regime, that would have place in the event of the money for the SESAR meant more and more navigational beacons. Now programme not being forthcoming? we are going into RNAV, precision RNAV and its Mr Miaillier: There are plenty of risk factors advanced applications. That will allow aircraft to be associated with the SESAR programme, because it is separated with less distance than is currently the quite an ambitious programme and because we are case. It will allow a higher capacity as well as better still in the validation stage of a number of the Y elements that belong to the programme. Not all the e ciency of the system and, as a by-product of that, decisions will therefore be made today; they will be less fuel burn. That programme will work only if all made progressively when we have the results of aircraft are capable of meeting that standard. We research. At each key point in the decision-making have done tests with the implementation of reduced process we will consider whether, for each of the vertical separation, which was not of the same envisaged capabilities, the answer is positive; standard but it can be used as a comparison. We have whether we have a positive business case and done some tests as to what the impact would be of whether we can move. This will be a continuing aircraft not being able to fly in an RVSM area. In process, which will also minimise the risks taken at other words, they would require the old separation. any given moment in time. The findings were that, if more than 2% of the traYc did not have the RVSM capability, all of the benefits Q313 Mr Leech: Did you want to add something, of all the aircraft would be completely wasted. If we Mr Calleja? move to such an environment, therefore, we have to Mr Calleja-Crespo: I wanted to come back to be able to do it for all aircraft. Having said that, there provide the Committee with the fullest information will be adequate mitigation. For instance, for on the previous point. You are now discussing military aircraft it is sometimes very diYcult, SESAR. If the Chair would allow, I would like to— because of the very limited size of the cockpit in fighter aircraft and the weight of the equipment. For Q314 Chairman: Yes. general aviation it is the same issue: they cannot have Mr Calleja-Crespo: Because I think that we are here large equipment; they cannot carry the weight and, to provide the maximum information and to give for general aviation, there is also a cost you all the elements. To come back to the issue of the consideration of course. They still need to be network manager and whether or not it can overrule, accommodated. Even though we are trying to I have been checking the present state of implement new rules for advanced navigation discussion—you have to understand that this is a capability and its application, we always keep in proposal which is now under discussion by the mind that there are certain communities, like the community institutions—and the answer, even more military and the general aviation community, that clearly than before, is no, it cannot overrule. The air must still be accommodated, and provisions are traYc management network function has the being made for that in consultation with all of the purpose of supporting initiatives at national level stakeholders, including NATS. Processed: 06-07-2009 18:38:30 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG4

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Q317 Mr Leech: Should governments or aviation results. Through the Single European Sky regulators across the EU be able to insist on aircraft Committee, where we have all the Member States of or airlines using the most up-to-date equipment? the European Union, we can take decisions on data Mr Hendriks: The answer would be yes, but it is not operability,we can set the standards and we can have so much of an issue. I mentioned earlier that the this technology standardised, certified and fully airborne capability is very often light years ahead of operational. When? As far and as long as the the ground-based ATC system; so many of the programme is continuous, it produces its aircraft already carry the equipment today. The development. There are a certain number of work Airbuses and the Boeings that are being delivered packages. We will have to see the results. We hope today already have that capability. that we can have some low-hanging fruit, some quick deliveries, because it is important when you Q318 Mr Leech: What proportion of aircraft in the are thinking of such an amount of money that there skies currently has the most up-to-date navigation are important concrete developments—I think our equipment? colleagues maybe can provide more details—and Mr Hendriks: I do not have the exact figures, but it then we can very eYciently, at European level, would be in the order of 75 to 80% already today. standardise this technology. Once this technology is standardised we have agreed with the countries, for example, the United States,—and yesterday we had Q319 Sir Peter Soulsby: Following on from that, I a very important meeting in Amsterdam between want to explore further how and at what stage it is intended to enforce the requirement to have the most SESAR and Next Gen—that we will work together sophisticated equipment to enable the full benefits of to ensure intra-operability and we will go together to this to be achieved. When and how will it happen? ICAO to have a International Civil Aviation Mr Calleja-Crespo: I think that it is very important Organisation certified. What we are building is a for us to explain the approach of the SESAR global system. SESAR is an open programme and programme. There is a definition phase, which has we are interested in having third countries been concluded and, next week, we hope to complete participate, third countries which have aviation the membership agreements leading to the accession agreements with the European Union on the basis of to the SESAR Joint Undertaking, which will be the reciprocity, because we want also our industry to instrument that will be in charge of the development benefit from similar opportunities which they may phase. We have the European Commission, which is be launching right now. On these conditions we are putting in ƒ700 million over the next seven years; ready to do it, but it is the standardisation which is Eurocontrol, which will put a similar figure; and extremely important. This technology can be then we have 15 very important players from Europe certified and implemented as a European standard, and also from non-European Member States. We and this will allow it to be used and operated within have the air navigation service providers, we have a the EU. This is also one of the added values which very important contribution from NATS, and we the European Union can bring to these kinds of have from other countries—from Spain, from programmes. Germany, from Italy—air manufacturing. Basically, the key players are putting in the money and assuming the risks of this very important Q320 Sir Peter Soulsby: In brief, there will come a programme, and then we will have the deployment point where you will say, “If you do not have this kit, phase, and I think you were right to mention the you do not operate”? challenges of the deployment phase. How is this Mr Calleja-Crespo: I do not know. I ask my going to work and why is industry so committed to colleagues. SESAR? It is very complex and it is a project which involves risk. I think one of the important elements, Q321 Chairman: Who is going to give the verdict on or one of the advantages, that SESAR will have, is that one? Mr Hendriks. that, first of all, we are pulling the resources of Mr Hendriks: We have always, so far, in the research, which were being distributed in many diVerent directions, towards a big project based on programmes where we have introduced the gate-to-gate approach, which is going to bring requirements for aircraft followed the line that, if in huge benefits to the aviation system. Second, we the end you do not have it, you no longer fly, but this have the main players involved. Third, this project has always been in very close concert with the will be intra-operable. We have an agreement with Airspace Users Organisation, giving them adequate the United States to ensure that SESAR and the lead-time in order to equip the aircraft, with Next Gen system, which is a similar programme adequate mitigation for those who are unable to which is being done by the United States, will be equip. To give you an example, when basic RNAV intra-operable, so it will be a global system. Then was made mandatory, IATA, very close to the there is the last element (and I come to your implementation date (IATA is the International Air question), there is something which we can produce Transport Association—the association of all the which makes it extremely interesting. It is not just a airlines), convinced us to postpone because they research project; it is not just the results of the were not ready, their members were not ready, so we research; we can actually standardise the results of postponed the implementation for a couple of this research in a very eYcient way as soon as the months, and then we all agreed on a common research is developed, as soon as we have concrete implementation date. Just days prior to that Processed: 06-07-2009 18:38:30 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Daniel Calleja-Crespo, Mr Sven Halle, Mr Alex Hendriks and Mr Bernard Miaillier implementation, one or two airlines said, “I am Sky. From tomorrow national sovereignty over sorry, we still have one or two aircraft unable to airspace ceases, it is centralised by Brussels, and we operate and we have a schedule to meet. Could we run the whole show: all the national sovereignty is have an exemption?” In consultation with all the transferred into Brussels. This is not the approach. states and the service providers, exemptions were The approach which was agreed by the Member issued lasting three months, and that gave those States in 2004 is a bottom-up approach. Countries airlines adequate time to retrofit the aircraft. It is a work together, they try to have a more eYcient Air flexible approach, nobody should be penalised, but TraYc Management System, they put in place the we should certainly also not penalise those airlines functional airspace blocks and they try to improve that have invested in accordance with the plan to the performance. What does the Single European operate aircraft. Sky II add to this approach? It adds two important things. First of all, it introduces dates. We are asking Q322 Chairman: In your earlier evidence, as I countries to establish the functional airspace blocks understood it, you were saying that either everybody by 2012, because we believe that if there is not some has it or, eVectively, it cannot operate. You cannot date, there will be many discussions but progress will aVord even a small percentage opting out. be uneven. Some countries have started before—the Mr Hendriks: It is not eYcient if not all of them UK and Ireland were the first—but others are not have it. moving fast enough to improve the performance of Mr Calleja-Crespo: I would to also introduce a the system. Second, we introduce a performance caveat in this discussion. Obviously, aviation is system in which we allow the European global, there are global standards and we have to Commission, on the basis of the input from the comply also with ICAO. We have examples where at national authorities, to adopt targets, targets which world level, being the International Civil Aviation will deal with a certain number of important Organisation, for example, for safety reasons, we concepts like flight eYciency, like environment, like have forbidden access to Europe, after a certain safety, and this will be implemented at national level. transition period, aircraft which were not equipped The element of targets is extremely important. with certain safety elements. This has always been Fourth, we have this as our programme, we have the done in the framework of the ICAO, because we are extension of competence of the system, and then we speaking about the global sector and we have an have a function, which is a supporting function, International Civil Aviation Organisation. We which is the network management. The network would have discussions with third countries in management is not there to overrule anyone; it is these matters. there to support the co-ordination between the Member States; it is there to provide some support. It cannot have binding powers in the countries, but Q323 Sammy Wilson: Can I come back to the last it can usefully help to co-ordinate, to manage better answer you gave to Mr Wilshire, because I am a little the frequencies, to give guidance also on how the confused about the level of intervention that there facts should work together better. However, the would be with the Network Management Function network management function is not a legally with either CAA or NATS. You said that as far as binding function, it is a support function, so it would the current situation was concerned you would not be wrong to assess Single European Sky only on the be able to intervene to overrule, so that there would basis of this element. This element is part of the be national sovereign responsibility. whole picture where you have the performance- Mr Calleja-Crespo: Yes. based system, where you have the extension to EASA, where you have SESAR and where you have Q324 Sammy Wilson: And yet, in the written also dates for the establishment of FABs. information that you gave, you have indicated that, first of all, in order to get a European system in place, Eurocontrol said aerospace planning, design, Q325 Sammy Wilson: If you are, first of all, saying management and the prerequisite processes can that there has got to be a uniform design because the currently hardly be considered as a national parts have got to fit in, and then you are talking sovereign responsibility, so there are elements there about a gate-to-gate management so that you have where you are saying that you will wish to overrule the most eYcient route, et cetera, not only are you inveigled nations because this needs to be addressed saying that you can interfere if the design is not right, in a pan-European context, perhaps facilitated by a you are also saying that the operation of that design, civil entity such as Eurocontrol. What elements of once it is up and since you want to monitor aircraft national sovereignty do you see being removed in and get them to ensure that there are eYcient routes, order to achieve the kind of uniformity that is et cetera, used, also involves you interfering at an referred to here? operational level. Mr Calleja-Crespo: I think that what we are trying Mr Calleja-Crespo: No, what we think is that this to do is to enhance the performance of the Air TraYc whole system will evolve logically and naturally to a Management System. There could have been an more eYcient system, because the FABs will approach which could have been followed, which is introduce more benefits, because the network an approach I call personally the “big bang”. By management, as the countries discuss the various decree we establish in Brussels the Single European possibilities, will also seek some approximation, Processed: 06-07-2009 18:38:30 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Daniel Calleja-Crespo, Mr Sven Halle, Mr Alex Hendriks and Mr Bernard Miaillier because the performance targets will also play a role responsibilities, which have not yet been determined, in the system and because SESAR will provide the becoming greater so that there is that greater technology, so I do not think that “interfere” is the centralisation? right word. On the contrary, I think all the elements Mr Calleja-Crespo: If countries do not agree to go in will lead to a more eYcient functioning of the this direction, because what we are presenting to this network as a whole, not through interference or committee is proposals from the Commission which direct action but by all the elements working are under discussion, they will not go forward. If together. The key word behind the Single European countries agree to go in this direction, then we will Sky process is “partnership”—partnership with the see how the process evolves, but at this stage these Member States, partnership with industry, national are proposals under discussion. If a country has supervisory authorities, air navigation service diYculties in accepting this, then they will oppose providers working together to improve the this situation. performance of the system. Q329 Sammy Wilson: So more responsibilities to Q326 Sammy Wilson: So if a company decided that, have a greater level of interference could be taken on yes, there is the ideal design that your controller or in the future? the network management function would like, but Mr Calleja-Crespo: I did not understand. they want to have a diVerent design, you would not interfere in that, or, if, once it was up and running, Q330 Sammy Wilson: Since the full responsibilities they decided, for whatever reason, they want to have have not yet been determined, if it was found that, a variation, you would not interfere then? for whatever reason, the bigger countries decided Mr Calleja-Crespo: As we would say in Spanish, you that they wanted to have their own national imprint want to be more Pope-ist than the Pope. No, we on whatever systems were designed, additional would not be able to interfere. We act on the basis of responsibilities could be taken on at this point, could the powers which Member States confer upon us, they, to allow for that level of interference? and Member States do not want us to go that far. Mr Calleja-Crespo: I would have to check that. We have a provision, I think. Countries, if they are not convinced, could leave. Q327 Chairman: I think it is a question; it was not a statement of the position. Mr Calleja-Crespo: What I mean to say is that the Q331 Chairman: If there is further information on European Commission does not have powers to that, perhaps you could send it to us. overrule Member States in their sovereignty. There is Mr Calleja-Crespo: Yes. We can provide this something very important in Single European Sky to information. which I would like to draw your attention, which is Mr Wilshire: Can I say one thing, Chairman? I have what we call the safeguard clause. We have a been listening to this question of which direction we safeguard clause, which says that the whole exercise are going in. It leaves me with a view that a pilot calls is done to try to work together to improve the up Eurocontrol and says, “Do you want me to turn performance of the system but that in no case can we left or do you want me to turn right?”, and the touch on very sensitive issues—military issues, answer he gets is, “I will talk to five committees, 27 defence considerations, national security. If the countries, think about it and in due course I will let Commission had this power to say, “Now you are you know.” That is no way to make progress with air not allowed to do this”, we would be interfering, as traYc control. you say, with these systems. I think that is not the approach. That approach would be that from day Q332 Chairman: Whether that is the situation is not one we establish the Single European Sky. The clear. I do not know who would want to answer any approach is the bottom-up approach. It is countries of that. working together that make the system work and we Mr Calleja-Crespo: I do not know what Eurocontrol are introducing some elements to accelerate the has to reply, but if the Member States want to go progress, to make it more consistent, to have some further and confer more sovereignty on Brussels to dates, to have the performance system, to have give us this power, it is always a possibility, but this support network management functions, but we rely, is not the state of play right now. at the end of the day, on the initiatives that come from the countries. The FABs do not come from the European Commission; the European Commission Q333 Chairman: Mr Hendriks. has no power to establish an FAB. Mr Hendriks: Just to step in there, Eurocontrol can only act to the extent that our Member States have empowered the agency to do so, not beyond that, Q328 Sammy Wilson: If you find then that, for and it is the same with the European Commission. whatever reason, some countries decide that they do The European Commission has received a certain not wish to go down the route of this kind of unified competency and can operate within that design, or whatever, that there will be a notice in the competency. If states decide to extend that brief that the ultimate responsibility is yet to be competency, then so be it, but we have to work determined for the network management function within the competencies given to our respective (or whatever body is set up) over the next number of organisations. The network manager is, to a large years, do you not see those powers and extent, a focal point, a facilitator, a co-ordinator to Processed: 06-07-2009 18:38:30 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Daniel Calleja-Crespo, Mr Sven Halle, Mr Alex Hendriks and Mr Bernard Miaillier ensure that we get a pan-European network that can Thank you very much indeed for coming and for only operate within the competency given. I think answering all our questions so fully. We do that is the answer. appreciate you coming here to see us. Mr Calleja-Crespo: Thank you very much. For us I think it was a very pleasant experience, and I did not Q334 Chairman: Thank you. We have kept you a expect to have such strong appeals to do more at a long time, a lot longer than we had planned. Perhaps European level in this area. Thank you very much. that indicates the amount of interest, but I think we Mr Wilshire: Just remember which country you are should let you go. You perhaps have trains to catch. in!

Witnesses: Mr Ian Hall, Director of Operations, Mr Alex Bristol, General Manager Operational Strategy and Investment, and Mr Lee Boulton, Manager Airspace Delivery, NATS, gave evidence.

Q335 Chairman: Good afternoon, gentlemen. I am Mr Hall: NATS’ view has been quite consistent that, sorry for keeping you waiting. I think you heard in terms of the overall eYciency of the air traYc some of the previous session. We did have a lot of management system, the operation of aviation in the questions and we had some full answers too. Could I air generally around London, it is better to expand ask you to identify yourselves, please, for the record? the existing infrastructure than to create new Mr Hall: Certainly. My name is Ian Hall and I am infrastructure, and that can be illustrated fairly Operations Director of NATS. simply by the experience that we will all have here on Mr Bristol: My name is Alex Bristol; I am the seeing the aircraft flying into Heathrow over this General Manager, Operational Strategy and area. If there were to be an airport in the Thames Investment for NATS. Estuary, then aircraft would be taking oV from that Mr Boulton: Lee Boulton, Manager Airspace direction, much as they do at London City, but in Delivery within NATS. much greater numbers, and the integration of those arrival routes and departure routes would just increase the complexity of the overall system, so it Q336 Chairman: Thank you very much. What will would either be a question of replacing existing be the impact of the proposed additional runways in infrastructure, or expanding the existing south-east England on airspace? infrastructure, rather than creating new Mr Hall: The decision to proceed with runway three infrastructure to operate alongside the others. had to be anticipated, to some extent, in order for us to think to the future about what kind of airspace Q339 Ms Smith: Moving on to something slightly design the London area was going to need in the long diVerent, NATS is concerned about a lack of rigour term and, of course, we had several scenarios that we and clarity in determining the appropriate balance had to work through. The decision to go ahead with between emissions and noise. Who do you think runway three means that at least one piece of the should take the lead in addressing this issue? jigsaw becomes clearer. The next stage for us is to Mr Hall: We are pleased now—this is a consequence develop the specific airspace design and address the of the Pilling inquiry—that extra powers are going to special issues to do with the additional routes that be given to the Civil Aviation Authority to provide need to be established, the kind of navigation guidelines and oversee the balance of environmental performance and equipage that it is going to be issues alongside airspace issues, so it is very necessary to operate, and then we need to establish specifically for us, it is not something that we can what the priorities are for the use of the runways and take on, but we look for a policy decision to help us what the priorities would be in terms of the and, of course, the clear challenge is between the Y distribution of the tra c according to pressing need to limit the climate change eVects environmental issues. There is a lot of work that we versus other environmental issues such as have to do, but, I have to say, I think we welcome the distribution of noise, or visual intrusion, or additional piece of clarity that one bit of strategic whatever. It is that balance that we are really looking decision is put in place. for further guidance on.

Q337 Chairman: When do you expect the work to be Q340 Ms Smith: When you say “a policy decision”, completed? you really see the responsibility for that lying with Mr Hall: Much of that depends on the processes for DfT perhaps? the planning, for the approval, for the completion of Mr Hall: My personal view is that I do not think the runway itself and decisions that need to be made (and I think this is NATS’ view as well) that there is around the use and the infrastructure on the ground. a clear policy that one should apply and the other Until we have got clarity about that, we will not start should not. There is always going to be some degree to develop specific airspace change proposals. of balance, depending on exactly where the route is and what the consequences are going to be, but if there were to be a clearer policy, or, as we were Q338 Ms Smith: I wanted to ask why you feel that creating our strategies we were able to determine in an airport in the Thames Estuary would not be a more coherent way how to put these policies or feasible in airspace terms? parties together, then it would make it much easier Processed: 06-07-2009 18:38:30 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Ian Hall, Mr Alex Bristol and Mr Lee Boulton to create a more consistent strategy, let us say, for approach seems to be to build constructively and airspace development, and then everyone would positively and to have someone who can broker have the relief of at least knowing what the long- these sorts of arrangements, but that will need some term view was. At the moment it is very hard for sort of rule-making process to enforce it. anybody to establish a long-term view. Q344 Ms Smith: Finally, can I ask you to take Q341 Ms Smith: So we are looking at a policy absolutely what you have just said to indicate what framework, really, which would be DfT? you think the powers of the co-ordinating function Mr Hall: Yes. might be or should appropriately be? By that I mean if you feel able to answer as fully as possible. Q342 Ms Smith: Have any wrong decisions been Mr Hall: What I can do is say that the need for rules made so far as a result of the problems around the in air traYc control is pretty obvious. There have to balance between emissions and noise? Have any be some clear rules, and that includes the way in wrong decisions been made so far because of the which aircraft must be operated and what delicate balance between emissions and noise, would equipment they must carry. They also apply to us in you say? terms of the distances that we have to separate Mr Hall: That is a very diYcult one to answer. Have aircraft and the methods by which we transfer the we had to make subsequent adjustments? I would aircraft, or transfer the information about aircraft. say, yes, we have, but in this instance ahead of the There are clear rules around that, so we are quite final decision. When we consulted on the used to operating in a rule-making framework. The arrangements for TC North, as it is known, the first round of Single European Sky bottom-up was airspace to the north and east of London, it was a very gentle and suggested, for example, that genuine consultation exercise based on the best functional airspace blocks ought to be created by information that we had, and we put a proposal around 2010. It was quite vague, quite imprecise forward which we thought would establish the best about what had to be delivered. When it was overall compromise in terms of those sorts of parties. apparent that there was not suYcient momentum, The widespread consultation meant that we had a lot the rule-making was tightened up, and under the to review when we got all of that information clear, SESII there is now an implementing rule that says and that has resulted in us reconsidering those you must implement by 2012, and that is a rule made arrangements and we will have to go out to by the states through the EU and the Commission to consultation on that again, but in terms of the point be applied by the states, so for me that framework made about any wrong decisions and the wish to for rule-making is suYcient at the moment. There is avoid them, this is a learning exercise and in many suYcient will to comply with that kind of framework cases these environmental trade-oVs are very for ruling for me not to be concerned that we would subjective and so opinion counts a lot in trying to come into conflict, for example, with the network decide the final outcome. manager or the nature of rule-making, because there will not be a firm rule until there is a unanimous view Q343 Ms Smith: Finally, just to change topics across Europe that the rule is justified. slightly again, to what extent do you think the proposed network management function will Q345 Ms Smith: They seem to have got the idea that change aerospace design responsibilities, bearing in day-to-day management of air traYc may be mind the witnesses’ evidence given earlier as well? compromised, perhaps, by having this network Mr Hall: I think the starting point for answering that Y management function at Eurocontrol. Can you is to reflect on the complexity of air tra c reassure us that day-to-day management and management itself, the complexity of the airspace decisions made in a particular airspace block will be system and the need to get a lot of alignment around left to the national air traYc control system? investments, particularly in aircraft equipage, but Mr Bristol: I think the answer to that is just a also in the infrastructure on the ground. That means reference. What happens today? We have an air that having a strategic plan behind which everyone traYc central flow management unit in Brussels, can align their investments is absolutely crucial, and which has a co-ordinating function centrally across so we welcome the Single European Sky framework, the network within Europe. Each individual state we welcome SESAR, the research aspect of that; we will then stick within its own guidelines, within its are heavily involved in that and directly committed own rules, and will continue to assure safety and to it. We also support the notion of a level of co- maximise capacity within the context of safety in ordination between these functional airspace blocks. their own airspace. I do not see that changing. Having been the first to get one established and then with another even bigger one right on our doorstep, it is really clear, as I said earlier, that the triangle Q346 Chairman: So you do not have any concerns between Amsterdam, Paris and Heathrow is crucial on this issue? to all of that, but it does need somebody who is not Mr Hall: To say we do not have any concerns would in one of those two groups to help co-ordinate all of be going too far, because the final arrangements have those activities. Quite how much power they might not been concluded. I think Eurocontrol have been have remains to be seen, and I think that was invited to make proposals now for the way in which probably reflected in the fact that that has not finally network management is handled. What we are been resolved yet. At the moment our general saying is that the rule-making framework, we think, Processed: 06-07-2009 18:38:30 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Ian Hall, Mr Alex Bristol and Mr Lee Boulton gives us confidence that it is highly unlikely we Q350 Mr Wilshire: Do you feel able to give this would end up in a conflict where we were forced to committee an undertaking that, were you to change do something that we did not think was appropriate. that view and were you to become concerned about the possibility of a dilution of standards, you would Q347 Mr Wilshire: I have got three areas I would like bring that to our attention? to explore briefly with you, but before I do can I Mr Hall: I think that it would very quickly come to explain that I have another meeting to go to and attention. The processes that we have for monitoring V when I walk out it will not be in disgust at your our e ectiveness are public and taken right to the evidence. I apologise for that before I start. Can I highest level in terms of NATS itself, but also the start with safety? You were nicely installed in the monitoring that we have through the CAA ensures stalls, listening to the previous performance, and you that there is complete transparency in terms of our heard, first of all, a compliment that you are amongst safety management and safety organisation. It is the best in the world at the job that you do, and then common for the CAA’s inspectors to be present in it was suggested that, because you are, you would our operations rooms on a day-to-day basis, become complacent. Do you have any sense of confirming for themselves that we are sticking to the complacency? standards and that there is authenticity to the Mr Hall: No. performance reports that we produce.

Q348 Chairman: You could not say yes to that! Q351 Mr Wilshire: I appreciate that, but the specific Mr Hall: There is absolutely no way could I say yes thing that I asked was would you be able to give us to that. I have got an emotional answer to that and an undertaking that you would draw it to our I have got a technical answer too. The emotional attention? I understand that it may well become answer is that I think it is quite diYcult for anyone clear, but that was not quite the same thing as I who is not involved in air traYc control to asked you. understand the personal connection that people Mr Hall: I am not quire sure, in a really specific way, have to the subject of safety. We are totally, how to answer that question. Are you asking would constantly abhorrent of the risk of aircraft getting we constitutionally, in a sense, by-pass all the close together and, of course, worse, there being a processes, and come to this committee? Is that the collision. It is something we live with day in, day out, question? so the notion of complacency is anathema to us. The second thing is that we absolutely understand and Q352 Mr Wilshire: I am not necessarily asking that maintain that safety is our top priority and because you by-pass. I might be suggesting that you copy of that every business case that we look at includes us in. an analysis of the safety benefits which come with it. Mr Hall: I can certainly take that away. I do not Not only that, we have inside NATS just revised our know constitutionally how to commit to doing that, strategic plan for safety and committed and but I am sure we do not have a problem with it. identified precise resources to be applied, not only to maintain safety, but to take safety to whole new Q353 Mr Wilshire: Can I make the suggestion that standards, and so, despite the fact that it is good to you do take it away, you reflect on it, you ask those hear that our practices are celebrated and taken on people I am sure you do need to ask and then write by other people, we are relentless in our pursuit of to us saying what your conclusion is? finding further ways to improve safety. Mr Hall: With pleasure.

Q349 Mr Wilshire: Do you have any sense at all, in Q354 Mr Wilshire: That would be helpful. Could I the developments that are taking place in Europe, move on, Chairman, to the use of runways for a that there is even the slightest risk that your moment. What do you consider to be optimum use standards will be compromised? in percentage terms of a runway? Mr Hall: It is very diYcult to imagine any way that Mr Hall: What we can say is that a high-performing that could happen, and the reasons are the safety runway, under good conditions (and I would use management systems that we have got, but also the several of the airports in the London area as confidence that we have in the regulator that we have examples) can operate to very, very high levels of in the Civil Aviation Authority, which is also utilisation, and I think the documentation indicates committed to ensuring that UK standards are not that Heathrow operates at 98%. I think that diluted through the establishment of standards at probably reflects some degree of averaging, because European level and, in particular, EASA. I should the declared capacity for some of these airports is also say, if it was not clear from the arrangements regularly exceeded by the numbers of flights that under the Single European Sky, that standards at a turn up, and that is what leads to the queuing—the European level must be applied at a state level, and queuing on the ground and the queuing in the air. it is the state level that gets to determine if it wants Therefore, part of the utilisation of runways which any additional measures put in place over and above needs to be considered, and, in particular, of course, the European standard. Everything that I have seen as a consequence of the announcement on runway so far points towards, not a dilution in UK airspace three, is the extent to which runway utilisation as a consequence, but relentless pursuit of should be reduced from its maximum theoretical strengthening that, and I am quite confident that capacity in order to provide greater resilience and that will be maintained. allow for the shift that happens in schedules because Processed: 06-07-2009 18:38:30 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Ian Hall, Mr Alex Bristol and Mr Lee Boulton of the vagaries of air travel but also because of the in advance of some firm proposals is probably eVects of the weather. That is one of the issues in excessive cost, and yet, if a project is not going to be terms of a framework of policies that might be viable from an air traYc control or a safety reason, helpful when it comes to establishing the real would it not be better to know that earlier because airspace design. of the other costs, that would be abortive costs? Have you any solution as to how you might find a Q355 Mr Wilshire: Can I take that answer as being way of meeting those costs or expecting other people an indication that trying to use a runway at 98%, to help you meet them so that you can start work which is what Heathrow tries to do, is probably not earlier? a good idea on the basis of fog, thunderstorms and Mr Hall: In terms of the arrangements, if we were to other things? understand, for example, that the clear priority was Mr Hall: What I am saying is that it is an inevitable to limit the climate change impact of additional trade-oV and it is not one that NATS can make the flights, then we would be saying we could put call on. What we can do is provide the infrastructure together a structure that did that but it would not to support whichever decision, in terms of priorities, reflect the trade-oVs for other environmental there is general consensus around. At the moment impacts such as noise, visual intrusion, and I know we are living with the consensus view that queuing in the sensitive issue of alternation at Heathrow has an the air and queuing on the ground is worth it in terms impact on the routes and has an impact on of the benefits of the high levels of runway utilisation. These are other sensitivities that it is utilisation, amongst the highest runway utilisation impossible for us to model in until some view is in the world, right in the middle of the most complex taken about the extent to which those trade-oVs airspace in the world. must apply, and what we are looking for through the work that we are doing with the CAA and the DfT Q356 Mr Wilshire: So you are accepting that there is on the future airspace strategy is to try to establish a link between queuing on the ground and stacking where these key issues are likely to appear and to and high use of a runway? start to take a view about the likely scenarios against Mr Hall: Yes, I am. which we can produce our long-term plans as part of the process that we are trying to put in place at the Q357 Mr Wilshire: Therefore, in order to reach some moment. of the environmental objectives, it would be sensible Mr Bristol: May I add to that? To give an example to use the two existing runways less than they are of the Heathrow third runway, we have not done no used at the moment? work at all on this. The initial part of work was done Mr Hall: Yes, I think, as we stand at the moment, to have a look at whether it is, indeed, feasible. We that is an obvious trade-oV that we have got. We would then see if there are show-stoppers. If there have got queuing. We could reduce the queuing if we are, we would then make those clear. It is not quite reduced or used the increased capacity, for example, as cut and dried as not doing any work at all until a for runway three to first reduce the queues and then third runway is announced; there was some increase the utilisation. The issue about fog and high feasibility work done previously. winds, and so forth, is another decision, again, because it happens very infrequently and there would be a clear waste of capacity if we were to Q360 Mr Wilshire: Are there any show-stoppers? assume every day was a foggy day. Mr Bristol: No.

Q358 Mr Wilshire: Is it a coincidence or is there Q361 Mr Wilshire: Could I ask you about a diVerent more to it? Frankfurt, Schiphol and De Gaulle seem sort of show-stopper? I understand that it is your to think that 75% usage is about as high as you view that if Boris Island were to be built the only way should go. in air traYc control terms that it could be operated Mr Hall: It is very diYcult to make these straight with flights coming out from the west or going in comparisons. The procedures that we operate to in from the west would be the closure of Stansted, confined airspace are practised to levels that these Heathrow and City Airport. Is my understanding of other airfields cannot quite support. That is one your position correct? aspect. The other aspect is they have got many more Mr Hall: I would not go quite as far as that. What runways and they have got massive airfield I was trying to do was illustrate that, by adding an infrastructure. We had the pleasure of being in additional piece of infrastructure into that very Amsterdam yesterday, where, after you have landed, complex mix, it would have a very direct impact on you are taxi-ing for 15 or 20 minutes to get anywhere the overall capacity of the London area. In other close to the terminal building. It is the same at Paris. words, you would get a much better increase in It is much less at Heathrow after you arrive, because capacity by expanding existing infrastructure than it is much more compact, so the pressure is not on you would if you built that infrastructure somewhere them to achieve the levels of utilisation that we are else after that. attempting to achieve in our airspace.

Q359 Mr Wilshire: The third thing, Chairman, is Q362 Mr Wilshire: In order to use a new airport built airport development. You make the general point in the Thames Estuary you would have at least to that the cost of doing a great deal of detailed work curtail the use of Stansted, Heathrow and City. I Processed: 06-07-2009 18:38:30 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Ian Hall, Mr Alex Bristol and Mr Lee Boulton have heard you explaining this. Is it minor Mr Hall: No, they have not. curtailment, is it complete closure, or is it something in between? Q367 Chairman: You are quite sure. It has not been Mr Hall: It really is a matter of trade-oV at the end suggested to you it might be better if you had a less of the day, but it is our responsibility to make it clear firm view? that, from our point of view, if you were to add Mr Hall: I have not spoken to anybody on the additional infrastructure such as that you should not subject, since we spoke at Swanwick, until the expect to get the full benefits and you certainly question was asked here. should not expect to get the same benefits as if you expanded existing infrastructure. I should also say Q368 Mr Wilshire: Let me see if I can have one last that we have not done the detailed work on that. We go at clarifying this, at least in my mind if nobody have not seen any specific proposals, for example. else’s. If a four-runway or a three-runway airport Informally we have been putting in some inquiries to were to be built in the Thames Estuary it would not establish what the likelihood is, but it goes back to be possible to use that airport at its full capacity my previous point (and I understand your point as without reducing the use of Stansted, Heathrow and well about chicken and egg here). We can go so far Y City Airports? in saying it is di cult to see how you would really get Mr Hall: That is our view, yes. the benefits. On the other hand, until somebody Mr Wilshire: A compromise then. Thank you for comes up with some proposal, we cannot do any that. detailed work on modelling to find out what might be possible. Q369 Chairman: Do commercial interests have the power to overrule any view you may have on the best Q363 Chairman: That sounds, Mr Hall, as if use of airspace around airports? somebody has suggested you modify your views. Mr Hall: The processes for deciding on our own Would that be right? commercial interests within NATS in terms of what Mr Hall: I am sorry? we invest in are a direct consequence of the consultation processes that we follow and the Q364 Chairman: Your recent statement suggests that priorities that are set for us by the DfT, by the CAA somebody has suggested you should modify your and by the customers themselves. We are hugely earlier views on the impact of the possible new sensitive to the diversity of the airspace users that airport. Is that right? require access to our airspace, and we are also very Mr Hall: No, I think we have been consistent all the sensitive to the issues on the ground. It is because of way from our contribution to the 2003 White Paper that sensitivity that we will invest in systems that do about the general approach to adding capacity in the not appear to have any commercial value for us London area. I also think that we have been whatsoever but are of benefit to our customers. Our consistent in our view that it is much better to commercial arrangements and the returns that we expand existing infrastructure than it would be to expect to get on any of our own investments, which create new infrastructure. is the source of our income; in other words, our own commercial interest is in satisfying the customers Q365 Mr Wilshire: It is a slightly less firm and the infrastructure around us. What that means explanation you have given this afternoon than we is that we consult extensively with our customers on were given when we visited Swanwick, where we all of our capital investment plans, and we are were told that it would involve the closure of capped in terms of the capital expenditure we are Heathrow, Stansted and City Airport. allowed to use. Despite that, we still will reflect it in Mr Hall: I am sorry if it appears to contradict that. customer need as a baseline for making our Certainly there has not been any subsequent commercial decisions. conversation or clarity of policy on this point. I remember the discussion that we had at Swanwick, Q370 Mr Leech: NATS has said that it is vital to and we stood in front of a map to try and illustrate work with the CAA, to be proactive in developing the point, and I am sorry if the language came across new technologies and techniques and, to quote you, in a more, how can I say, precise way than was “where necessary, mandating equipment to ensure intended. What we were trying to do was indicate the consistency of application”. Has the CAA failed to problem that was created by trying to do it rather be suYciently proactive in mandating valuable than to say that one or all of them would have to technologies and techniques? close as a consequence. I remember saying that if you Mr Hall: The rule-making processes require put an airport here and an airport here and the consultation, and there is one specific example of departures from this airport were flying straight potential rule-making which had been notified, towards the flights that were arriving for the other which is the mandatory carriage of transponders. airport, then something would have to give, and This is a piece of radio equipment on an aircraft that right at the moment we do not see how those two has the ability to transmit to air traYc control and to airports could operate at full capacity at the same other aircraft their identification and the height that time. It is as simple as that. they are flying. It can also go on and give air traYc control additional information which is helpful. Q366 Chairman: Has somebody suggested to you When the consultation process was followed, that you should change your position? against a clear indication of an intention to Processed: 06-07-2009 18:38:30 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Ian Hall, Mr Alex Bristol and Mr Lee Boulton implement this rule, for which we were gearing our Mr Hall: I cannot be sure exactly what systems they investments, the response to the consultation put the were talking about, so it would be diYcult for me to CAA oV proceeding with that rule-making and now respond to that in context. SuYce it to say that carriage of transponders is not anticipated until British Airways, amongst many other airlines, have 2012. This, for me, is an example of what happens if a very modern fleet which is very well equipped and the rule-making process that we discussed earlier, could operate in more advanced ways, and if we were even at a European level, breaks down; that you find able to ensure that the whole aviation fleet was one part of the infrastructure is geared up to assume established to the same levels, then, yes, there are the benefits of rule-making, particularly on more things that we would be able to implement. equipage, and then it does not happen and you have got some costs but no benefits, and we ended up in Q374 Mr Leech: Is there an argument for airports this instance having to invest more money to make being able to restrict the use of aeroplanes that have the airspace safer until we can get to transponder got the most up-to-date technology? carriage. Mr Hall: I think in any of the systems that you want to optimise, if it requires the benefits to be achieved by everyone meeting the same level of capability, Q371 Mr Leech: So it is fair to say that the CAA Y then, yes, it is justified, and I say that from the have failed to be su ciently proactive? perspective of the whole nature of air traYc control Mr Hall: I do not want to give the impression of a being around the fact that it relies on people being judgment on the CAA itself, but what I do want to equipped to the relevant standards and then do is reflect on the process which the CAA is obliged applying the rules that are required to operate it. to go through and demonstrate that the consequence of following it in the way it did resulted in the non- Q375 Sir Peter Soulsby: Can I follow that up? I do implementation of a rule that was going to be very, not know if you know the answer to this, but is the very valuable for UK airspace, and I want to point retrofitting of this sort of equipment very expensive to the need for us to learn the lessons from that and compared with the costs of operating aircraft? make sure that the subsequent rules that need to be Mr Hall: Yes, that is one of the arguments that has put in place are put in place much more firmly. That been put forward for many years. Many of the is why I think, both through the framework of Single aeroplanes can last and run through various cycles to European Sky and by having a clearer policy be used for diVerent uses in diVerent places, and framework for the implementation of these rules, the what we have to acknowledge is that when you have DfT can support the rule-making and build up got highly complex airspace and you are going to run greater momentum for the CAA to ensure that the at these sorts of levels of utilisation, you may need rule-making really does come into force. tighter rules than you require elsewhere. Much of the infrastructure in Europe is established around a Q372 Mr Leech: So what else needs to be done now capability that assumes that there will be radar there rather than waiting for the future? and that radar will see the aircraft and deal with Mr Hall: The sorts of equipment that we want to them. In Australia, for example, there aren’t radars implement in the near future will depend on rule- all over Australia, so they require a completely V making. The transponder carriage in 2012 is an di erent set of equipment to be carried on the V absolute must. The rule-making to support the aircraft to operate e ectively. It does not mean that development of the precision navigation systems we want the same rules in every bit of airspace everywhere, but it does mean that if people are going that were being discussed will also have to be Y implemented in those sorts of timescales. There is to operate through the systems where the e ciency already a rule for us to implement data link of the system relies on everyone being able to operate capabilities so, instead of controllers speaking to in the same way then it follows that there should be rule-making. pilots, they can send messages straight on to the flight deck, and that rule is due to be implemented in 2013. We would like to see further rule-making Q376 Sir Peter Soulsby: What I was trying to get the behind that to ensure that the benefits achieved by flavour of was whether for the airline operators the the technology can be accelerated and brought fitting of the kit, whether it be transponders or the forward. At the moment it is diYcult to see how to more sophisticated navigation kits, is actually a very get those rules put in place. I am trying to illustrate expensive process when retrofitting to aircraft over the point—I appreciate the question—of being their, whatever, 30-year, 40-year life? focused on what are the clear rules that will really Mr Hall: They certainly tell us that it is, and it is not move the game forward and produce benefits just the fitting of the equipment itself, it is the amount of time that the aircraft has to be taken out quickly and then getting everybody committed and of service in order to carry out the work, but, of the industry committed to delivering them. course, the safety standards are so high that fitting equipment in aircraft is much more expensive than it Q373 Mr Leech: British Airways have said that is doing it on the ground. “airlines would already use these techniques if they were not constrained by UK and European air traYc Q377 Chairman: The CAA question whether there control practices which we believe can be made more have been any real capacity benefits as a result of the flexible”. Would you agree with that assessment? Single European Sky. Do you agree with that? Processed: 06-07-2009 18:38:30 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG4

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18 March 2009 Mr Ian Hall, Mr Alex Bristol and Mr Lee Boulton

Mr Hall: I think that progress to date under Single and long-term improvements, and the short-term European Sky has resulted in many of the service improvements are already being considered with providers, such as NATS, getting together to think changes to airspace arrangements to allow flights to about, “Right, from today how do we optimise the fly straight across Ireland and as far across the UK system? How do we align our routes and make it as possible towards continental Europe in the more eYcient?”, so the process has started. Under morning, for example, without having to turn the Single European Sky I am very confident that various corners along the way to stay in line with the greater eYciency in terms of airspace will evolve but, current airspace arrangements. At the moment the more importantly, the future eYciency in capital focus is on operational eYciency. The next thing we investment will result in lower costs for increased will have to turn to is how we create more eYciency capacity across the system. in the operation of the ATC arrangements in both countries. Q378 Chairman: So you see it as an eVective project? Q380 Chairman: Are you confident you will be able Mr Hall: Yes. to do that? Mr Hall: Yes, we have got some very specific targets Q379 Chairman: What are your views of the which we have set and we are committed to. By the eVectiveness of the UK/Ireland functional airspace end of this year we will have produced a plan to take block? us from 2010 to 2013, which is chosen to coincide Mr Hall: We were the first, with the Irish, to with the end of the SESAR period and the announce a FAB in June last year and we have just implementation of the benefits of that, so it is all delivered the report for 2008 and a plan for 2009. timed to fit into the progression from FABs into The structure of the work is such that, with the Single European Sky implementation. airlines, we have the military and we have the unions Chairman: Thank you very much indeed for involved in identifying short-term, medium-term answering our questions. Processed: 06-07-2009 18:39:01 Page Layout: COENEW [SE] PPSysB Job: 412381 Unit: PAG5

Ev 64 Transport Committee: Evidence

Wednesday 1 April 2009

Members present

Mrs Louse Ellman, in the Chair

Mr David Clelland Sir Peter Soulsby Mr John Leech Graham Stringer Mr Eric Martlew Mr David Wilshire Mark Pritchard Sammy Wilson Ms Angela C Smith

Witnesses: Mr Tom Needham, Head of Operations Policy, Airport Operators Association, Mr Tim Hardy, Airside Director, BAA Airport Limited, Mr Paul Kehoe, Chief Executive OYcer, Birmingham International Airport Ltd, Mr Richard Gooding, Chief Executive, London City Airport, and Mr Simon Butterworth, Head of Airfield Strategy and Compliance, Manchester Airports Group, gave evidence.

Chairman: Good afternoon, gentlemen, and Q384 Chairman: Does that mean that you will have welcome to this Select Committee. I know we seem a key role in making those decisions? a long way away, but we are not really very far. Do Mr Hardy: Yes, I will. members have any interests to declare? Mr Clelland: I am a member of Unite. Mr Martlew: I am a member of Unite and GMB Q385 Chairman: Does that mean that the statement unions. that NATS has given to us, that it is vital to schedule Graham Stringer: I am a member of Unite and an ex- below capacity limits and that the third runway member of Manchester Airport, former Chair of could be used to build resilience into the system, is Manchester Airport. something that can actually be put into practice? Mr Hardy: Yes, that is exactly right. We will have to Ms Smith: I am a member of GMB. Y Chairman: Louise Ellman; I am a member of Unite. look at the implications of the tra c that uses the Sir Peter Soulsby: I am a member of Unite. northern runway and what that means for the Mr Leech: Because we are talking about airports, I resiliency of the airport as a whole. In fact, as a first have to declare a beneficial non-pecuniary interest in step towards that, we are examining the resiliency of a piece of land surrounding Heathrow Airport. the existing two runways now since the announcement in January.

Q381 Chairman: I would like to ask our witnesses, please, to identify themselves for our record. Q386 Chairman: How far has that discussion gone? Mr Kehoe: Paul Kehoe, Chief Executive, Mr Hardy: Again, necessarily in these matters this is . a complicated area of discussion. We are some few Mr Hardy: Tim Hardy, Airside Director, BAA. months down the road with our partners in Mr Needham: Tom Needham, Head of Operations considering the resiliency implications of Heathrow. Policy, AOA. We expect to have some outline proposals in place Mr Gooding: Richard Gooding, Chief Executive, within the next couple of months. We wish to discuss London City Airport. those with the Department for Transport to get a Mr Butterworth: Simon Butterworth, Head of view from their side on the viability of those Airfield Strategy and Compliance, Manchester proposals and whether it ensures the resiliency that Airport. we are looking for.

Q382 Chairman: Mr Hardy, what commercial Q387 Chairman: Have the Department for assurances have you had from NATS that the third Transport given you any indications up to now? proposed runway at Heathrow is feasible in terms of Mr Hardy: We have had one exploratory meeting airspace issues? with the department and we have discussed, in very Mr Hardy: I should say that we have had no broad terms, some of the tactical options that we commercial assurance, because the process of have to enable further resilience at Heathrow and, airspace design for runway three has not yet been therefore, in a three-run way environment we expect completed and it is subject to a number of options to be able to explore and expand those resiliency that at the moment we are considering along with options going forward. NATS. Q388 Mr Wilshire: On this subject you have said that Q383 Chairman: What are those proposals? BAA would expect to have a big say in the usage of Mr Hardy: Those proposals will be the eventual split runways. I can understand that. At the moment the of traYc, for example, on the new runway, the two runways are used in the order of 98% of the time. pattern of the traYc, the number of aircraft that are There are those around the industry who indicate required to cross runways to access that new runway. that 75% is a sensible maximum. What is your view It is a very detailed piece of work. of a sensible maximum use of a runway? Processed: 06-07-2009 18:39:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG5

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1 April 2009 Mr Tom Needham, Mr Tim Hardy, Mr Paul Kehoe, Mr Richard Gooding and Mr Simon Butterworth

Mr Hardy: I guess the best way to answer that Mr Gooding: Leaving to one side whether such a question is that when we go into planning the use of venture is ever fundable at all and deserving of our runways we go into it in collaboration with the attention, the view that we hold is that the site airlines, with NATS and with ACL, the slot co- proposed for the Thames Estuary airport is actually ordinator, so it is a very community-based approach further in a straight line away from London City as to how those runways are used. In terms of the than Heathrow currently is. We have found a way practical limits, 98%, or thereabouts, is where we over many years, 25 years almost now, to have a have the best balance between capacity and delay, modus operandi with Heathrow which has worked and that balance between capacity and delay has perfectly well, and so, with an airport further away, been established for some 10 to 15 years or so. we should be able to work out a suitable system. I Having said all of that, there are circumstances have to confess, there is no work going on on this at where the operation of the airfield becomes more all because of our scepticism about whether this complicated in the event that there is any disruption, project has any real prospect of ever coming to and there are a number of ways in which that fruition. disruption can be mitigated in future with the new technologies around air traYc management. Q394 Mr Wilshire: What about the view about Heathrow and Stansted being vulnerable? Q389 Mr Wilshire: But I am right in thinking that, Mr Hardy: I would echo the comments made by Mr in the event of a third runway, there will be fewer Gooding. There is no work being carried out at the aircraft landing and taking oV from the existing two moment on a new Thames Estuary airport, runways? particularly from an airspace perspective. It is not Mr Hardy: I think it depends on how the capacity out of the question that it may introduce new areas declaration is handled. We already know that we of population to noise which are unaVected at the would have approval to go as high as 605,000 ATMs moment. The issue of the proposed estuary airport: from the current cap of 480,000. The theoretical we have not yet been engaged on it or what the maximum of those three runways is 702,000 ATMs; impacts to businesses would be. so there is already built into the plans a significant degree of resiliency. Q395 Mr Wilshire: It seems, Chairman, that we have three answers: one is that they would have to close, Q390 Mr Wilshire: Is that a, yes, or a, no, there one is that they would have to reduce and now we would be fewer flights on the two runways? have a third one saying it would not matter. The Mr Hardy: Overall, on average, there would be matter gets more and more confused. Thank you, slightly less. Chairman. Mr Kehoe: Can I add a fourth? Q391 Mr Wilshire: The flight paths that you would use for the new runway would not be the same as for Q396 Mr Wilshire: There are several of you. Let us the old runways? have a fifth as well! Mr Hardy: No, the new standard instrument Mr Kehoe: I agree with Richard Gooding in terms of departure routes and, subsequent to that, the new the fundability, but if it were to be built I think there designed departure routes may follow the same are other issues, not only for Heathrow, Stansted tracks but, on the other hand, they may not; it just and London City, but Amsterdam and the Belgian depends on how the airspace redesign around FIR (flight information region), because it is so far Heathrow proceeds. into the channel that the descent routes would need to occur over Belgian and Dutch airspace.

Q392 Mr Wilshire: So it would be reasonable to say that fewer flights in and out of the two runways at Q397 Graham Stringer: Have all of the airports that the moment would mean less noise for those under you represent produced master plans for the use of the existing flight paths? UK airspace? Mr Hardy: The balance round the six ends of Mr Kehoe: A master plan for airspace, no. A master runways would be such that the volume per end of plan for the ground infrastructure, yes. runway would be reduced. Q398 Graham Stringer: Anybody else? Mr Gooding: I think all of the largest 29 airports in Q393 Mr Wilshire: Thank you. Could I next bring the UK have produced a master plan, as we were City Airport in on this? We were told in a visit to required to do by the 2003 White Paper, but that Swannick by NATS that the consequence of a does not take account of airspace. Thames Estuary airport would mean that Heathrow, Stansted and City Airport would have to close, and I am quoting what they said rather than inventing Q399 Graham Stringer: Have the CAA carried out what they said. When they gave evidence they back- their commitment to complete the redesign of UK pedalled furiously on that, saying that it means there airspace, as was required in the Aviation White would have to be fewer flights out of City, Stansted Paper, to your knowledge? and Heathrow. Which of the two comments that Mr Butterworth: We have seen no evidence of that NATS have made to us is true? so far. Processed: 06-07-2009 18:39:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG5

Ev 66 Transport Committee: Evidence

1 April 2009 Mr Tom Needham, Mr Tim Hardy, Mr Paul Kehoe, Mr Richard Gooding and Mr Simon Butterworth

Mr Needham: There have been no obvious moves by Mr Kehoe: I think the airspace breakdown is roughly CAA or DAP to engage with the airport community 40% which is used by commercial aviation and 60% on airspace strategy in terms of a national plan. which is Class G, or the open FIR, which is also used by the military.There is a question, I think, that if the RAF has reduced in size over the last 20 years, Q400 Graham Stringer: That is quite worrying, is it because of a lack of a cold war, from 90,000 down to not, because if they are not engaged now, then they might not be ready for the 2011 White Paper? Is that 30,000, there must be a consequent reduction in the your understanding? number of aeroplanes flying, and many of those that Mr Needham: Indeed, that is the vulnerability, but as are flying in the UK, presumably, are in support of I believe the CAA presented in their evidence, their operations in and Afghanistan. One has to beg rationale for delaying the future airspace strategy the question, why do they need the large requirement was the decision on runway three. of airspace for purely air defence in the north and training in the Midlands and East Anglia? I think there is a question over the allocation of airspace for Q401 Graham Stringer: What are the consequences military uses going forward. for your businesses of not having that redesign? Mr Butterworth: Can I oVer a specific example of Mr Needham: What we will have is to continue with that? What we are seeing in Single European Skies II the existing arrangements set down in CAP725, and the general requirement for more eYcient use of which is the current airspace change documentation, airspace, and more eYcient public transport by air is but in terms of a national strategy which the 2003 more ability to do point-to-point traYc. That is not White Paper promised, we would strongly support possible with the current design of airspace because that, particularly as we would then have to interface it forces aircraft to fly down specific corridors, with developments on European airspace as avoiding other areas of protected or restricted undertaken by the Single European Skies and airspace. A specific example may be that to fly from CESAR initiatives. Humberside to Jersey you currently have to route via North Wales, which is not a direct line of sight. Q402 Graham Stringer: I understand that those are the objectives. What I am trying to get at is whether Q405 Graham Stringer: Clearly not. I know very there are any good impacts or bad impacts on your little about this, but my children would say it does business of the failure of the CAA to redesign the not seem fair, the allocation of 60:40. When you look airspace? Mr Butterworth: The straightforward consequences at the actual number of aeroplanes, it must be vastly that we will see are that we will continue to see the weighed down on the side of commercial flights. Do amount of delay that we currently have in the you know of the justification for that balance and system, we will probably see an increase in that delay what do you think the right balance of the allocation as traYc growth returns to the industry and we will of airspace should be? not be able to take advantage of the potential Mr Butterworth: If you look to the response that the environmental benefits that can be gained by CAA, Department for Transport, the Department of potentially changing airspace. Airspace Policy gave you, it was that they feel that they are acting in Government policy interests in terms of how they find a policy in the use of airspace. Q403 Graham Stringer: Is it possible to quantify Our opinion is that there is a wholesale need for a those impacts? I appreciate that answer, and it is very review of that given that things have changed over valuable, but it would be even more valuable if you the decades, and if we are going to adopt a use of could quantify the cost to the environment—the cost airspace which is compliant with the future needs of in time and the cost in delays. Is there any work environment and Single European Skies, then it being done on that? needs to be under a strategic framework of a master Mr Kehoe: Not at this stage, but I think you are plan that allows the best benefits for users. absolutely right to ask that question, because the key is that with uncertainty comes commercial risk and commercial risk equals cost. We are without an Q406 Graham Stringer: I understand from my environment or a framework. We have a very briefing that commercial airliners are allowed to use sensible White Paper on the ground, we need to be military airspace at weekends. Is that of any use? able to launch the aeroplanes that we are planning Does it make much diVerence? Is it helpful? Could for on the ground into the air but there is a that process be followed for the other days of the disconnect between the two at the moment and with week? that there is uncertainty. Mr Gooding: I think it is diYcult to be able to count on it, and that is the trouble. Also, the weekends are Q404 Graham Stringer: That is very helpful. Can I the time of lowest business traveller use of aircraft move on to monetary aspects? In some of the anyway, but the real thing is the lack of certainty. I submissions there have been complaints that there is think the military appear to feel that they are being inflexibility with the use of military airspace. Can sensible and flexible, and from their viewpoint I can one of the witnesses tell me what the real problem is see that, but from our point of view and, more and what they would like to see in terms of the importantly, our airline customers, we cannot count change of civilian airspace and military airspace? on it. Processed: 06-07-2009 18:39:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG5

Transport Committee: Evidence Ev 67

1 April 2009 Mr Tom Needham, Mr Tim Hardy, Mr Paul Kehoe, Mr Richard Gooding and Mr Simon Butterworth

Q407MarkPritchard:MrGooding,howwouldano- Q412 Mark Pritchard: Can I glean from your answer fly zone over Parliament impact on your business? that your members, the Airport Operators Mr Gooding: At the moment one of our arrival Association, are very relaxed about the lack of routings passes not very far from here; so we would competition? have to move it. That is a rather simple example. We Mr Needham: I do not believe I said that. I think that do have arrangements, in times of heightened what we have within the UK airports community is a security, to not fly over this area and, if there was an dynamic and competitive market place. There have emergency situation, we would trigger those been questions raised about the position of BAA arrangements. If this was a long running situation, which have been addressed by the Competition then we would have to sit with our colleagues in Commission,butintermsof theoverallmarketplace, NATS and Department of Airspace Planning to I believe that we have a competitive and contestable figure out what we would do. market.

Q408 Mark Pritchard: Would it impact on your Q413 Mark Pritchard: So you think the Competition business? Commission got it wrong on the monopoly point? Mr Gooding: In the short-run, clearly it would be a Mr Needham: I did not say that. nuisance and be highly likely to impact. In the longer- run, we have for a long time had to fit ourselves into a Q414 Mark Pritchard: No, but do you think they did? zone that was in other people’s zones, so we are rather Mr Needham: I would prefer to give that question used to having to behave flexibly and make changes. some more consideration before responding, to be We would need to go through the process as outlined perfectly frank with you. in CAP725 to achieve that. Q415 Mark Pritchard: Would you be prepared to Q409MarkPritchard:Thankyou.MrHardy,areyou write to us on that? pleased or displeased with the Competition Mr Needham: I think so. Commission’s findings with regard to competition of Mark Pritchard: Thank you very much. British airports? Are you content see Gatwick and Stansted sold oV? Q416 Mr Leech: On the point of competition, if Mr Hardy: I think as far as the Competition competition is widened in the south-east, will that Commission’s findings are concerned, in general potentiallymake itmore diYcultinterms ofthe useof terms we have been disappointed by the way in which airspace if you have other airport operators vying for the conclusions have been reached. Nevertheless, we additional business and additional traYc? tookthedecisionbackinSeptembertocommencethe Mr Needham: I think the key to the future on that sale process for Gatwick, in advance of the question really isthe development of aviable airspace CompetitionCommission’sfinalreport,andweareat strategy for the UK as a whole. I think that the future the moment considering the options around the airspace strategy which the CAA are speaking about report that has now been presented and will get back will concentrate very heavily on the congested to the Competition Commission by the due date with airspace in the south-east, and what we are hoping is our view of how the rest of the divestment should that the outcome of that will be a sustainable proceed and what our actions would be as a result. framework within which all airports can operate.

Q410 Mark Pritchard: Of course, you may be Q417 Mr Leech: If there are lots of diVerent airport disappointed by the Competition Commission’s operators, as opposed to a smaller number, is there findings. Some of us were disappointed that the potential for making it more complicated to deal Heathrow was not thrown into the mix as well, given with airspace? BAA’s (in my personal view) poor customer service Mr Needham: There are not going to be any more levels. Maybe there will be an opportunity for that to additional airports. happen at another time. Edinburgh or Glasgow: which would be your preferred option? Q418 Mr Leech: No, diVerent airport operators who Mr Hardy: I have to say very much the same answer. might want to compete with each other. Weare considering our proposals at the moment as to Mr Needham: I do not see how that would necessarily which of those two airports would be the one that we impact upon the airspace, but maybe my colleagues would propose to be divested. That work has not yet have diVerent views. been completed. Mr Hardy: I would say that the three London airports, to take those first—Gatwick, Stansted and Q411 Mark Pritchard: Mr Needham, clearly I should Heathrow—serve a variety of markets in their own think your members would want to see, and would right anyway. If the competition resulted in them welcome, more competition? taking diVerent chunks of their individual markets Mr Needham: I have no evidence to present to you and using that as a competitive framework, I do not thatwouldsupportthatposition.Wearesimplyatthe think it would necessarily change the way in which present time awaiting developments. You have other airspaceis managed,controlled anddelineated, itjust memberssittingin BirminghamandManchesterwho depends on the overall volume of traYc coming into maywishtoexpressanindividualview,butintermsof the south-east of England, which in itself is a a collective view outside of BAA, I am not able to challenge now for all of the airports in the south-east; comment on that. not just because one airport is a competitor to Processed: 06-07-2009 18:39:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG5

Ev 68 Transport Committee: Evidence

1 April 2009 Mr Tom Needham, Mr Tim Hardy, Mr Paul Kehoe, Mr Richard Gooding and Mr Simon Butterworth another, it is a problem that we all share, and, in occurring at Birmingham are as a result of capacity responsetothisparticularinquiry,onethatwebelieve issues at places like Clacton-upon-Sea, so the strategically should be held by DAP. airspace above Clacton-upon-Sea may have an impact on the arrivals and departures through flow Q419 Mark Pritchard: Two brief final points. Mr control at Birmingham. Therefore, what we are Kehoe, regional airports are more and more saying is that we would like to have equal rights to important. I just wondered whether you would like to that airspace, but I am sure there are equal issues in comment on whether, with the increased traYc terms of the London TMA and the airports at Luton forecast for Birmingham and the extended runway, and London City versus the other three BAA there is likely to be a significant or perhaps a slight airports.Clearly,aswegrowuptoour205,000limitas (whatever option you wish to choose) use of airspace to air transport movement, we want to be able with and will entry to Birmingham via the County of some certainty to have the ability to grow into the Shropshire, in particular the Shropshire Hills area, a airspace, and that is the thing that we are uncertain of massive area of outstanding natural beauty, be at the moment, because there is no national plan, and impacted or will the heights be maintained at current we do need a master plan that follows the Aviation levels? White Paper. Mr Kehoe: There is an issue with Birmingham lying Mr Butterworth: I do not agree. I would not say there between two very high-level and dense traYc areas, is any particularly hierarchy between Birmingham Manchester to the North and the London TMA to and Manchester. Perhaps it is a question that NATS the south and, therefore, we do tend to get squeezed might be able to answer, given they operate the traYc from time to time. The other factor, of course, is that of all those airports and at the high levels across the ourrunwayliesatavaryingdirectionthanmostofthe whole of the UK. Our concern is that the airspace other runways in the UK. We are roughly north/ change process that we are currently required to go south, where most are east/west (and that is a fact of through is extremely complex and lengthy and it has history), and so there are some complex issues some measures that aren’t necessarily defined well surrounding the Birmingham airspace. I do not think enough in terms of how you balance them. That is in the short-term there is a need or, indeed, a plan that leading to a situation where we have got some we have looked at for our runway extension to start airspace change in the south-east that is going taking in large amounts of airspace to the west of us Y through an extremely lengthy debate, and has been overShropshire.Thereissu cientcapacity,provided ongoing for upwards of seven or eight years now.The that there are other things happening in the network knock-on impact of that is that the airspace change that will allow that to happen. that follows on from that is expected to be in the Manchester terminal area. We were expecting that to Q420 Mark Pritchard: Mr Hardy, this committee take place in the next few years, to take eVect from someweeksagosuggestedthatPresidentObamamay about 2012. Given the delays of the airspace change V wish to use a di erent airport to come to the country down in the south-east, we are expecting that to be to tominimise disruptiontothegreat Britishpublic,and be delayed by up to two years at the moment already; I am glad that he has taken the advice of this so our real concern is that, without a national committee and come through Stansted, but were strategic framework to the airspace that is required there any disruptions to the travelling public at across the whole of the UK, we do not see an end to Stansted as a result of the President’s visit? that problem being resolved. Mr Hardy: I understand the visit went well yesterday, so thereis noreason to suspectthere shouldhave been any over disruption or overly-disruptive events as a Q423 Graham Stringer: That comes back to the result. What I think was important is that the overall questions I was asking previously of the CAA not volume of visiting traYc to the UK was spread over a getting on with the re-designation of their plans. number of airports and not just focused, for example, Mr Butterworth: I think all my colleagues would on Heathrow. share the same view, that we do not have a national airspace strategy that matches that of the White Q421 Graham Stringer: I have two follow-up Paper on airports. questions. Mr Kehoe said that Birmingham is disadvantaged because you are sandwiched between Manchester and London. Q424 Graham Stringer: That is an important point. Mr Kehoe: We can be, yes. One final question. What underlies all of this is the estimates in the White Paper that in ground terms, in Q422 Graham Stringer: In Manchester there is recent 20 years’ time there will be half a billion passengers evidence, they say, that they are disadvantaged using UK airports. Do you think the figures in the because priority is given to the south-east system. 2003 WhitePaper are still credibleand, if theyare not, Could you both expand on that a little bit, because what figures would you replace them with? you are both claiming disadvantages and I would be Mr Needham: Certainly we believe that those figures interested to hear that exposed a little more? are credible. We believe that they are viable and we Mr Kehoe: I think in the food chain I am at the believe that the current economic circumstances may bottom, Manchester is above me and the TMA at see growth slow, but all the evidence is that when Heathrowiscertainlyabovethem,butthereareissues growth is slowed it has recovered and gone to the within the system in terms of the problems that are levels as forecast. Forecasts clearly can be wrong, but Processed: 06-07-2009 18:39:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG5

Transport Committee: Evidence Ev 69

1 April 2009 Mr Tom Needham, Mr Tim Hardy, Mr Paul Kehoe, Mr Richard Gooding and Mr Simon Butterworth we believe that the general approach of the White flights that that, therefore, they have less priority Paper is correct and that the forecasts presented are than others, whether it is business passengers, tourist still viable. passengers or whatever? Mr Gooding: Mostly you could look at this on the basis of whether it is an air transport movement or Q425 Graham Stringer: Is there not evidence from not. Is it a movement for hire? That is a fairly easy the first Gulf War and the SARS epidemic that what definition to strike. I am not pretending that my happens as well is the slope of the growth returns; suggestion is easy or simple, because it is not, it has you hit the projected targets later? complex implications and other people have views Mr Needham: Possibly. about it. What I am trying to illustrate is that if we Mr Gooding: That is true, but we need to bear in do not meet the demand, we need some form of mind that the White Paper proposes not providing rationing. My suggestion may or may not be the suYcient capacity to meet that market demand. So right one and there may be others, but we will need if the figures do not get to where they might have to have one if we want to meet the demand. The view done, we will see actual demand coming down nearer of my colleagues here, I think, is that the priority for to the capacity that is available. At the moment there government is to meet the demand. are 30 million passengers a year in 2030 who are not accommodated. Q428 Mr Wilshire: Collectively I think your submission, and those of others, have two recurring Q426 Sammy Wilson: Following on from that point, themes. One is concern about the strategy for the if the capacity of the airspace is not going to grow future and the other is about the change process and you do not believe it can grow in line with the itself. There are three questions that have occurred to number of people who wish to fly, one suggestion me on this. The first is that several of you have said that has been made—London City have suggested that the change issues with airspace represent “a this—is that perhaps we need to give some priority huge commercial risk”, not having an answer to the to various types of flights. The suggestion was put change process at this stage. Could you tell us why it forward that perhaps for business passengers, or for is a huge commercial risk? flights which are delivering business passengers, Mr Kehoe: Because it is aVecting us as we speak. Last some priority should be given there. Can you night Solihull Council gave us permission to extend elaborate on that? First of all, how practical is it to our runway. That permission has to go to separate flights in that way and, secondly, how do Government central oYce for the West Midlands, you believe that priority would influence the use of and we hope that will be a formality. My existing airspace? understanding is that the current CAP725 process Mr Gooding: What we were trying to illustrate was that we will now need to go through to redefine the that there is a current shortage of capacity in the airspace for that 400-metre extension requires us to market place in London and the South East, even in build the runway and then seek permission for the the current economic circumstances, because we still airspace change. Of course, my board would not see delays and what is called flow control, which is sanction the build of that programme without the keeping the aircraft on the ground at the other end airspace change being in place, knowing with because there is not a slot available. That is still certainty they were going to have it. So I think what happening today. That is how the excess of demand we are looking for from the CAA and DAP is is being dealt with now, which is essentially to form leadership and having a framework whereby we a queue. A perfectly legitimate solution to an excess have already agreed the elements of our master plan of demand is to form a queue, but we want to on the ground and in the air and that the planning demonstrate that there may be other ways of permission that we have now received last night addressing the mismatch between demand and would unlock the airspace elements and allow us to proceed with certainty. supply. One which we are all bought into is that there should be suYcient supply of capacity to actually meet the demand, because there are so many Q429 Mr Wilshire: Have others got experience of downsides to not meeting that demand. What we that sort that they can add? No? Another of the illustrated with business travellers was that “a way”, comments being made along these lines is that the not “the way”, of achieving a balancing up between uncertainty about both the strategy and the change supply and demand is to prioritise certain types of leads to delay in taking investment decisions. Do we traYc. It is matter of opinion whether business travel have any examples of that that will support the is the right one to choose or not, other people might assertion? choose diVerent ones, but I was merely trying to Mr Gooding: I think, as we go forward, we are more illustrate that that is the consequence of not meeting and more seeing that we cannot build any more the demand with airspace capacity; that we have to infrastructure on the ground unless we have got have some version of rationing. clarity of view that the airspace will match it, and right now in the little world I occupy we have slightly more capacity on the ground than the airspace can Q427 Sammy Wilson: In practical terms, though, feed us. So there is absolutely no argument, however can you divide flights in that particular way? Can keen one’s shareholders might be, to invest in further you take flights that come into particular airports ground infrastructure to meet whatever demand will and say they are such a homogeneous bunch of be unless I can match it up with the airspace. Processed: 06-07-2009 18:39:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG5

Ev 70 Transport Committee: Evidence

1 April 2009 Mr Tom Needham, Mr Tim Hardy, Mr Paul Kehoe, Mr Richard Gooding and Mr Simon Butterworth

Q430 Mr Wilshire: One of the sorts of points that is being held up by a process. That just results, as I said going to be made in detail is that the costs can be before, in delay. It may not be immediately obvious, huge in getting to a stage where you can get an but the travelling public are experiencing it right answer. Is anybody able to give some indications of now. the costs that have to be risked in order to get these things to a point where air traYc control can be Q434 Mr Wilshire: The third of the questions I brought to bear? wanted to pose to you is about your thoughts on Mr Gooding: It is multi-millions. We are talking lots what NATS say when one raises this issue with them. of money. I think it is diYcult to just pluck a number The answer that I have heard from NATS when one out of the air, but it is big money. An expansion says why do not they engage at an earlier stage is that which we recently carried out which required, not to do that sort of thing would be hugely costly and DAP approval, but actually SRG approval, we have until they knew what you wanted to do they would spent our £30 million building the project and then feel unwilling to spend money ahead of the decision. SRG, part of CAA, come and approve its use. That This sounds a bit like chicken and egg. Would you is a big risk for a relatively small company. care to comment on NATS’ view of why they do not do it in a diVerent way? Q431 Mr Wilshire: Does anybody in BAA have any Mr Gooding: I am somewhat surprised to hear that, feel for a ball park figure of the costs involved in because the one thing that I have learnt about NATS getting to the stage of a runway at Heathrow before is that they are really good at sending invoices. NATS would engage with you? Mr Hardy: In our preparatory work for the third Q435 Mr Wilshire: But that is not the same thing as runway we have spent, as Mr Gooding says, multi- spending money. millions of pounds on the programme to date and, Mr Gooding: No, but we have engaged them, in a therefore, we are already at risk for those amounts. sense, as private consultants in order to advise on In reality, as far as our customers are concerned, the exactly these matters. So they are not taking the risk, airlines, at some stage we will have to draw the line we are paying them to do that sort of redesign work. under these investments and recover it somehow. Mr Butterworth: One of the things underlying our There is some degree of doubt about how that would concerns about the development of the future work going forward. The trick, obviously, with the strategy for the use of airspace is that it currently new runway will be to make sure that we have the seems to be devolved to NATS, and whilst they may processes of planning and airspace approval running be the best body of expertise to deliver that, clearly in parallel so that we do not extend the risk any they are a commercial organisation and they have further, but it has to be said that, thus far, prior to got some concerns about where they are going to the Government’s announcement in January about recoup the benefits of that. Our view in the utmost runway three, we had already spent a number of sense is that the price really has to be paid by millions of pounds on the preparatory work. government for putting together that overview of the strategy of how airspace is divided up and used Q432 Mr Wilshire: If I could put to one side for a across the UK. minute the debate about the desirability or otherwise of expanding airport facilities and just focus on if we Q436 Mr Wilshire: You think the taxpayer should are going to do it: is it reasonable to suggest that the pay rather than the airlines, the airports and the way in which we do airspace work at the moment passengers? delays the actual physical process of delivering what Mr Butterworth: Ultimately everybody will benefit. we have decided we are going to deliver? Mr Gooding: It certainly can. It has the potential to Q437 Mr Wilshire: But this should be paid for by do that and sometimes, I think, it does. taxpayers, not by the users? Mr Butterworth: The development of the Q433 Mr Wilshire: Has it done so in the past? Are overarching strategy, we certainly believe, ought to there examples? be funded publicly, centrally, because it is of benefit Mr Gooding: I think the past has been very much a to the overall airspace of the UK, which is a national book of chapters, where each chapter has been a resource. piecemeal solution to the problem. We are sort of running out of piecemeal solutions, which is why Q438 Ms Smith: Going on from that, I hear what you have heard so much from all of us today already you say there, but somebody said earlier, I cannot about our keenness to see a national strategy for this: remember who it was frankly, that we need master because the previous localised piecemeal solutions plans for both infrastructure on the ground and use are no longer feasible or as feasible. of airspace; the two are inseparable in many ways. Mr Hardy: Can I add to that and say that some of The new national planning agreements that came in the impact of these delays is not immediately with the Planning Bill would obviously be a way of obvious, but actually, in terms of the travelling doing that and would take a lot of pain out of the public, delay is clearly the output of any planning system in many ways and solve the procrastination about approval of airspace redesign problem that was mentioned here. Do you think, and, obviously, as far as sector lengths are though, that under such a system the Civil Aviation concerned, it makes for a very ineYcient air traYc Authority should be responsible for developing such system to have airspace that should be redesigned national planning statements, not agreements, and Processed: 06-07-2009 18:39:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG5

Transport Committee: Evidence Ev 71

1 April 2009 Mr Tom Needham, Mr Tim Hardy, Mr Paul Kehoe, Mr Richard Gooding and Mr Simon Butterworth do you think attached to that would be the cost of Q442 Ms Smith: But you may have to pay more developing planning permissions for infrastructure perhaps. on the ground? Surely it should not be the taxpayer Mr Gooding: If we are getting the benefit, there is that should pay for that kind of development in already a mechanism by which that may be terms of planning permissions and all the rest of it? recovered. I think that probably more addresses Mr Kehoe: I think there is a view that the developer your question. should pay. I think we are agreed on that. If we are doing work on the ground that has an impact in the Q443 Sammy Wilson: On the whole question of air, I think we have to pick up that bill. I think where capacity, given that you have already described in we are coming from is that there is no national your answer, Mr Gooding, that we are probably well framework into which to launch anything, and I over capacity at present, hence the queuing, et think the Government has a duty to set the cetera, and that we are intending to double the framework, as they have done so well with the number of people flying in and out of the United Aviation White Paper, and we are launching master Kingdom by 2030, are you convinced that by plans at our cost into that framework. introducing new technology, creating additional airspace by squeezing some of the military uses, or Q439 Ms Smith: But the framework itself would whatever, and re-organising the way in which we use include a degree of work that would traditionally be existing airspace that we can create the capacity for undertaken by planners, in consultation with people the additional flights that you are predicting under such as yourselves, and in that sense it is not as clear- the strategy at present, or are we still going to have cut as you would like it, I believe. Surely it is not as to find some way of rationing the airspace in the way black and white as you would have us believe in you suggest or other people have suggested? terms of cost. Mr Gooding: It is a cocktail, is it not? There is the Mr Kehoe: There is another issue, in that if I make a cocktail of a mix between the military and civil, there decision to do something on the ground here, it may is the cocktail ingredient of new technology, as you well impact on my other colleagues. There has to be have mentioned and there is the cocktail ingredient a sort of super-national organisation that can look of rationing. I suspect our cocktail has got to have down and make sure that the plans I am doing do not elements of all of these in it. It is unlikely to be one impact adversely on Heathrow or Gatwick. So we do broad brush simplistic solution. need this overarching organisation. Q444 Sammy Wilson: But we should be capable, Q440 Ms Smith: I go back to my point. The through all of those things, of creating the ability to overarching organisation under the terms of the new deal with the increase in the passenger flow that we Planning Bill, as I said earlier, would take some of are predicting for the next 20 years. the pain out of the current planning system, and Mr Gooding: We should be and we need to remember some of the responsibilities currently undertaken at that the White Paper, of course, was consulted on local level would go to national level. Surely some of very widely, including with NATS and the CAA. the costs attached to the current planning system, Had they had genuine fears that it was which would then go national, ought to be met, as undeliverable, I think we might have heard before, by developers on the ground? something from them at the time. Mr Butterworth: I think there is acceptance at local Mr Butterworth: In addition to that, it might be level that the airspace changes required for certain worth looking at the work that Eurocontrol has developments at each location should be borne by carried out in that respect, because they have each location. The diYculty we have is that with a certainly looked holistically at the entire European number of developments across the UK that are system in support of the Single European Skies included in the Air Transport White Paper, across programme and CESAR in terms of quantifying just the whole of the UK, there are so many of them that how much capacity can be gained and what it is diYcult to determine who is responsible for throughput can be managed through that. which piece of capacity growth that is required in the main pieces of airspace. It is those major pieces of Q445 Chairman: Mr Gooding, you said to us in the airspace outside the local airport area that we are evidence you have given us that you think there going to be saying there needs to be a central should be more preference given to passengers who responsibility for. are more economically beneficial. Would you tell us a bit more about what you mean and how that Q441 Ms Smith: But the benefit of central could work? organisation of strategy and development of master Mr Gooding: What I was driving at, as I said in plans nationally would be felt by airspace users, answer to an earlier question, this was an option passengers, everybody, and airport operators would rather than a single strand answer, but in selecting a be one of the major beneficiaries, so surely you particular group, and for my purposes I selected should bear some of the cost of it. business travellers, not least because we look after Mr Gooding: If the overarching authority you are business travellers so I guess I have to declare an suggesting is the Civil Aviation Authority, we interest at that point, but business travel plays a vital already pay for that anyway. That is not a role in the economy of the country. We are an island. government expense, we pay thumping great licence If we want to be in the international trading arena, fees to the CAA to cover these sorts of issues. we need to have people flying backwards and Processed: 06-07-2009 18:39:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG5

Ev 72 Transport Committee: Evidence

1 April 2009 Mr Tom Needham, Mr Tim Hardy, Mr Paul Kehoe, Mr Richard Gooding and Mr Simon Butterworth forwards for business purposes, and, therefore, there Q449 Graham Stringer: I understand that, but I is a way to value the contribution of those folk which think you said that because they were commercial is diVerent, I am not saying better or worse, from they were dealing with those issues diVerently than leisure travellers. I was just homing in on the fact they would have done if they were not commercial. that if we do not have either suYcient capacity or an Mr Butterworth: I think the aspect of the response organised rationing system, we are at risk of that you are referring to there was that in a deterring at least those business travellers who are so commercial sense they are concerned about vital to the economy of the whole country. incurring high costs for developing a strategic plan across the UK in support of perhaps the White Paper when there is no mechanism for them to regain the Q446 Chairman: How could this actually operate? cost of doing that. Have you given any thought to that? What would you do? Would you categorise the planes, the passengers in them, or what? Q450 Graham Stringer: That is helpful. Let me start Mr Gooding: I think all of those are open to with Manchester. Does Manchester operate examination. At the moment it is almost a free-for- Continues Descent Approach? all to join the queue, and maybe a queue is not the Mr Butterworth: We do. right answer if we have a shortage of capacity. To go back, I am not really advocating this sort of Q451 Graham Stringer: How many of the major discrimination at all, because I do not favour airports the UK do? discrimination on that front, but we have got Mr Hardy: The London BAA airports operate discrimination by default, we have got long queues CDA. of aeroplanes waiting to come to our airports and Mr Kehoe: On an ad hoc basis. Not all approaches land at them. From an environmental viewpoint, are CDA. from a business viewpoint, that cannot be right. If we are to go forward with a constant forecast Q452 Graham Stringer: Does the AOA? undershooting with the supply of capacity, we are Mr Needham: I think the general position is that in going to have to have some form of rationing. Either the large airports, BAA, Manchester, CDA is a fairly we have rationing as it is practised today, which is to well established procedure nowadays. At the join a queue, or we find some way of discriminating remainder of the airports it is on an ad hoc basis. between classes of traYc. I am not really advocating discrimination at all, because I think it is utterly the Q453 Graham Stringer: I asked previously about the wrong way to go, because it implies constraints in balance between military airspace and commercial our economy that should not be there. airspace. Is the balance between general aviation and commercial aviation the right balance? Some of Q447 Chairman: So it is an aspiration rather than a the evidence we have had seems to indicate that too proposal? much space is given over to general aviation. They Mr Gooding: It is an illustration of what happens if are our next witnesses, so if you want to say we do not get to the point of having some version of something now is the time to say it. an overarching airspace strategy document that sets Mr Needham: I think the point that we would like to the policy for us all to operate under. make on general aviation is that we have worked very,very hard over the last few years to develop new arrangements for air traYc services outside of Q448 Graham Stringer: Three questions and then I controlled airspace, and they have now been in have finished. Mr Butterworth, you said something operation for about two weeks—they actually came very interesting in a previous answer. I was opposed into eVect, I think, on 12 March—and that is a to the privatisation of NATS when it happened. I significant step from the commercial sector which is have never been able to find any evidence from my for the benefit of general aviation, largely. So I think point of view that it has not provided the service that we are working with our partners in general one would have expected it to since it was privatised. aviation, the businesses in the general aviation You said in an answer to a previous question that community, to provide services. because it was commercial, it was operating diVerently. Do you think you could expand on that? Q454 Graham Stringer: Anybody else? Mr Butterworth: I think it would be hard to say that Mr Butterworth: In the Manchester area we are it is operating diVerently. What we have got is a currently completing, or NATS on our behalf are constraint in the process whereby NATS are completing a process of airspace change currently the organisation in the UK that take consultation to actually reduce the area of controlled responsibility for the design of the airspace change airspace around the Manchester Airport area, that supports the growth and capacity for the UK or thereby giving back parts of the airspace for general bit by bit, in a piece meal fashion, the areas of the aviation use and for their benefit and eYciency; so I UK. Because there is only one organisation enabled think there is evidence there that we are doing as to do that and they have constraints in their capacity much as we can to aid general aviation. Clearly to deliver that process, it means there is a knock-on somebody somewhere might need to take a view on eVect to everything else that is behind them in that where the conflict arises and who should benefit if chain. the conflict should arise. Processed: 06-07-2009 18:39:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG5

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1 April 2009 Mr Tom Needham, Mr Tim Hardy, Mr Paul Kehoe, Mr Richard Gooding and Mr Simon Butterworth

Q455 Graham Stringer: This is a technical area. I do think it is an important point to talk about how not know about other members of the committee, environmental impact could be mitigated going but I find it diYcult. Can you marry it up? You want forward and what the beneficial expansion of more military airspace on the one hand, but you are controlled airspace might be. We want more and handing over space to general aviation, just on more traYc to undergo continuous descent service, but this appears to be a contradictory approaches, with the drop-oV in fuel burn and the policy? reduced noise. I think this is an important area to Mr Butterworth: It might be of value if we could just focus on going forward. establish what is meant by “general aviation”. It is quite a wide-ranging statement. It ranges from, if Q459 Sir Peter Soulsby: To pursue the point, are you like, recreational flying right the way through to there any figures either in your evidence or that you business aircraft, and so I think it might be valuable are able to let us have? to establish which part of general aviation is the Mr Butterworth: I would be happy to provide some concern, because I think we would feel that we are figures for you. serving them all. We operate under a public use Sir Peter Soulsby: I think it might be quite helpful to licence; we are obliged to be available to all know the proportions at each of the major airports companies on an equal basis. in general.

Q456 Graham Stringer: You are not aware of any Q460 Mr Wilshire: One final question from me, particular problems within the category “general Chairman. I hope I know the answer, but I would aviation”? like to get on the question on the record. Do any of Mr Butterworth: I think it depends which area of you have any concerns at all that the changes now general aviation you might be talking about. Our being looked at can compromise safety? view is that they are well represented on the national Mr Gooding: I would like to turn that round, if I may. committees that look after airspace and air traYc I think they enhance safety, not compromise it. management with the DAP, and if you look at the amount of airspace below, let us say, six or seven thousand feet, where most recreational flying takes Q461 Chairman: What other views are there on place, there is not a great deal of airspace that safety? excludes them at all. Mr Kehoe: I think safety is paramount, and we do not compromise on safety. Mr Hardy: I think the other aspect is, obviously, Q457 Sir Peter Soulsby: I would like to go back with new technological advances, with SESAR briefly to the question that Graham Stringer asked going forward, safety will be enhanced even further. about continuous descent approach. Do you have Mr Butterworth: Safety is designed into the system. any figures for the proportion of approaches that are The system of procedures that the air traYc service now CDA? operators operate under provide for that safety. Mr Butterworth: Could I qualify my earlier Those margins cannot be eroded. The consequence statement? Whilst we do operate continuous descent of more flights into the system, as Mr Gooding approaches, at the moment it is largely at night, and established earlier, is that you get more delay and a that is because we can only operate it whilst the rest queue in the system, whether that is on the ground or of the airspace is relatively uncluttered. To gain the potentially in the air. most benefit, I think it is probably worth perhaps turning towards the environmental benefits that can Q462 Chairman: What can you tell me about be gained by airspace change, because collaborative decision making? How is that going to environment’s a critical part of sustainable aviation improve on what there is now? for the future. We could get more use of continuous Mr Hardy: We have collaborative decision making descent approaches and we could getter better partially installed in Heathrow at the moment and departure profiles for aircraft to operate more we have a programme to roll out CDM for the rest Y V V e cient take-o profiles if the airspace was di erent of the airport some time during the summer. to the constraints that they currently reside within. Collaborative decision making means that we can reinforce predictability and consistency in Q458 Sir Peter Soulsby: Are there actual figures—I operation, we can take advantage of capacity more Y do not know whether they are in your evidence, but e ciently than we have done before and it gives a I did not notice them anywhere—of the proportion degree of resilience to the operation during of particular airports and in general, that are able to disruptive events like fog, snow, and so on. So we use CDA and the constraints that have prevented place a high value on CDM and we are collaborating those proportions being higher? with the airlines and with NATS at Heathrow to make sure that is a success. Mr Hardy: First, I can tell you at Gatwick and Heathrow, for example, the number of CDA approaches at night is in the region of slightly higher Q463 Chairman: Does anybody else want to than 90%. During the day, for the reasons that Mr comment on that? Butterworth has mentioned, it is slightly lower Mr Butterworth: We are just embarking on because the airspace tends to be more congested. I introducing CDM at Manchester. It is a very useful Processed: 06-07-2009 18:39:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG5

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1 April 2009 Mr Tom Needham, Mr Tim Hardy, Mr Paul Kehoe, Mr Richard Gooding and Mr Simon Butterworth tool for informing all the parties involved in a flight, weighting put to the various interests surfaced by an whether it be on the ground or in the air, as to airspace change”. Could you amplify what you whether it is actually going to operate at the time mean? that it is predicted to. Collaborative decision making Mr Hardy: By all means. During the course of an came around from a Eurocontrol initiative which airspace change application, the sponsor for route was concerned that, once an aircraft landed on the changes or airspace changes around the airport is the ground, they had no predictability about whether it airport operator, generally speaking. The process would be back in the air at the time that the ATM can become very iterative, in other words smaller (air traYc management system) expected it to be and smaller considerations need to be taken into consideration before the airspace change is actually there. What CDM does is it allows predictability and Y approved, and so we believe that the DfT and the allows e cient use of the slots in the en-route Directorate of Airspace Policy have a role to play in airspace to be used that are predicted to be there. assisting with the weighting of the various What it does not do, unfortunately, is allow arguments and counter-arguments as to why a additional capacity in the airspace. proposal should proceed, or not, as the case may be. I think the important thing is to make the process more eYcient and quicker in its resolution than it Q464 Chairman: Are there any other comments? Mr appears to be at the moment. Hardy, in BAA’s evidence you say that the DfT and Chairman: Thank you. Thank you very much for the CAA have responsibility to “establish the coming and answering our questions.

Witnesses: Mr Paul Draper, Secretary, General Aviation Alliance; Mr Guy Lachlan, Chief Executive, British Business and General Aviation Association; and Mr John Brady, Vice-Chairman, Light Aircraft Association, gave evidence.

Q465 Chairman: Good afternoon, gentlemen. Could will impact our sector, which is the heavy non- you introduce yourselves for the record, please? scheduled airline sector, more quickly than it will the Mr Lachlan: Guy Lachlan, Chief Executive of the airline sector. British Business and General Aviation Association. Mr Draper: If you look at the smaller aircraft end of Mr Draper: Paul Draper, Secretary of the General the market, there is no doubt that sales have suVered, Aviation Alliance. particularly from American manufacturers. There is Mr Brady: John Brady, Vice-Chairman of the Light no English manufacturer left in the marketplace now Aircraft Association. really for smaller aircraft. There has been a shift away from those smaller American aircraft types Q466 Chairman: Thank you very much. How do you into microlights in the UK where there has been see the future growth of the general aviation and some expansion. This is proven by evidence of pilot business aviation sectors in the UK? How do you see licence issues from the CAA where over the last eight the current situation in relation to growth? years issues of licences to private pilots have gone Mr Lachlan: The current situation is generally bad. down by about 30% and have largely been replaced If you look at EUROCONTROL’s figures for by what is known as the National Private Pilot’s business aircraft movements, it shows that the UK is Licence which has a lesser requirement for a licence the third most heavily aVected country in the EU in and can be used by people with a lower medical terms of reduction of business aviation movements. requirement. There has been expansion of sorts in I think we are down about 27% year-on-year. If you that area. There is also evidence that sales in the look at traYc through Luton Airport, for example, second-hand market, where a lot of trading which is one of the most important heavy GA/ normally takes place, has slowed significantly just business aviation type airports in the country, that is lately. When that will come back will depend on number one on the hit parade throughout Europe when the general economy improves. with a decrease of something over 30% year-on-year in terms of movements. In terms of aircraft flying Q467 Chairman: You are not making any and new aircraft sales the picture is uniformly predictions on that? serious. There are areas that as yet have not been so Mr Draper: No. heavily impacted, like flying training which at the Mr Brady: In the sport and leisure aviation area it is moment is holding up reasonably well and quite diYcult to track levels of activity because there maintenance in some areas is holding up reasonably is no recording, but airfields report less activity in well, but the actual flying and selling of new and used general so I think we can say the operation of light aircraft is in dire straits right now. As to the future, aeroplanes has reduced but, of course, there are I think it is very diYcult to make predictions. I would rather a lot of them. In the UK register there are agree with some of the assertions that were made in about 1,000 airliners but about 26,000 other aircraft the previous session about getting back on to some in the UK on the register. In the small aircraft sector form of growth after this downturn, but exactly what we think there are about 17,000 powered aeroplanes shape that will take is unknown to anybody, of one sort or another and another 2,500 gliders, so particularly when you add in the eVects of the there are something in the order of 20,000 aircraft Emissions Trading System and cap and trade which about, plus lots of hang gliders and paragliders, Processed: 06-07-2009 18:39:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG5

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1 April 2009 Mr Paul Draper, Mr Guy Lachlan and Mr John Brady which can fly across country these days. I think a lot Q469 Chairman: Mr Brady, any special points? of people are going to the cheaper end of the market Mr Brady: We heard in the earlier session about the because those sorts of vehicles can be had for a amount of controlled airspace there is in the UK. I thousand pounds or so and people enjoy their air would just like to point out that above 25,000 feet sports in other ways. the whole of the UK is controlled airspace, so the airlines have everything above 25,000 feet. The airspace is then stepped down towards airports in Q468 Chairman: What are your major concerns controlled airspace across the country. Generally about access to airspace? Who would like to give me speaking, the sport and leisure part of general some information on that? aviation flies outside controlled airspace but Mr Lachlan: I would echo some of the points that occasionally crosses it. We do find that controlled were made in the previous session about the lack of airspace has expanded, we are not quite sure by how a joined-up complete strategy for how airspace and much and the CAA cannot tell us. I heard in a ground infrastructure should be used. We have a previous session somebody said about 60% of the situation where as an airport becomes increasingly UK in the lower levels was controlled airspace, but congested, contrary to what we have just heard, once I have not been able to demonstrate that; I think the that airport becomes co-ordinated non-scheduled CAA is working on it. We do find that controlled traYc is squeezed away from the airport completely. airspace sometimes takes up rather more of the There is no right to appeal, no other process, country than it needs to. For example, Doncaster scheduled traYc has the right to eliminate non- has recently established controlled airspace. It is scheduled traYc. That means that the non- about the same size as Gatwick but it only has 2% of scheduled business type GA migrates to other the number of movements that Gatwick has, so it airfields and those airfields typically have limitations takes up a big chunk of airspace that was previously about their use either in terms of operating hours, open to everybody. It is now only available by number of movements per year, or both. That does permission using a radio call. The quota of not fit necessarily with the airspace capacity, as was controlled airspace squeezes general aviation and we said earlier, so you have got very anomalous have to live in the open airspace that is left. situations where you have got fantastic, world class facilities, such as at Farnborough, which as you Q470 Chairman: Do you think there should be limits probably know is a purpose-built business aviation on the percentage of controlled airspace for each terminal of the highest standard, operating from an sector? airfield which has very, very low levels of movements Mr Brady: We think that the controlled airspace permitted and it is constrained because of that. On allocated to commercial operations should be the other hand, you have got places like Biggin Hill, proportionate to the amount of traYc that there is at which is able to operate a long way under their airports. We know that in some other countries there movement limit because their movement limit has are specific points at which controlled airspace of been set for historical reasons because it used to be diVerent sizes will be allocated to airports, but in the a training field. In all cases, the movement caps on UK we seem to have a standard and, as I say, airfields are set in isolation from what makes sense Doncaster, with very little traYc, has the same low from the airspace. That is one aspect. The other one level controlled airspace that Gatwick does, which is is the promise of greater and greater integration and perhaps one of the busiest airports in the country. eYciency in use of airspace generally throughout Europe. As you have probably discovered, aviation Q471 Chairman: Would you like to see it controlled does not fit with national boundaries very well, so by individual airports? That is not feasible, is it? our interfaces between UK and European airspace Mr Brady: I do not think we have any problem with and how the diVerent blocks of airspace work the control of the established controlled airspace at together are extremely important to fix so that the airports because we can always ask air traYc control capacity of the system as a whole can be increased. for a crossing clearance if tht is practical. For Mr Draper: If you look at smaller aircraft using example, the gliding movement may not be able to smaller airfields, many of them are located quite get a crossing because they cannot maintain height close to larger regional airports with large areas of and are diYcult to integrate with other air traYc controlled airspace which eVectively limits the control. Generally speaking, the general aviation heights at which aircraft can enter to gain access to sport and leisure section would like to stay outside these airfields and, therefore, there are the practical controlled airspace where it can share with the diYculties of operating in weather which is not as military but be less trouble to the commercial good as one might hope and also obtaining operations. agreements to co-operate with the adjoining airfields in terms of air traYc movements and the like. As Q472 Mr Leech: Mr Draper, you said that the those airfields find it more diYcult to operate and pressures on airspace had impacted on airfields in attract users, their income drops and, therefore, it is terms of their ability to make money. Are there any diYcult for them to keep in operation. In turn, that examples where airfields have actually closed as a removes essential—in many cases—airfields to result of that? Mr Brady mentioned Doncaster and which business people as well as leisure people can the restricted airspace around Doncaster. Has that fly and makes the whole transport system more had any specific impact on particular airfields that diYcult. are now struggling as a result? Processed: 06-07-2009 18:39:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG5

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1 April 2009 Mr Paul Draper, Mr Guy Lachlan and Mr John Brady

Mr Draper: Some of the airfields around Doncaster commercial terms has improved considerably over were extremely concerned when the proposals were the years and we believe that it ought to be possible published and had very detailed negotiations with for them to give some up, as has technology Doncaster Airport about their position. In all cases improved to enable them to see what is going on. they managed to reach agreement and the impact on Mr Lachlan: The point was made in the last session them is yet to be felt. They had struggles. about just how diverse GA is and it is worth keeping that in mind throughout this discussion because it Q473 Mr Leech: Are there any other examples? really covers everything from powered hang gliders Mr Draper: I cannot give you oV-the-cuV instant up to Barack Obama’s plane. The heavier end, the examples. business aviation end which flies in and out of Mr Brady: I can think of a small one. There is a controlled airspace all the time, pay the same scale of consultation going on at the moment for Glasgow charges as the airlines so there is no cross- Airport. Glasgow has three times the controlled subsidisation going on in terms of airspace usage. airspace of Gatwick and only a third of the movements, but it is currently bidding for a third Q475 Graham Stringer: Transponders were increase in its controlled airspace which would close mentioned. Could you tell the Committee what your the gap between Glasgow and Edinburgh and would attitude is to the CAA’s aspirations to have more isolate the Highlands and north Scotland from aircraft within the general aviation area fitted with England for aircraft that cannot cross airspace, Mode S transponders? those that do not have a radio, do not have a Mr Brady: I am involved in responding to the CAA’s transponder or in weather conditions they will not consultation on fitting transponders in all aircraft in have a corridor to go through. Although they could all airspace in the UK. A transponder responds to an go round the ends, the terrain in a small aeroplane is interrogation from the ground. In general aviation inhospitable to the west and it is a very long way to aircraft we have no mechanism for seeing the the east. There are also a couple of airfields transponder returns from another aircraft. Airliners underneath that controlled airspace which face an and business jets and so on actually have uncertain future if the proposal goes ahead. As I say, sophisticated systems that do that. Our concern in it is currently under consultation. the open flight information region is that our greater risk is close encounters between general aviation aircraft and if they all carry transponders that is not Q474 Mr Leech: Manchester has said that perhaps V you are more accommodated than you should be a ected at all because no aircraft with a transponder and British Airways have suggested that they are can see another aircraft with a transponder unless eVectively subsidising general aviation. Two fairly they have the sophisticated equipment which we contrary positions. Who is right? cannot fit. We thought it was a good thing to have Mr Brady: Can I start with Manchester airspace? It transponders for carriage in controlled airspace and is not possible to travel through that bit of the in other particular circumstances, but to try and fit northwest for a light aircraft except through a low this enormous number of aircraft with this very level corridor which is 1,250 feet above mean sea expensive piece of equipment for something that is level, so about 1,000 feet above the ground there is a not completely proven we thought was not a very narrow corridor between Liverpool and proportionate response. We are still waiting for the Manchester, otherwise you have to go to the other CAA to come back and tell us what the outcome of side of the Pennines and you bump into Doncaster that consultation is. We understand they are not which has just been established. NATS very kindly going to propose any more that all aircraft should oVered to give us some airspace and, in fact, they carry transponders in all airspace. have given us 50 feet on the Manchester low level corridor. Q476 Graham Stringer: You are saying that basically Mr Draper: I have an instrument rating attached to you accept if general aviation goes into controlled my licence and to keep that current I need to train at airspace a transponder would be a good idea because an airfield that has instrument approaches. Basically, the commercial aircraft would be able to see? we are priced out of the market or not able to gain Mr Brady: Indeed. A general aviation aircraft going access to airports with those facilities very easily into controlled airspace can only do so with because of the presumed amount of usage by them, clearance from air traYc control, so it has either a they just will not let us in. It makes it extremely radar or a procedural clearance already which diYcult for us to keep current, which we need to do should keep it clear of other aircraft. The Light if we are going to fly within the system. There are Aircraft Association took the view that if the certainly diYculties in gaining access to those sorts weather was instrument flight rules, if it was cloudy, of airports as far as we are concerned. The other then a transponder would be very important because aspect in terms of the use of the airspace is that we if the procedure broke down then the transponder find in practice it is extremely rare for any airport to might save the day in a collision between two give up any controlled airspace, notwithstanding the aircraft. However, if the weather is clear and the fact that they now have these continuous descent aircraft are cleared into controlled airspace under approaches, admittedly not 100% as yet, but as they visual flight rules then we do not believe it is are coming in there never seems to be any suggestion necessary because we can also use see and be seen as of them giving up any airspace, and that is a back-up in the event that the procedural clearances regrettable because aircraft performance in or radar clearances should fail. Processed: 06-07-2009 18:39:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG5

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1 April 2009 Mr Paul Draper, Mr Guy Lachlan and Mr John Brady

Q477 Graham Stringer: Is the intrusion of military two beacons, generally speaking. The pilots have to aircraft into uncontrolled airspace a problem? be extremely alert because they cannot always be Mr Brady: Most military aircraft do fly in assured of getting a radar service either from uncontrolled airspace. We share the open FIR with Stansted or Luton because they are busy with the military and always have done. Military aircraft commercial traYc. However, having said that, sometimes fly in controlled airspace in much the NATS recently introduced a lower airspace radar same way that light aircraft do. service which might be available to them and which we have generally applauded and have been seeking, Q478 Graham Stringer: Is flying in uncontrolled to my knowledge, for eight years or so, so that is a airspace a safety problem? Does it cause you any definite improvement which helps. other kinds of problems? Mr Brady: We do not think so. The Chairman of the Q482 Graham Stringer: For people under these flight UK Airprox Board said that as far as risks with paths for general aviation, the one you have just commercial aircraft there were no risk-bearing described between Luton and Stansted, when the encounters since 2006 and for general aviation we commercial airspace increases and, therefore, now have the lowest risk for a decade. There has aircraft are pushed lower, is there any form of been an awful lot of work going on to educate people consultation with the people who are aVected by that and improve the radar services that are provided. It noise or does it just happen? seems to be bearing fruit now because risks and Mr Draper: If there is a request for expansion of the encounters seem to be going down across the board. controlled airspace then the airspace change process requires that the proposer, ie the airport, actually Q479 Graham Stringer: I am not clear from that does consult with the local authorities. answer how much risk there is with military aircraft in uncontrolled airspace. Q483 Graham Stringer: I understand that and they Mr Brady: I do not believe there is any more risk of are consulting about controlled airspace and the close encounters between military aircraft and light aircraft going through there, but does that aircraft than there are between light aircraft consultation include the knock-on impacts that themselves. As was said in the earlier session there general aviation will have? are rather less military aircraft now than there used Mr Brady: I have this to raise with the Civil Aviation to be. Authority tomorrow because within the airspace Mr Lachlan: In the developments that have just change process, which we think is actually quite come into eVect in this country the military have good, there is a requirement for the sponsor to look been very heavily involved in everything that has at the impact on other airspace users and been done. I would say that it is a low risk and environmental issues, but they tend not to do this. getting lower, if anything, because these new services There is a consultation going on at the moment to are thought out in complete co-ordination with change the airspace around Stansted which would military users of the uncontrolled airspace with a cause more crowding in that gap, but the impact on view to making it safer for everybody. other airspace users is not actually being considered, so I have to take that to the CAA to draw their Q480 Graham Stringer: So transponders would not attention to it. change the risk of accidents at all? That is the point I am really driving at. Q484 Graham Stringer: I have been in more debates Mr Brady: I think it is fair to say transponders than I would have wished to be about controlled would, but the improvement in safety across all of airspace round East Midlands Airport and nobody the FIR would be modest and the costs would be has ever brought up the knock-on impacts of general enormous because the cost of a transponder equates aviation, but there is a real issue there, is there? to a fair proportion of the whole value of many Mr Brady: Yes. If we crowd people together and aeroplanes. reduce them in altitude then we increase risk to that sector and it may be across the piece that is the right Q481 Graham Stringer: You were talking previously balance but it does need to be set out and considered. about the increase in controlled airspace. Some of the evidence we have had, and it might be from Q485 Ms Smith: British Business and General yourselves, is that as the controlled airspace Aviation Association have suggested that the use of increases you are forced to fly lower which has a airspace should be prioritised by the economic value noise impact on communities. Is that accurate? Is of the passenger. Could you elaborate on that? that true? Can you give us examples? Mr Lachlan: It seems to me, as was alluded to in the Mr Draper: That would be true in principle. previous session, that at some stage we are going to Furthermore, it means that there is more funnelling have the fact that if there are going to be constraints generally, or there can be, of aircraft down a similar on either capacity or utilisation of natural resources route which poses more noise and also more at some stage we are going to have to get into some potential risk. If you take the example of the kind of limiting system. Obviously there are several corridor between Luton and Stansted then all traYc options for how we decide to do that. The easiest has to fly at below 2,500 feet so, therefore, most would be just to say that we will make it more and aircraft actually fly at 2,400 to make sure they have more expensive and allow those with the deepest got a margin and they follow the same route between pockets to continue flying while those without the Processed: 06-07-2009 18:39:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG5

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1 April 2009 Mr Paul Draper, Mr Guy Lachlan and Mr John Brady deep pockets cannot, which does not seem very fair. also the induced value of the increased business It seems to me that there ought to be some way of activity and tries to analyse it in a way that is as identifying the economic value not just of business impartial as possible. I can certainly provide full travellers but of all users because, of course, taking copies of the report if that helps. I do not know if a a vacation has an economic value, although I do not similar report has been done on the airline side. It is know how much that has been studied. Thinking not a straightforward thing to do, of course. The fact specifically about distribution of fossil fuels, we can that I keep coming back to is if I were to go and buy then make decisions based not just on who is the last a gallon of fuel and set light to it—not here, but person who can aVord it. somewhere—then I am contributing to the GDP of the UK because I have bought the fuel, but I have Q486 Ms Smith: Within the general aviation sector not put that fuel to any use. I think we need to look there must be a broad range of the numbers of at what use we are getting out of the fuel that we business passengers carried, for instance, by are burning. business aviation. Can you give me an idea of what that range might be? Q490 Ms Smith: Is there any evidence to suggest that Mr Lachlan: In terms of total numbers? the business aviation sector provides better value for money in terms of the UK economy than, say, the Q487 Ms Smith: No, in terms of numbers of commercial sector? Is there any hard evidence to passengers carried per aircraft. prove that? Mr Lachlan: It is small. It is something in the order Mr Lachlan: I would say yes. If you have a look at of three and a half on average. The argument that I this PWc report that I will furnish you with, the would put forward is that it is tempting to always induced value of business aviation to the UK look at a full aircraft as being an eYcient aircraft, economy is roughly equivalent to the total of the and of course some entities would encourage that direct and indirect values, so it has a very high ratio view, but on some routes it might make sense to just of induced value to the value that is generated as a have smaller aircraft full of people going from A to direct and indirect spin-oV from performing the B. It is a fact of life in the business world you do not flight. always fly on popular routes. In fact, that is one of the rationales of having business aircraft, you are Q491 Chairman: British Airways have suggested flying to places that are not served by other forms of that light and recreational aviation is eVectively travel so, of course, there are not hordes of people being subsidised by commercial aviation. Do you wanting to go there. That does not mean that the agree with that? Mr Brady? value of the flight is low just because there are less Mr Brady: British Airways have proposed this for people on board, they may be going out to conclude some years and, indeed, a few years ago there was a business deals that are of very significant economic major study by the Civil Aviation Authority into value to the country or to Europe. I would cross-subsidy within aviation sponsored partly by encourage a view that moves away from looking at Y British Airways. The sport and recreational sector a full aircraft being an e cient aircraft per se when was excluded from this study which found that we I would say if 90% of the people on that full large were subsidising British Airways and the like. The aircraft have paid 99p for their seat then I would structure of CAA costs and charges was changed to question the rationale for burning the fuel. put more costs on to general aviation and especially on to sport and recreation, and less on to British Q488 Ms Smith: I appreciate that, but surely at the Airways. I believe it is their proper business to go end of the day you would acknowledge that the about trying to reduce their costs and charges in environmental cost of general aviation as compared whatever appropriate way that they can. to commercial aviation has to be a factor if we were Mr Draper: We would also say, Chairman, that they to get to the point when we had to ration, and I hope add costs to general aviation in as much as they we would not. If we did then the environmental cost plead for new technology, such as Mode S would have to be very carefully studied before we transponders and the like, which we require solely to made any kind of commitment to rationing of any assist commercial air transport. If there were no kind. commercial air transport we would not need them. Mr Lachlan: Absolutely. All I would say is that cost Maybe if they want to make more use of the has to be balanced against economic value rather controlled airspace and expand it they should than the number of people on the plane. subsidise the technology that is required to be put into our aircraft to allow that to happen. Q489 Ms Smith: Are there any studies that you know Mr Lachlan: If I can just add that if the non- of that have taken place to measure this kind of scheduled carriers had the ability to guarantee the impact and then the balance? availability of slots at busy airports which they can Mr Lachlan: Yes, at least on the aviation side. A very capitalise and use on their balance sheets we would authoritative study has just been concluded by very much appreciate that as well. I sit on the CAA PricewaterhouseCoopers that I think I referred to in Finance Advisory Committee of the Safety my evidence which is the most recent that I know of Regulation Group and can confirm what was said that has been concluded anywhere in the world. It earlier about the elimination from an airworthiness was finished last December. It looks at not just the point of view of this so-called cross-subsidy that has direct and indirect value of the flying that is done but existed up to now. There is a formula in place that is Processed: 06-07-2009 18:39:01 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG5

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1 April 2009 Mr Paul Draper, Mr Guy Lachlan and Mr John Brady agreed for those airworthiness charges that will see Mr Brady: I can oVer two reasons. Glasgow is the elimination of so-called cross-subsidies in the historic. It has had quite a large airspace. It did have next two or three years. two runways and now has one. It has retained all of the previous controlled airspace and, in fact, is Q492 Chairman: What changes would you like to see asking for some more. The Doncaster case is that the in the Airspace Change Process? CAA applies standard design criteria to controlled airspace which is always 10 miles wide and even Mr Brady: I believe that the Airspace Change Y Process is quite good. It was reviewed and when there are very low tra c levels the controlled completely overhauled about three years ago. We airspace is still 10 miles wide. In Germany, for heard earlier that some people would like the process example, smaller airfields get airspace that is only six for Airspace Changes to be set out in advance miles wide and it seems to work for them. without too much consultation, but we have quite a good and eVective consultation process. The CAA Q496 Chairman: You also say that airspace changes have stepped back from the airspace design and sometimes force general aviation aircraft closer to consultation area to be the decision-maker and have the ground causing environmental damage. Could given the responsibility for doing all the work to you name any areas where that has happened? those that would have controlled airspace, NATS or Mr Draper: We gave the example earlier, Chairman, the aerodrome sponsor. We do not have any problem of Luton and Stansted. That is a prime example of with that. About the only diYculty we have we have where we are kept quite low. There are other areas already mentioned, which is the problem of properly where, for example, you are kept to 1,500 feet above analysing the eVect of changes on other airspace ground, and that is part of what is happening in the users, which I hope the CAA will address in the other changes proposed at Stansted and also near future. airfields around there.

Q493 Chairman: Are there any particular concerns? Q497 Chairman: Mr Lachlan, you say in your Mr Draper: Yes, Chairman, I think there is an evidence that “climate change concerns will argument which says that the current process puts increasingly gain precedence over ‘lifestyle’ views of more burden on to organisations such as ourselves, consultees”. What do you mean? What are the which are non-profit making, we are not paid in any lifestyle views? way. We have to keep alert to all these proposals. We Mr Lachlan: This is not just an aviation related issue; have to put a lot of time and eVort into dealing with it is the same in many aspects. I appreciate it is them. The changes which took place during 2006–07 diYcult politically to sell to the electorate. have increased that burden. I think it would be more Everybody is in favour of doing the right thing to helpful if the CAA was more involved in the process reduce the level of emission of greenhouse gases but from the start when the proposer puts forward their when somebody wants to build a wind turbine intentions to see that we do not get situations such anywhere near them, they do not like it. When you as Mr Brady mentioned beforehand, such as want to double-glaze your listed house that you live Gatwick has a very tight controlled airspace in you cannot do it because it is a listed house. It just environment whereas Glasgow has a very loose one seems that we have not quite got the balance right and wants a much greater area. That somehow generally across the piece of saying, “Well, I am seems to be wrong in principle and they should be sorry, environmental concerns outweigh X, Y and told that at the outset so that we do not have to Z”. They might not outweigh everything, but as a tell them. society I think we need to come to grips with the fact that either we are in favour or against doing the right Q494 Chairman: Mr Lachlan, have you anything to thing. We cannot be in favour of it if is in someone add to that? else’s back garden but against it when it is in our Mr Lachlan: Again, some kind of framework own. balance should be incorporated. The process itself works very well and the degree of consultation is Q498 Chairman: What about flying over national extremely thorough. I do not know that there is the parks, say, if it reduced emissions? Would you think right balance yet in terms of environmental benefits that was the right thing to do? being reaped by eYcient usage of airspace versus the Mr Lachlan: I think it should be studied and we interests of people who have justifiable issues about should have clear rules that say if it makes suYcient noise or whatever else. I think maybe some more environmental impacts then, yes, it should be work needs to be done working out some more allowed. clearly stated balance between emissions impact and the improvements that can be made by sensible Q499 Ms Smith: In some cases business travellers planning of flight paths. using general aviation could use alternative means to get from A to B, it is not always that there is no other Q495 Chairman: You also say that there are air or rail means of getting to where they need to be. excessive volumes of controlled airspace around Surely, therefore, the same principle ought to apply? some airports, such as Glasgow and Doncaster. Why Mr Lachlan: Yes. I think the air traYc network do you think that has happened? Is NATS using the should be looked at in one as a piece of an integrated wrong design principles? transportation network. I absolutely agree with you. Processed: 06-07-2009 18:39:01 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG5

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1 April 2009 Mr Paul Draper, Mr Guy Lachlan and Mr John Brady

Q500 Ms Smith: So rationing in the sense that we concerns and they have gone away to do some talked about earlier would also include a test for redesign to cope with those. Having something that business travellers as to whether or not there are was pre-planned and signed oV well in advance alternative means of them getting to where they need would stop the consultation process. to get to? Mr Lachlan: Absolutely. We could all think of areas Q504 Chairman: Mr Draper, have you anything to where you clearly would not have President Obama add to that? on a train to go back up to Stansted, so there are lines Mr Draper: Only, Chairman, that we are involved to be drawn somewhere between me using an aircraft with NATS in a forum called the GA Forum which and President Obama, there is a whole range of enables us to have discussions with them about the people in-between and maybe one could draw a line. principles of what is happening to the airspace I think it is an area worthy of study. structure and how that would aVect GA. We would like that sort of forum to continue so that we can Q501 Ms Smith: Is this not an Orwellian approach input before any Master Plans are actually eVected. to running the country? In fact, they did talk to us and I was involved in the Mr Lachlan: Pass! preparation of the scoping study, which I believe is still with Government, to decide on what the future Q502 Chairman: Could you give us an example of airspace arrangements for the country ought to be. where an extension of controlled airspace has Once the decision is made on the principles of that restricted the use of a small airfield? then we would hope that GA is going to be involved Mr Brady: The current consultation at Glasgow in taking that a stage further so that the potential aVects a small airfield which is an up and coming impact on GA can be considered as part of the microlight centre at Strathaven which is to the south overall plan. of Glasgow, between Glasgow and Edinburgh, and the change in airspace proposed will impact on them Q505 Chairman: Do any of you have any current quite significantly, increase the intrusion of aircraft safety concerns? using the airfield and make it probably less safe Mr Lachlan: One example is the carriage of traYc because generally aircraft will fly much lower than collision avoidance systems—TCAS—in upper they currently do. The airfield owner is currently airspace is only required on aircraft that weigh more doing battle with National Air TraYc Services than 5.7 tonnes which seems to be not perhaps a Limited to try to roll back some of their aspirations sensible thing to do. Our view as an Association is for increasing their controlled airspace for that that anybody operating a complex jet-powered reason. aircraft in that airspace, particularly in congested airspace that we have around here, should be Q503 Chairman: Mr Draper and Mr Brady, in your carrying that equipment regardless of the size of the evidence you do not support an Airspace Master aircraft because a small aircraft can collide with a big Plan, you think it would “pre-approve” changes. aircraft and they would both come down. That is What are the problems that you envisage? one. Mr Brady: We have talked about the Airspace Change Process and the consultation process which Q506 Chairman: Any other concerns? invites views from other airspace users and from the Mr Brady: There are quite a number of activities environmental aspect. If the changes to airspace going on at the moment, one of them sponsored by were set out well in advance so that quite long-term the CAA, that seek to improve safety outside infrastructure plans could be made by airfield controlled airspace. We have seen various reports owners and the like then I think that would remove from the Airprox Board and from others that say the rather nice democratic process we currently have safety is improving steadily year-on-year outside of consulting on airspace changes at the time they controlled airspace. I am really quite pleased that is are going to be made. The previous group talked the case. about the Airspace Change aVecting London North, Mr Lachlan: We would agree with that. which is quite important, but that has gone back by Chairman: Thank you very much for coming and several months principally because of environmental answering our questions. Thank you. Processed: 06-07-2009 18:41:20 Page Layout: COENEW [SO] PPSysB Job: 412381 Unit: PAG6

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Wednesday 22 April 2009

Members present

Mrs Louise Ellman, in the Chair

Mr David Clelland Ms Angela C Smith Mr Philip Hollobone Sir Peter Soulsby Mr John Leech Sammy Wilson Mr Eric Martlew

Witnesses: Jim Fitzpatrick MP, Parliamentary Under Secretary of State, Mr Jonathan Moor, Director General of Civil Aviation, and Mr John Parkinson, Head of Airports Policy Division, Department for Transport; Sir Roy McNulty, Chairman, and Mr Mark Swan, Director Airspace Policy, Civil Aviation Authority, gave evidence.

Chairman: Good afternoon and welcome to the framework for the use of that airspace, but it is the Committee today. Do Members have any interests Civil Aviation Authority, the independent regulator, to declare? which designs and implements detailed measures to Sir Peter Soulsby: Yes. I am a member of Unite. ensure all users are granted fair and equitable access Mr Martlew: I am a member of Unite and GMT to it. The CAA is seen as one of the leaders in its field. Union. NATS and to a certain extend the MOD are Mr Clelland: I am a member of Unite. responsible for the day to day safety operation Chairman: I am a member of Unite. within the two FIRs. Although each Member State Mr Leech: Chairman, given that we are talking remains sovereign over its allocated airspace, it is about airspace, I have acquired a non-pecuniary sensible to utilise this finite resource as eYciently as beneficial interest in a piece of land surrounding possible. That is why the UK has strongly supported Heathrow Airport. the European Commission’s initiative through the Single European Sky in encouraging airspace to be Q507 Chairman: Thank you, Mr Leech. Could I ask considered in a wider sense beyond the confines of our witnesses to identify themselves, please, for our national borders, to improve traYc flows and reduce records? the negative impact of aviation on the environment. Jim Fitzpatrick: Chairman, if I could introduce my To that end, the UK has been the first to establish a two colleagues from the Department for Transport, functional airspace block with a neighbouring state, Jonathan Moor on my direct left, who is Director in this case Ireland, which will deliver gains in General of Civil Aviation, and John Parkinson, who capacity, safety, environment and cost eYciency. is Head of Airports Policy Division. Eurocontrol, the intergovernmental organisation Sir Roy McNulty: I am Roy McNulty, Chairman of comprising 38 states, has enormous airspace and air the Civil Aviation Authority, and with me is Mark traYc management expertise and is ideally suited to Swan, who has recently become the Director of realise the initiatives of the Commission. The UK, Airspace Policy, replacing John Ascott, who being a member of both Eurocontrol and the EU, is attended with me at the previous hearing. instrumental in influencing Eurocontrol’s delivery of eVective air traYc management measures. Furthermore, the European Aviation Safety Agency Q508 Chairman: Thank you very much. Minister, we (EASA), is establishing common rules for air traYc are at the moment in a global recession and air traYc management and air navigation service safety to has reduced severely. Why are you so confident that ensure a high uniform standard of ATMs right the demand for air travel will continue to grow at the across the EU. Member States and key industry levels you have been predicting? partners such as NATS are fully involved and the Jim Fitzpatrick: Chairman, I was wondering UK will work hard to ensure that these standards are whether it would be helpful to the Committee if I set world-leading. Thank you very much, Chairman. out briefly the role of Government and the other key players in managing airspace, but if you are happy that you have covered that then obviously I would Q509 Chairman: Thank you. Could you tell us why not want to detain the Committee, but I have got a you remain confident that air traYc will continue to brief statement of about two minutes. The respective grow as you have been predicting, given that we are roles of the various players have developed over now in the depths of a global recession and air traYc many years to be complementary and mutually clearly is being severely aVected by that? supportive. ICAO’s Chicago Convention recognises Jim Fitzpatrick: I think it is self-evident on the basis each state’s sovereignty over its airspace and of the experience of recent decades that air traYc has requires it to arrange the provision of air navigation been growing. There have been some reductions on a services. UK airspace is organised into two flight temporary basis as a result of circumstances outside information regions, the London and Scottish FIRs, aviation’s control, but generally speaking we are which extend towards Iceland and to the confident that the range of figures we outlined in the north and to the Channel Islands in the south. The 2003 White Paper in respect of the numbers of Department for Transport specifies the policy people who have been using and will continue to use Processed: 06-07-2009 18:41:20 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG6

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22 April 2009 Jim Fitzpatrick MP, Mr Jonathan Moor, Mr John Parkinson, Sir Roy McNulty and Mr Mark Swan aviation will continue to grow. The assessments we Jim Fitzpatrick: I think it goes both ways, have made within the Department and the evidence Chairman. The assessment of aviation capacity and of aviation around the world do give us confidence certainly in the national perspective when we are that the figures are robust enough to be able to be talking about the assessments we have discussed in relied upon. the Planning Bill, the Planning Act last year, national infrastructure projects, when something Q510 Chairman: How often do you go back to those like Heathrow comes along clearly that takes some figures and look at new predictions? considerable time. The Heathrow assessment is a Jim Fitzpatrick: As you know, in the 2003 White very good example of that, how long it took us from Paper we said we would produce progress reports establishing the consideration, going for the between three and five years, so we have published consultation, assessing the submissions. Airspace the progress between three and five years. Perhaps change can be assessed in a much shorter period, so Jonathan could say how closely we monitor them in there was an assessment carried out beforehand to between the publication of the reports. see if it was compatible, if it could be done safely,and then in the course of all the planning applications and submissions which would have to be gone Q511 Chairman: When you are answering that, through once the decision in principle has been could you indicate how that monitoring is being taken—which we have—clearly the defined V a ected or changed by the recession? conclusions and adjustments which would have to Mr Moor: Certainly. Since the Air Transport White be made would have to be undertaken, but they can Paper was published in 2003 we have updated our be done in a much shorter timeframe. traYc forecast three times: in December 2006 at the time of the progress report in November 2007 and in January 2009 at the time when we published the Q515 Chairman: Sir Roy, are you satisfied with this Heathrow decision. The forecasts are still in line with procedure? the overall range set out in the Air Transport White Sir Roy McNulty: Absolutely.I think it has stood the Paper and in January 2009 the central forecast test of time. We have had major developments like showed an increase of passenger numbers from 235 the second runway at Manchester. Generally million passengers in 2008 up to 465 million speaking, airspace change can be done well within passengers in 2030. That is lower than the range at the timescale needed to get planning approval and to the time of the Air Transport White Paper but it is do the construction. still within the range of the high and low forecasts. It is still a very significant increase compared with at Q516 Mr Leech: Were any concerns raised at all the moment. In the first three months of this year about whether or not a third runway would have any passenger numbers are tracking at around the 2006 negative impact on the use of airspace or any issues level, so they are less than they were in 2007 and 2008 surrounding safety, or was it a case of, “Well, yes, a but they are tracking about the same as 2006. third runway can easily be accommodated”? Jim Fitzpatrick: It was an assessment that was made and the conclusion was positive in that it could be Q512 Chairman: Do you believe that the accommodated. I would not want to suggest in any developments set down in the 2003 White Paper are way, shape or form, Mr Leech, that there was any all still as necessary now as they were then? simplicity involved in this. I know you were not Jim Fitzpatrick: I certainly do, Chairman, and suggesting that. It was a very sophisticated process having gone through the Heathrow exercise so which had to be gone through and airspace change intensely over recent years and the figures that was one of the elements we had to be confident of Heathrow are dealing with in terms of capacity, that meeting, so it was undertaken, it was evaluated and clearly indicates to us that we do have a capacity we were confident that it could be done very problem there. Therefore, we do stand by the eVectively and safely. predictions and the requirements that aviation will have to meet as assessed then, as Jonathan has just outlined. Q517 Mr Leech: Have any concerns ever been raised when we are talking about airport expansion, not necessarily at Heathrow, any other airport? Have Q513 Chairman: When you took your decision on any concerns ever been raised about safety and Heathrow, did you look at airspace issues? security of airspace with the planned expansion of a Jim Fitzpatrick: We did. There was some preliminary particular airport? airspace assessment undertaken as part of the whole Jim Fitzpatrick: Forgive me, my colleagues will have consideration of Heathrow to determine whether or more experience in terms of the industry of aviation not, where we were required, in our belief, to support as I have been there for less than three years. the additional runway capacity, it could be However, there are always concerns raised, in my introduced safely within the airspace confines which understanding. Whenever there is an expansion the were available to us and those assessments were first thing people will say is, “Can it be done?” We positive. were saying that Heathrow is running at 99% capacity,and I am sure that some people would draw Q514 Chairman: Is airspace something which is the conclusion that if you are running at 99% considered after the decision on expansion, or is it aircraft, how are you going to squeeze in more part of the decision itself? aircraft, and maybe make that assessment as being in Processed: 06-07-2009 18:41:20 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG6

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22 April 2009 Jim Fitzpatrick MP, Mr Jonathan Moor, Mr John Parkinson, Sir Roy McNulty and Mr Mark Swan the air, whereas we are talking about on the ground Mr Moor: Essentially a third runway will give you and the ability to land and take oV. Concerns, in my significant more capacity throughout the day. The experience, will be one of the first things that people reason for stacking is twofold. One is just simply the who are interested will want to ask about and those volume of the aircraft arriving at particular times of opponents of aviation, I would imagine, would the day. There is another reason for stacking, which always use airspace as a possible area where there is a good operational reason. When the airport is might be diYculties, but I am not sure what the operating at 99% capacity you need some stacks in experience was elsewhere. there so that the air traYc controllers can bring the Mr Moor: If I could just explain the process at right mix of aircraft into the airport. So stacking is Heathrow. NATS did an independent study based not necessarily completely negative when you are on the proposals from the airport operator, how they dealing with a very congested airport like Heathrow. would operate the airport. That study was published With a third runway you are bringing additional at the time of the adding capacity at Heathrow capacity and because, on behalf of the Government, consultation, so it was freely available during the the Secretary of State has decided not to release all consultation process. The CAA were also involved the capacity immediately that will give an in the project, the sustainable development of opportunity for the airport to be run more eVectively Heathrow, and therefore took a preliminary and therefore to reduce unnecessary stacking assessment of that study, but this is all subject to because there will be a third runway available there much more detailed work done at the time of the for landing and take-oV. planning application because you cannot design a detailed airspace change until the planning Q520 Ms Smith: You talk about “unnecessary application is agreed, because that is exactly how the stacking”. Will you insist on targets to reduce airport will operate. I think in terms of another stacking? airport, for example a recent application on Mr Moor: I certainly think there is an opportunity to Coventry airport did have some airspace issues and look at setting targets. The CAA has recently done a I think Sir Roy might be able to explain to you study for us on resilience, which will be published, I exactly the CAA’s role in that application. think, fairly shortly. That will look at the economic Sir Roy McNulty: If I might add briefly, you benefits of reducing time delays, and obviously mentioned concerns and I think we see them more as stacking adds to time delays. issues to be solved. In the Coventry/Birmingham case, because of the location of the two runways Q521 Ms Smith: If they were to be introduced, which there was a potential for conflict between them, that Y body do you think should be responsible for setting tra c would interfere, coming from one to the other, and monitoring these targets? and in looking at the planning application we Mr Moor: I think it is important to look and see advised that there would need to be constraints on exactly what you are trying to achieve with the the way in which the expansion at Coventry could be targets and then assessing which body is the most handled because our first priority is always to ensure appropriate body to actually regulate those targets. that there is safety. So, where there are issues like this Y A lot of performance measures already exist, which we would put in place su cient constraints to be sure the airports publish. Eurocontrol publish measures that the system operates in a safe way. and they publish targets around time delays. I think in terms of any regulation of targets in the future I Q518 Mr Leech: Would you ever say, “If you are would probably look to our regulator, the CAA, to going to build a third runway at Heathrow, that is do that. going to seriously have an impact on the potential for having a second runway at another particular Q522 Ms Smith: Any comments from the CAA on airport,” because I know there were certainly some that? comments made about the feasibility of a new Sir Roy McNulty: It is not part of our remit at the airport in the Thames Estuary and the impact that moment, but if we were given the remit it is the type would potentially have on airspace around the of thing we could readily do. South East? Sir Roy McNulty: I think that is a correct statement. Q523 Sammy Wilson: Some people say there is much If a major new airport was developed in the Thames too cosy a relationship between the CAA, the Estuary it would have implications for London City, Department and NATS and therefore if there is to be for Stansted and for Heathrow, and potentially for regulation it should really be done by some more Gatwick, so there would need to be some adjustment Y independent body such as the Environment Agency. of the tra c flows but we would always ensure that Have you any comment on whether or not giving whatever adjustments were necessary and agreed over the monitoring of the situation to an were made because we would always ensure that independent agency such as the Environment there is a safe system. Agency may well engender some more confidence in the work that is being done? Q519 Ms Smith: DFT evidence acknowledges that Jim Fitzpatrick: I would not agree with that, Mr the third runway at Heathrow could possibly reduce Wilson. I think the CAA fiercely defends its integrity stacking, routine stacking, or even eliminate it. What and certainly its role as regulator is quite well discussions has the Department had with NATS on recorded. I do not see that there is conflict between this point? the two bodies. I think there is a very solid working Processed: 06-07-2009 18:41:20 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG6

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22 April 2009 Jim Fitzpatrick MP, Mr Jonathan Moor, Mr John Parkinson, Sir Roy McNulty and Mr Mark Swan relationship and I think we are very happy for that true that there is less military flying than there was, to be examined and scrutinised by anyone. There will but I think a very important fact we have to always be some sceptics or cynics who will argue that remember is that the type of flying the military are organisations are in too close a relationship, but I doing is diVerent. Once they brought in the think the public scrutiny by yourselves and by Eurofighter, which has a completely diVerent flight others, by the reports published to Parliament, gives profile from anything we have ever seen before to the opportunity for reassurance that there is no way exercise that type of aircraft requires a lot more the arrangement is failing the public, either in terms airspace than the previous less advanced aircraft did, of professionalism or integrity. so there has not been a pro rata reduction in the Sir Roy McNulty: I would like to endorse that amount of airspace the military use just because they completely and I have had the experience of being in have fewer aircraft, but Mark knows a lot more NATS. I was the Chairman of NATS and we have about it than I do. been regulated by the CAA. The CAA did us no particular favours. They are regarded, I think, worldwide as one of the most rigorous regulators Q527 Chairman: One of the points which have been both in safety and in other aspects. We have a suggested to us is that because of your military civilised professional relationship, that is for sure, we background perhaps that is indicative of too much are not fighting all the time, but I do not believe that emphasis on the military than civilian aspects. having a civilised professional relationship is any Would you comment on that. sort of crime. Mr Swan: I think I will have to leave others to judge on my performance over the next couple of years, Q524 Sammy Wilson: Leaving that aside and just Chairman, if I may suggest. Yes, I am an ex- looking at the argument in terms of independence, if, Typhoon pilot, so I do have some experience in using for example, it were to go to, or even consideration the airspace. One of the points I would make is that given to the Environment Agency taking on the role, the airspace is not denied. None of the airspace is do you believe you would have the expertise? denied to any user. Particularly the military can Sir Roy McNulty: The CAA certainly has the regularly fly in controlled airspace. However, their expertise in relation to noise. I think we are among training requirements, their high energy movements the leading experts in the country as far as noise is in large formations of aircraft tend to mean that the concerned, which is one important part of the airspace they utilise, predominantly over the sea and equation. Given the remit which we are expecting to some of the lesser populated areas of northern get in relation to Heathrow and air quality, I have no Scotland for specific low flying training, does not doubt we will acquire the expertise. I think our track mean to say they cannot have access to other parts record as regulator shows that we are independent, of the sky when they need it. In terms of carving up we operate in a very rigorous way, we acquire the the airspace, of course most of the military training, expertise we need to do the job and we do it properly. apart from designated danger areas, is free airspace to GA, to gliders, and it is shared. It is uncontrolled airspace, much of it flown in the principle of “see and Q525 Mr Martlew: Can I come to the aspect of the avoid”, so this idea of percentages implying that a division between military and civil aviation? Is the split right? My understanding is the use by military certain amount of airspace, as Sir Roy has outlined, aircraft of airspace has reduced considerably over is completely closed to the military and that the the last decade. Is that correct? military can only use another part of the world is Sir Roy McNulty: I will invite Mark Swan in a comparing apples with pears to a degree and I think moment to comment on it, but I assume you are can confuse the debate on who gets to own what and talking about the division between controlled and who uses particular portions. uncontrolled airspace. There have been lots of figures bandied about, both in front of this Q528 Mr Martlew: So can I take it there is no Committee more recently and elsewhere. It is quite particular problem? confusing because it depends on what you are Sir Roy McNulty: We do not believe there is an issue, talking about. which is not to say that some users do not perpetually complain about the subject and they Q526 Mr Martlew: Tell us what we should be love a debate about whether it should be 40, 60, 55, talking about. 45 or something, but the CAA has never started Sir Roy McNulty: I can come up with several from the point of view of, “Let’s decide we will give options. One of the problems when you talk about 60 to one and 40 to the other.” The 60/40 is an end airspace is how far up are you going? As some people result of a case by case allocation of airspace for put it, do you go all the way up to God or are you particular needs and making sure that the system is quantifying something a little bit shorter than that? kept safe. We have to bear in mind that above 19,500 ft all of the airspace is controlled, because that is where all the international flying takes place, and so on. If you Q529 Mr Martlew: If I can just go on from that come down below 19,500 ft, 40% of that is controlled slightly, my experience of military aircraft is in airspace. If you add a lump of the airspace above Cumbria and it is low flying. We do not see much of 19,500 ft you can get to 60% controlled but, as I say, it now, but it is a tranquil area and I think there are it depends on what you mean. Having said that, it is comments here from some of the county councils. I Processed: 06-07-2009 18:41:20 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG6

Transport Committee: Evidence Ev 85

22 April 2009 Jim Fitzpatrick MP, Mr Jonathan Moor, Mr John Parkinson, Sir Roy McNulty and Mr Mark Swan am not just talking about military aircraft, I am strategy. Virgin Atlantic and BA have told us they talking about overall. What do you do to preserve have not yet been contacted about the FAS work. the tranquillity of various parts of the countryside? How do you respond to that criticism? Surely these Sir Roy McNulty: The main thing the CAA does in are major stakeholders? relation to this is handling airspace changes when Sir Roy McNulty: I do not think it is entirely fair to these are proposed. We handle airspace changes in say that nothing much has been done on this front. accordance with a quite detailed set of guidance For the last three or four years, I think, since we which we get from the Secretary of State, 20 pages kicked oV this exercise, we, together with NATS and worth, which covers all the diVerent factors we need the MoD, have done a number of studies, the major to take into account. One of those factors is one of which was done by NATS, what we called a tranquillity, but also another factor is limiting the “scoping study. What it showed was that in looking noise nuisance to large volumes of population, but at this very major exercise, which is looking at you cannot allow one of those factors to drive airspace needs and policies out to 2030 so it is everything. We try to arrive at a balanced judgment looking 20 years ahead, the conclusion a year or so taking those factors into account, together with the ago was that there were still too many major need to move traYceYciently and the need to unknowns to carry this work forward meaningfully. preserve safety above all else. For one thing, it was uncertain what would be the outcome of all of this Single Sky II and SESAR Q530 Mr Martlew: So you do not have any exercise in Europe, which will have a major bearing designated areas where you say we should not fly on the way in which we manage our airspace in this there? country. There has been a debate going on about a Sir Roy McNulty: No, we endeavour, in line with the third runway at Heathrow, which is a major factor as guidance we have, to avoid Areas of Outstanding regards airspace in the South East. There have been Natural Beauty and we recognise the desirability of discussions about environmental climate change and keeping tranquil areas tranquil where possible. how that relates to aviation, and that debate is not yet finished. The conclusion between ourselves from Q531 Mr Martlew: The other option is that you give the initial studies was that it was too early to push everybody a bit of the noise and spread it out? this forward because there were too many open Sir Roy McNulty: Absolutely, and thus annoy questions. We have now concluded that with the everybody! We do try to avoid that. decision on Heathrow and with the conclusions we can now see on Single European Sky II and SESAR we can see the way forward a bit more clearly, and Q532 Chairman: Minister, are you satisfied with one of Mark’s initiatives has been to launch now for progress on developing the Future Airspace real a project definition study on this Future Strategy? There does not seem to be much progress Airspace Strategy. I think I said at the previous in developing that. Are you satisfied with the work hearing I attended that this is not a short exercise, that is being done? this will take us two or three years, but consultation Jim Fitzpatrick: We certainly think that the process with all of the major stakeholders for sure will works properly. As Sir Roy has just indicated, the happen, probably an initial round sometime this guidance which is issued through the regulator from year, and we will take this forward, but it is a non- the Department is quite voluminous. The potential trivial exercise. This is a very complicated exercise conflict between Areas of Outstanding Natural and it will fully take, I think, the two or three years Beauty, population centres, et cetera, has to be I indicated. worked out and we are going to be consulting later Mr Moor: I would just add that we have established this year on the guidance in line with the a joint project board, which is jointly chaired by recommendations from the Pilling reports in respect myself and Mark Swan and involves NATS as well, of environmental issues. We are satisfied that the to start taking this work forward and developing it. way it has been operated up until this point has been As Sir Roy said, we intend consulting on it at an satisfactory, but by virtue of the fact that aviation, as appropriate time, once we have actually got the we described earlier on, is expanding, the demands work underway and we have something to consult at Heathrow and elsewhere, airspace change on. processes require scrutiny and consultative Mr Swan: I would just add, Chairman, to echo Sir arrangements and we have been going through those Roy’s comments about the certainty, we are now on in several areas, as you know. There have been lots an established programme footing with this work, so of interest groups which have been lobbying strongly if I may just answer the criticism, the time simply was that we should go one way rather than the other and not right to engage the external stakeholders, who clearly that process seems to have been working are very keen to see this work, simply because there because people had the opportunity to express their is no point at this particular stage in going to them views as to where the change should be and where it with a series of products which, frankly,we could not should not be. have a useful debate over. But we are very keen to get their input at the right time and, as Sir Roy has said, Q533 Sir Peter Soulsby: On that, could I just put to that will be sometime soon. you what the Airport Operators Association said to us? They said they had not been invited to field any experts to contribute to this much needed work. Q534 Chairman: So it has been a matter of timing? They were talking there about the future airspace It is not neglect, it is just timing? Processed: 06-07-2009 18:41:20 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG6

Ev 86 Transport Committee: Evidence

22 April 2009 Jim Fitzpatrick MP, Mr Jonathan Moor, Mr John Parkinson, Sir Roy McNulty and Mr Mark Swan

Mr Swan: It is timing, Chairman, yes. emissions is certainly much more prominent now than even in 2007. The Secretary of State’s statement Q535 Chairman: We have been told that your 2002 in respect of Heathrow quite clearly indicates that. environmental guidance lacks clarity, particularly in The Department’s policy on CO2 emissions as terms of priority attached to environmental impacts regards aviation where we have been successful in such as noise and emissions. Do you agree with that leading the argument for aviation to be included in criticism? the Emissions Trading Scheme within Europe, Mr Moor: We are working on this at the moment as although we lost the argument internationally at part of responding to Sir Joseph Pilling’s ICAO, and the benchmarking of CO2 emissions at recommendation on setting the environmental duty the 2005 average in the future all indicate that CO2 for the CAA. Project work is being undertaken now emissions is a very important aspect of aviation and we are proposing to consult later this year on a policy for the Government. I am sorry, Chairman, I draft environmental duty for the CAA which would am not privy to why it was not mentioned in CAP also include looking at the guidance and how the 725. guidance should be updated in line with that. Q540 Chairman: Can any of your colleagues give us Q536 Chairman: When exactly will the Department some information? provide the CAA with an environmental policy Sir Roy McNulty: If my answer is not complete I will framework? send you a supplementary note, but CAP 725 was re- Mr Moor: The environmental duty would be part of issued because we had done a review of the Airspace an aviation regulation bill and that would depend on Change Process. We had, I think, streamlined it in a when parliamentary time is available. The question number of respects and that was why it was re-issued is, would the guidance be updated in advance of that in 2007. That is just talking about the process we use bill or as part of that bill, and I think that is something we still need to work through with the for assessing airspace changes, but the Airspace CAA. Change Process was still being operated under the same environmental guidance which had been given to us in 2002 and I think anything that needed to be Q537 Chairman: So you do not feel any concern picked up from Stern or from Eddington I would about the time lapse? expect to surface in the new edition of the Mr Moor: We feel that the guidance at the moment environmental guidance. I do not think there was is fit for purpose, and maybe Sir Roy might want to anything in either of those reports that changed the add more to that. process we followed. Sir Roy McNulty: I know the sort of statement which was made to you and has been made to me, that the guidance is not a formula that you can apply Q541 Chairman: So are you satisfied then that the to each and every situation, and I think that is as it CAA’s airspace policy documents do actually reflect should be. There is a degree of judgment involved in up to date Government policy? these things and the environmental considerations Sir Roy McNulty: They reflect Government policy which would apply to airspace changes, let us say as given to us through the environmental guidance. around London, are completely diVerent from the considerations which might apply, say, in Cumbria or Scotland. To that extent the guidance is general Q542 Mr Hollobone: Can we turn to Europe and the guidance, it is not a recipe that solves each and every question of the Single European Sky. The Single question, and I think that is the way it will probably European Sky programme aims to create by 2020 an remain because there is no such thing as a perfect air traYc management system designed, managed formula that solves all the questions we get and regulated in a harmonised way to sustain presented with. European aviation from an air traYc movement point of view for the next 30 or 40 years. The Q538 Chairman: Should reductions in CO2 emissions witnesses we have had before the Committee have feature much more largely in that? almost uniformly supported the Single European Sir Roy McNulty: Again, that is a question for the Sky initiative, but some have raised concerns that Government ultimately, but I would imagine, given there may be political obstacles. British Airways told the prominence and importance of CO2 emissions us that the Single European Sky programme needed and given the targets which have now been nailed in “full UK backing in order to realize their benefits”, place, I would expect that the new version of this will and “ultimately, it is a question of national political certainly give attention to CO2 emissions. will to design and implement cross-border, eYcient airspace integration”. A number of aerospace Q539 Chairman: Could I direct that question to the companies also told us that the greatest obstacles to Minister and in answering it, Minister, could you tell the Single European Sky were also political. This us why the 2007 issue of CAP 725 does not mention question is to the Minister. Given that the Secretary the Stern or the Eddington Reports? of State has recently confirmed that the UK remains Jim Fitzpatrick: I am sorry, I cannot explain why it a “firm supporter” of the Single European Sky, does does not mention it, given that it was just as I was the Government see any institutional or financial arriving at the Department. My colleagues might be problems with the UK’s involvement with the Single able to answer. Certainly the question of CO2 European Sky II package or with SESAR? Processed: 06-07-2009 18:41:20 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG6

Transport Committee: Evidence Ev 87

22 April 2009 Jim Fitzpatrick MP, Mr Jonathan Moor, Mr John Parkinson, Sir Roy McNulty and Mr Mark Swan

Jim Fitzpatrick: We are still committed to both. Sir Roy McNulty: I do not know all about that Clearly, as with any pan-European initiative, there particular set of words, but I have had many are going to be obstacles to overcome. However, we discussions with the Head of Eurocontrol, and are firmly of the opinion that there are benefits which indeed with the European Commission, and I think will accrue to aviation in the UK and in the world in indeed they were represented in front of you not so terms of climate change with the ability of countries long ago. The very clear policy emphasis from them to cooperate more fully and therefore aircraft to be is on partnership and collaboration. It is not a case able to fly more directly rather than the that Eurocontrol will dictate how we arrange our awkwardness that exists at the moment. I do not aVairs in this country, but if there are legitimate think we are blind to the fact that there are issues which they think should be raised they challenges ahead, but we are committed to the certainly will be raised with us and we will respond process and will continue to do so. to them, hopefully in a spirit of partnership and collaboration to work out the problems. Sometimes—and I have had a lot of experience of Q543 Mr Hollobone: A key component of the Single this—we have seen words coming from Europe European Sky II proposal is the establishment of a which maybe sometimes have lost something in Network Management Function whose ultimate translation or acquired something in translation responsibility would be the coordination between V which was not really intended. The arrangements, di erent Functional Airspace Blocks in Europe and for Network Management, are very clearly, in my to formalise the existing arrangements for the mind, in the mode of collaboration and partnership design, allocation and use of airspace. Eurocontrol and no infringement on things which we would is likely to perform this role. In its written evidence regard as vital prerogatives of our regulatory to this Committee, Eurocontrol said, “airspace system here. planning, design and management and the pre- requisite processes can currently hardly be considered as a national, sovereign responsibility Q546 Mr Hollobone: Yes, but, Sir Roy, sometimes any more”. My question to the Minister is this: does these words from European institutions come back the Department guarantee that the proposed to bite us in a very severe way decades on.. Network Management Function would not have the Sir Roy McNulty: Absolutely, which is why we pay power to overrule national regulator enormous attention to the legislation, to the recommendations? Secondly, do you agree with implementing rules, and so on. This, I think, is just Eurocontrol that airspace planning, design and from a paper, but what I think Mr Hendricks said to management can currently “hardly be considered as you in his evidence was more clearly of a national, sovereign responsibility any more”? collaborative and partnership nature than those Jim Fitzpatrick: We are certainly of the opinion that words could be taken to mean. it would not compromise us in terms of sovereignty. It would respect national airspace. In relation to the Q547 Mr Hollobone: Can we move on to the issue of protections which we have in place, despite the fact EASA? The Single European Sky II package also that we are positive partners in trying to push this includes the objective of establishing a single safety whole thing forward as far as we are concerned those framework for Europe, centred on the European safeguards are very real and we are very confident Aviation Safety Agency (EASA), in order to that we can protect the sovereignty of UK airspace, improve safety levels alongside the increase in air so we do not see that there is a problem and that we traYc. Are you, Minister, and you, Sir Roy, satisfied would have to surrender that. that the proposed extension of EASA’s responsibilities to include the safety of air traYc management will not reduce the UK’s high safety Q544 Mr Hollobone: Can you guarantee that the V power to overrule national regulator standards and is EASA now running e ectively and recommendations would not be passed to Europe? at full capacity? Jim Fitzpatrick: Mr Hollobone, I cannot guarantee Jim Fitzpatrick: I can certainly assure you, Mr that I am going to be able to walk out of this room Hollobone, that safety is the Government’s priority in half an hour! On the ability to give that cast iron and that we will work closely with the CAA to ensure guarantee, as far as we are concerned we see that that the excellent aviation safety record of the UK is there is no threat to UK sovereignty within the not compromised. EASA has made considerable framework that is being established because it is improvements in recent years, in particular in respect cooperative and that sovereignty is written into the of business planning. The first draft business plan for arrangements as they stand at the moment. the next five years has been adopted in December 2007 and the financial situation in terms of fees and charges regulation came in to force in 2007, which Q545 Mr Hollobone: Are you concerned, as I and has stabilised EASA’s budget. The management others are, that Eurocontrol should have said what board, on which all Member States are represented, it has said in its written evidence to this Committee? is providing more eVective strategic oversight. This Jim Fitzpatrick: To be perfectly frank, until I heard is currently being chaired by one of the UK you say it 30 seconds ago I had not even considered representatives, I understand, from the CAA and the it, so to ask me to give an instant judgment as to agency has adopted a more consistent constructive why—obviously, Sir Roy has put his hand up and he partnership approach with national aviation clearly has a better perspective on this than I have. authorities such as the CAA. So we do believe that Processed: 06-07-2009 18:41:20 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG6

Ev 88 Transport Committee: Evidence

22 April 2009 Jim Fitzpatrick MP, Mr Jonathan Moor, Mr John Parkinson, Sir Roy McNulty and Mr Mark Swan

EASA has come a considerable way, European countries either have fitted or have trained notwithstanding that they were criticised in the years at this point, although the overall European before, and we do not believe that there is a problem aspiration for P-RNAV is still there as a concept. in terms of safety because, as I have said, we want to make sure that our record is not in any way, shape or Q549 Sir Peter Soulsby: So what do you see as the form compromised. steps that are necessary to assess the benefits and the Sir Roy McNulty: I am equally satisfied on that timeframe for doing it? front. We spend an enormous amount of time and Mr Swan: Some steps are already in place. I think the attention studying EASA’s plans and proposals. We UK has had the initiative in terms of from the CAA go through them with a fine toothcomb. We debate perspective NATS was instructed some time ago in anything we are uncomfortable with, and to date we terms of all future airspace design to include P- have ended up with regulations we are quite satisfied RNAV capability within that airspace change and with. As regards air traYc management, the same there has been the odd trial of P-RNAV routes, process has gone around. The initial proposals were notably Arlanda in Sweden, but of course that not acceptable to us. We raised many objections. airspace is not nearly as congested as the London Those objections have been listened to. The TMA. There are some trials but as yet the risk to proposition is now in a shape we can live with. On delivery of the final benefits I think will be a crawl, your second point, EASA does not yet have the walk, run, type of concept with careful evaluation capacity to fully exercise those functions once they based on the safety appraisal of just how good these are in place but there is a European budgetary navigational techniques are and what that will mean process to be gone through, which is always a rather in real terms for improving eYciency. painful exercise. To date, once they have gone through their budgetary processes and they do get Q550 Sir Peter Soulsby: What do you think is a the people they need and the resources in place—and realistic timeframe for looking to the we are very fortunate to have Michael Smethers as implementation of some of these benefits? Chairman of the Management Board—one of the Mr Swan: It is very diYcult for me to judge. I do not priorities we have put on it is making sure that the have the background expertise to really quantify it. resources are obtained to do the job properly. I would say in the order of years, though, in order to understand the eYciency benefits to be derived and building on the current initiatives one could imagine Q548 Sir Peter Soulsby: We have had quite a lot of in, let us say, for example, something like a five year evidence about the benefits of fitting the most period when your careful airspace design process sophisticated navigation kits available beyond the starts to take place, then you would be able to really standard which is mandated for airlines. I just assimilate the benefits this could bring. Due to the wonder whether you can give us a view as to whether safety case and the complexity of the airspace we are those benefits are really as great as has been talking about, it really is a walk, crawl, run, but I suggested, and if they are what is preventing their think the European aspiration we fully support. being adopted universally in UK airspace? Sir Roy McNulty: Might I invite Mark Swan to Q551 Sir Peter Soulsby: Does the Department see comment on that? that as a realistic timeframe? Mr Swan: I assume you are predominantly referring Mr Moor: Yes, I think we do. I think this is an to P-RNAV, Precision Radio Navigation Aids, a essential part of where SESAR and other European step change in capability in that one no longer would initiatives can add some real value to having an have to rely on just ground beaconing in order to approach across Europe which is mutually agreed, increase your navigational eYciency in any piece of which will ultimately end up in significant reductions airspace. On the P-RNAV as a concept in terms of not only in time delays but also potentially risk to delivery of the benefits you have alluded to, I reductions in CO2 emissions as well. I think the think the overall answer is that we simply do not technology behind P-RNAV and other initiatives is know yet what the extent of those benefits will be, quite essential in terms of getting the benefits which but theoretically given the end state that could be we are hoping from the Single European Sky. reached with all aircraft using densely controlled airspace fitted with this type of equipment and the Q552 Chairman: How does the Department’s receiving air fields appropriately configured, one can guidance to the CAA protect general aviation from see there could be tremendous benefits in the areas of being squeezed into smaller areas? Does the reducing separation minima between aircraft in Department give any guidance to try to achieve that? allowing improved continuous descent approaches, Mr Moor: We recognise the value general aviation with the knock-on noise and environmental eVects. contributes to the economy, but one of the issues But of course all of this has to be taken inside the here is that it will always be a balance between the framework of the safety network which would two and I think, as Sir Roy said earlier, this 60%/40% manage this increase in navigation eYciency and between controlled airspace and uncontrolled that is where the risk has to be mitigated most airspace is not a given percentage, it is a balance to carefully in the already existing control procedures be achieved. We recognise the value of general that we have. I think the other point I would oVer is aviation, but we also recognise the value of that of course in terms of UK airspace we do not expanding commercial aviation and civil aviation, so control what other European companies and other I think it is very important that we maintain that Processed: 06-07-2009 18:41:20 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG6

Transport Committee: Evidence Ev 89

22 April 2009 Jim Fitzpatrick MP, Mr Jonathan Moor, Mr John Parkinson, Sir Roy McNulty and Mr Mark Swan balance. I am not sure we need to give any more Mr Moor: We have regular conversations with CLG guidance, but perhaps Sir Roy has a view on that about planning land use and there is a number of as well. proposals even at this moment about changing Sir Roy McNulty: I do not feel there is any need for airports into diVerent alternative use and that is more guidance, but that is a position I am usually in! something which from an aviation perspective we I do not think it is as serious a squeeze as is have concerns about and those are conversations we sometimes portrayed. We did a calculation recently have had with CLG, but there is an awful lot of on the change between controlled and uncontrolled airports in the UK and it is quite diYcult to assess airspace and uncontrolled airspace has reduced by how that land use should be used most eVectively in something like 2% over the last five years and the regional areas. I think that is why we feel it is compared with other kinds of squeezes one can think appropriate for local planning authorities to make of, that is not very extreme. What I think is more of those decisions rather than bringing it to a national an issue for general aviation is access to airfields. level. There have been pressures at large busy airports to hike their charges and general aviation is being squeezed out of those for commercial reasons. There Q556 Mr Martlew: Just on that point, we are not have been smaller airfields acquired for housing or making any more airports, are we? The danger is other purposes and built on and so are no longer that we have got existing airports and a lot of them available to general aviation. In my mind that is a are in the wrong place because they were there for the bigger issue than airspace issues. War, but you are not going to open any new airports and the more you lose, the less capacity you have unless you add extra strips? Is that not a fact? If more Q553 Chairman: Whose responsibility would it be to airports go out of business, then you are going to address that? have more capacity problems? Sir Roy McNulty: We did a strategic review of Mr Moor: In terms of civil aviation, this is what we general aviation three or four years ago. It was an looked at in the Air Transport White Paper and back issue which was flagged up. The Department, I in 2002 we looked at over 400 diVerent potential think, agreed to discuss that with DCLG and schemes for expansion, many of them small airports whoever else is involved from a planning point of which had an aspiration to expand. Our decision at view. I think it is certainly, in my mind, more a that stage was to allow the expansion of existing Government policy issue. airports because we felt that was sustainable growth, rather than going to a small airport and changing that into a much larger airport. We believe the Air Q554 Chairman: Is that something the Department Transport White Paper is a sensible approach to the has discussed with DCLG? overall civil aviation need. We do recognise, though, Mr Moor: I think this comes back ultimately to that there is a growing demand for general aviation overall capacity constraints we have across the and business aviation. There is capacity around the aviation sector and I am afraid a lot of this is a country for that, but in order to deal with that you knock-on implication, so when you have an airport have to balance the diVerences between the noise and Y like Heathrow, which is operating at 99%, tra c that growing demand. which would have gone there moves to another airport, and it goes down the chain, so you end up with airports like Biggin Hill being used much more Q557 Mr Leech: I am not sure whether you have now for business aviation because they have been answered this question already, but is the squeezed out of other airports within the Central Department or the CAA a statutory consultee in London area. So I think the issue here ultimately planning applications to convert airports to comes down to the need for more capacity across the something else? whole of the South East airspace, but I think we also Mr Moor: It is not from the Department’s have to bear in mind that there are quite perspective, but the CAA — considerable issues at a local level with small Sir Roy McNulty: I do not think so, but I can check. airports and noise and regularly we receive letters from airports complaining about noise considerations. Our view is that our Air Transport Q558 Mr Leech: Is there not a case, though, that if a White Paper looks at it at a national level, at decision made by a local authority may have a long- nationally significant airports, and therefore CLG is term impact on the aviation industry because you expected to give planning guidance around the are getting rid of a small airfield, then surely the application of local airports. But again, even at a Department or the CAA should be a statutory local level there is always this balance between noise, consultee? Do you not agree with that? pollution and the local economy and the benefits Mr Moor: What I would say is that we obviously aviation brings to it. would be a consultee on any of the strategic airports we set out in the Air Transport White Paper. Those are the airports we decided were nationally Q555 Chairman: But have you been aware of this as important and therefore the airports we took a view a specific issue? One of the points Sir Roy has just on, and we then did a progress report and for the top made is about diVerent land use. Is that something airports we have asked them to do master plans as you have been aware of? well. Processed: 06-07-2009 18:41:20 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG6

Ev 90 Transport Committee: Evidence

22 April 2009 Jim Fitzpatrick MP, Mr Jonathan Moor, Mr John Parkinson, Sir Roy McNulty and Mr Mark Swan

Q559 Mr Leech: But from the perspective of general decisions being made at a local level that one flight aviation and business aviation, if they are being should have priority over another, then that would constantly squeezed out of the bigger airports and be a local matter. Forgive me, I am not familiar with these smaller airports are becoming more important what the national regulations say in terms of for general aviation, surely in those circumstances whether we have a role in determining which aircraft the smaller airports then should take on a higher takes oV as opposed to another. significance than they have in the past? Mr Moor: If I could just add to that, it is a Mr Moor: I just come back to the Air Transport competitive marketplace and we do not run airports White Paper and even in the White Paper we looked at the end of the day. General aviation, we recognise, at quite an amount of smaller airports. I think our contributes significantly to the UK economy and view here is that what is happening in smaller therefore there are airports in the South East as well airports is that often business aviation is squeezing as around the country which provide a service to out general aviation because it is more valuable to general aviation and to business aviation. In terms of the airport itself. So if you go to Biggin Hill, you can rationing slots, if I take an example, City Airport see a very clear indication there that business does have business aviation flying in and out of it. aviation is taking a much greater proportion of their They have been squeezed recently and that is a air traYc movements in comparison with general commercial matter because they can make more aviation. That does not mean to say that general money by selling a slot to a commercial provider aviation has not gone somewhere else or cannot still than to a business aviation provider. However, if that operate from Biggin Hill. When you go to see these slot is really valuable to that business aviation small airports, I do not believe they have a huge capacity overall problem because certainly Biggin provider, I am sure they can also pay. Hill is an active marketer in terms of getting more businesses to operate out of that airport. Q562 Ms Smith: London City Airport itself has actually said that some form of organised priority Q560 Chairman: Minister, is this something which action based on the economic significance of has been drawn to your attention as a policy issue? passengers might be a good idea, but would the view Jim Fitzpatrick: Planning disputes or planning be in the DfT as well that there is a potential applications with the CLG—I am aware of several environmental impact from following such a course which have gone through the process. One in of action which would be detrimental to the UK particular comes to mind where the airport was generally? In other words, if you give priority to partly owned by the Maritime and Coastguard smaller aircraft with fewer numbers of passengers on Agency and Hampshire Constabulary and there was board, that in itself would be environmentally a dispute between them and GA, so I know these damaging? issues are around, but in terms of a formal role as a consultee—forgive me, I would have to check the Jim Fitzpatrick: We have outlined in broader strokes records, Chairman, but I do not remember our concern about the environmental impact of expressing a formal opinion other than just to be aviation and set out how we would want to see it aware, because it concerns general aviation, that progressing in general terms. The question of the size these issues at smaller airports were happening, and of aircraft and the capacity of aircraft and whether certainly when I meet representatives of GA they do they are flying with fewer passengers is an entirely articulate a concern that there is a squeeze, but I separate issue and we have actually made think, as we have said, it is more in the perception pronouncements in respect of the ability of slots to and more in the change of pressures from be protected at the moment because of the economic commercial operators than anything else. downturn, not to be lost to airlines as a result of their Ms Smith: The British Business and General not being able to use them, and a temporary measure Aviation Association suggests that economic values over the summer months. Forgive me, City Airport should be at the heart of every UK aviation policy is in my constituency, I should probably say, decision and they have said that it seems Chairman, because I am a big supporter. They anachronistic that a scheduled carrier laden with employ quite a lot of people and are very proactive party-goers destined for a cheap weekend in Prague in the community, so I understand the pressures they should have the legal right to displace traYc of far are under, as outlined by Jonathan, but they are greater net worth to the British economy. This was working in a commercial environment, as are other something they brought up when they came to give small airports, and therefore they will look to evidence. Does the DfT believe that this concept of maximise their revenue to make sure they are able to rationing or planning for use of air space according function. City Airport is probably better placed to the economic worth of the flight has any because it is a successful airport, despite catering for credibility? both commercial and general as well as private flights. With the smaller airfields, again they have Q561 Chairman: Minister, is this a policy you these conflicting issues which they have to deal with. might pursue? I am not sure the environmental dimensions would Jim Fitzpatrick: Given the pressures on general be a major concern for the Department because we aviation, I think there are going to be conflicting have laid out how we want aviation to contribute to interests and we would obviously want to make sure dealing with climate change in making its that general aviation had its place. If there are contribution to reducing emissions in overall terms. Processed: 06-07-2009 18:41:20 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG6

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22 April 2009 Jim Fitzpatrick MP, Mr Jonathan Moor, Mr John Parkinson, Sir Roy McNulty and Mr Mark Swan

Q563 Ms Smith: Would it be possible to objectively somebody and that’s not commercially viable for measure the diVerent economic significance of us.” So my question back to City Airport would be, diVerent flights? Would that be possible? “What market failure do you want us to correct Jim Fitzpatrick: It is clearly possible to determine for?” It is a competitive environment. the benefits of an A380 and the new technology of a brand new aircraft and its ability to fly with double the payloads of most other commercial aircraft and Q566 Mr Martlew: I represent an area which has a be quieter, cheaper and cleaner against older very small sub-regional airport, but it used to have a aircraft. I think the simple answer is that regular flight into Heathrow and it was important technologically it is possible to determine the carbon for the economy of that particular sub-region. If footprint of any engine. there is no priority given to anywhere, and bearing Ms Smith: I meant the economic significance of the in mind the major London airports have a national passengers. priority, surely there should be somebody who decides that you can fly in from one of the smaller airports, if you want to put a scheduled flight on, Q564 Chairman: Would it be possible to measure the that they have priority over the people going to the economic value of the passengers? The proposal put stag night in Prague because the economic benefits to us was that priority should be given to aircraft or to that sub-region are very important. air passengers depending on their economic value, Jim Fitzpatrick: I think that is absolutely fair and presumably to the country. Would it be possible to V V absolutely right, and indeed it is one of the issues we di erentiate between the di erent aircraft? regularly consider, and indeed are considering at the Jim Fitzpatrick: I think you are at risk of entering in moment. I have recently had representations from to the realm of individual privacy and the right to the Durham Tees Valley, because BMI have withdrawn individual to function. If somebody is coming on a their flight, they want to use the slot at Heathrow for private jet into City Airport going to Canary Wharf, something else. They are saying that actually has an they could be bringing in a contract worth £100 economic impact on their sub-region within the million to the UK economy. Equally, they could be North East. We have had representations previously coming in for a weekend to do shopping in Oxford from Inverness and from other parliamentary Street. It is the same as somebody who is travelling colleagues from diVerent parts of the country who on a commercial jet, who may be bringing in a big say that the economic regulation should consider contract or coming for a weekend shopping regional and sub-regional development as a higher expedition. To actually ask people to declare—well, priority than it does at the moment. That is a moving we do ask, “What is the purpose of your visit?” to a feast because that is a matter which will have to be certain extent, but when we screen them to make sure they are not a security risk, or whatever, I am not considered and applied each and every time, and it is sure—maybe I am entirely wrong here, Chairman. a matter which is under consideration by the Maybe we are screening everybody to work out who Department at present. we want to come into the country and who we do not want! Q567 Chairman: Is there anything in today’s Budget which could impact on the CAA’s work in relation Q565 Chairman: Are we going to have some to safety or environmental resources? revelations now? I will ask Sir Roy if he wants to Jim Fitzpatrick: I am not sure whether we have had come in on this. an opportunity,Chairman, to make an assessment of Sir Roy McNulty: I personally would view that as a the Budget. Forgive me, I am looking to my very impractical suggestion. I think the job of the colleagues. I do not know whether Sir Roy has had controllers is diYcult enough dealing with all the a chance to — factors they already address without looking at the Sir Roy McNulty: I have been busy with the price tag on the side of each aircraft to decide what Department all day and I thankfully know nothing priority it should have. I might add that at the time about the Budget! of the NATS PPP an idea which surfaced from somewhere, not from NATS, was that priority should be given to airlines who were prepared to pay Q568 Chairman: Are you aware of anything there for priority and that was scotched firmly by the which could impact upon the resources in relation to aviation minister at the time, and rightly so. I do not safety or the environment? think there is any place within the job of air traYc Jim Fitzpatrick: Obviously, there is bound to be control for commercial priority expressed in those something within the Budget but I have not had a terms. chance to study it yet. By virtue of the Government’s Mr Moor: If I could just say something briefly, I commitment to public expenditure and trying to think the key issue here is what market failure are build and grow the UK’s way out of a recession and you trying to regulate for, and I think in this instance Transport being the Department that it is in all its there does not seem to me to be a market failure aspects, not just aviation, a big player in terms of around who should use slots. As soon as you get into investment in public infrastructure, I would be very that environment and start to regulate about who surprised if there was not something there. In respect can use slots and who cannot use slots, you will start of whether there is something specifically dealing to actually have perverse market conditions where with aviation, I would have to check with colleagues the airports will say, “You are holding a slot back for and write to the Committee in due course. 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22 April 2009 Jim Fitzpatrick MP, Mr Jonathan Moor, Mr John Parkinson, Sir Roy McNulty and Mr Mark Swan

Q569 Chairman: Could we have any guarantee that Sir Roy McNulty: I think traditionally there has the budgets in relation to aviation safety and been a shortage and I agree with the comments the environmental issues would be protected? Minister made earlier. There is likely to be a Jim Fitzpatrick: I think you can certainly have a resumption of traYc growth and then there will be a guarantee, Chairman, that safety is the top priority need for more controllers. When I was in NATS we for the Government in respect of aviation, as it is in were facing one of our periodic binds in this respect shipping, as it is in road safety. With aviation clearly and we looked at every conceivable avenue to it is and we are very clearly on the record, as are all quicken up the supply of capable controllers. We of our partners and stakeholders, in regarding safety looked at the military aspect at that time and there as a top priority.In terms of the environment, I think was no easy solution available to us because, as we during the course of the last 90 minutes or so we have keep on saying in many contexts, safety is clearly outlined that this is something which is under paramount and we will not put diluted skills into consideration. We are reviewing the position at the doing a job like this. moment and we will be publishing later in the year. It was part of the planning inquiry, so the Q573 Sir Peter Soulsby: Is it likely to be a environment is something which is going to be particularly serious problem in the near future? pronounced on later and is something which is Sir Roy McNulty: In the near future, no. To an moving. As we have developed environmental policy extent, on this particular topic we get a benefit from to deal with climate change, the whole of the recession, so the pressures which constantly Government is looking at its role and its increasing traYc have put on the system are eased performance set against the targets which we have and will be probably for the next two or three years, agreed for Government in the years ahead. but long-term the need to attract and train qualified controllers will remain a challenge. In the very long- Q570 Chairman: There is a long and expensive term the job will change if SESAR is brought in and conversion process for military air traYc controllers is successful, but you will still need controllers, moving into civil work. Do you think there is any probably trained to an even higher level with reason to have a major review of that process, to diVerent skills, higher levels of skills. speed it up or to make it more eYcient? Mr Swan: If I may add, I think we, the UK, are Jim Fitzpatrick: I am sorry, Chairman, I am not signed up to a common core training requirement qualified to say anything on that. harmonised with the rest of Europe’s civilian air Sir Roy McNulty: I can maybe add a brief comment, traYc controllers and the military is not. As Sir Roy which may need a more detailed note in due course. has said, their training requirements are diVerent. The jobs which civil air traYc controllers and For the military to then adapt that common core military aircraft controllers do are fairly diVerent, so training requirement, I suspect—you would have to they are trained diVerently to do diVerent types of ask them—would probably cost a considerable jobs. It therefore is not the case that an ex-military amount of money, an investment for skills that controller falls easily into a civil job to perform that would not have to be used until they became civilians kind of task in an eYcient way. We do make some themselves, if that is the career they chose to pursue. allowance. I believe there is some reduction in terms So that harmonisation versus the financial trade-oV of the training requirement, but it is not a major I think is probably a key consideration were you to reduction. We would be quite happy, if the ask the MoD for its view. Committee wished, to do a review of that, but I am not sure it is an avenue where there is an easy quick Q574 Chairman: Minister, I would like to ask you win at the end of it. about the planning process, the planning system. Are you satisfied that the guidelines in place about Q571 Chairman: You are not aware of changes the parallel operation of the work of the which could be made? Infrastructure Planning Commission on airport Sir Roy McNulty: We can look at what changes development and the related responsibility of the CAA under the Airspace Change Process are could be made, but this has been looked at before Y and the conclusion basically was that they come su ciently clear? from diVerent backgrounds with diVerent skills, Jim Fitzpatrick: I think we covered a lot of this doing diVerent tasks before, and to make sure they earlier on, Chairman, when we were discussing the are absolutely as proficient as we need for civil air Airspace Change Process and how long it takes traYc controllers they need substantial training. We compared with the planning process for, for do not do that for fun. It costs NATS money and it example, Heathrow and how we made the is not done just because that is the way it has always consideration before having consulted with NATS been done. and it will have to be finalised afterwards once the planning application is in. The Planning Act which provides the new arrangements for national Q572 Sir Peter Soulsby: There is some evidence, I infrastructure projects is a lot clearer and a lot more think, from the airport operators who were drawing streamlined than that which went before. We are our attention to the predicted shortage of qualified confident that we can work within the process, and controllers in the future. First of all, are they right indeed in terms of the update of the Aviation White that there is likely to be a shortage, and if this is not Paper it is quite clear that when we said we would the solution, what is? review and progress publication every three to five Processed: 06-07-2009 18:41:20 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG6

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22 April 2009 Jim Fitzpatrick MP, Mr Jonathan Moor, Mr John Parkinson, Sir Roy McNulty and Mr Mark Swan years—and we are committed to a national policy from the planning process. The example I gave statement on aviation which will fit into the national earlier was Manchester. The second runway at planning process—that looks to be the way forward Manchester took four or five years in the in due course, where we are likely to be publishing development and getting planning approval. Once our next review. planning approval was obtained, the necessary airspace changes were made within a couple of years, Q575 Chairman: Sir Roy, do you have any views which was about half of the construction period, so on that? the two processes fitted together quite well, and that Sir Roy McNulty: I think they are obviously is the norm. connected subjects, but I have always seen the Chairman: Thank you very much for coming and Airspace Change Process as somewhat following on answering our questions. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [SE] PPSysB Job: 412381 Unit: PAG7

Ev 94 Transport Committee: Evidence Written evidence

Memorandum from the Campaign for National Parks (CNP) (AIR 01) The Campaign for National Parks (CNP) is the national charity which campaigns to protect and promote National Parks for the benefit and quiet enjoyment of all. We welcome the Committee’s inquiry into the use of airspace and are pleased to have this opportunity to submit evidence. 2. Of the Committee’s stated areas of interest, this submission relates to changes to airspace management that we believe are required as a result of the impact of increased airport capacity on National Parks.

Summary 3. Our main concerns about current and future projected capacity and use of airspace relate to the increased risk of noise and disturbance to National Parks, where peace, tranquillity and a sense of escape from day-to-day pressures are highly valued and defined as one of the special qualities for which these areas are designated in the first place. 4. We have set out below some brief background on National Parks and how they are reflected in aviation policy, by way of context to the comments that follow.

Background—National Parks

National Park purposes 5. National Parks in England and Wales have two statutory purposes:1 (i) to conserve and enhance the natural beauty, wildlife and cultural heritage of the National Parks; and (ii) to promote opportunities for the public understanding and enjoyment of the special qualities of the Parks. 6. A wide range of public bodies, including the Department for Transport (DfT) and the Civil Aviation Authority (CAA), must take these purposes into consideration when making decisions that could aVect the National Parks.2

National Parks and aviation policy 7. The Transport Act 2000 requires the CAA to carry out its air navigation functions in the manner it thinks best calculated to, among other things, take account of any guidance on environmental objectives issued by the Secretary of State.3 8. Directions issued under the Act also state that in relation to the environmental impacts of air operations, the CAA must take into account: (i) guidance given by the Secretary of State on the Government’s policies on sustainable development and on reducing, controlling and mitigating the impacts of civil aviation on the environment; (ii) the need to reduce, control and mitigate as far as possible the environmental impacts of civil aircraft operations and in particular the annoyance and disturbance caused to the general public arising from aircraft noise and vibration, and emissions from aircraft engines; and (iii) The need for environmental impacts to be considered from the earliest stages of planning.4 9. Guidance issued by the Secretary of State states that changes to airspace arrangements should be made after consultation, only where it is clear that an overall environmental benefit will accrue or where airspace management considerations and the overriding need for safety allow for no practical alternative [emphasis added].5 10. With regard specifically to the over-flight of National Parks and Areas of Outstanding Natural Beauty (AONBs) the Guidance states that while legislation and planning policy do not preclude over-flight of these areas and government policy will continue to focus on minimising over-flight of more densely populated areas below 2000ft, where it is possible to avoid over-flight of National Parks and AONBs below this altitude without adding to environmental burdens on more densely populated areas, it clearly makes sense to do so.6

1 As set out in section 5 of the National Parks and Access to the Countryside Act 1949, as amended by section 61 of the Environment Act 1995. 2 Section 11A(2) of the 1949 Act as amended by section 62(2) of the Environment Act 1995. 3 Section 70(2). 4 The Civil Aviation Authority (Air Navigation) Directions 2001, incorporating Variation Direction 2004. 5 Guidance to the Civil Aviation Authority on Environmental Objectives relating to the exercise of its Air Navigation Functions (2002), paragraph 36). 6 As above, para 45. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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11. Recognising the general policy aim to protect the special qualities which make the countryside attractive and special, including tranquility, and the specific aim to give strong protection to nationally designated landscapes such as National Parks AONBs, the Guidance also states that whenever practicable the CAA Director of Airspace Policy should pursue policies that will help to preserve the tranquility of the countryside where this does not increase significantly the environmental burdens on congested areas.7

Inquiry Questions

Is the current approach to planning and regulating the use of UK airspace adequate?

How are the eVects of aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted? How should the balance between conflicting interests be struck? 12. We are taking the questions above together because in the present context the issues of regulatory adequacy, aircraft noise, and the weight that should be given to competing environmental factors as well as non-environmental factors are connected—we believe that the current approach to regulating the use of airspace is inadequate insofar as it purports to protect National Parks from aircraft noise and disturbance. 13. How the eVects of aircraft noise and emissions are taken into account in decisions relating to airspace is set out in the background section above. 14. The inadequacy of the current regulatory framework has most recently been demonstrated in the endorsement by the CAA of proposals to extend the area of controlled airspace over parts of the New Forest National Park (the Terminal Control South West, or TCSW decision). This decision threatens to seriously disturb the peace and tranquillity of the National Park. 15. CNP, together with the New Forest National Park Authority and a strong body of respondents, expressed serious concern about the way in which the TCSW decision was taken, as well as the outcome, to the DfT. In particular, we questioned the evidence base underpinning the CAA’s decision and believe that in making it, insuYcient weight was given by the CAA to the impact of the proposals on tranquillity within the National Park. Our concern was only heightened by the fact that the DfT Guidance on environmental objectives referred to above, which the CAA is specifically required to take into account, could be interpreted by the regulator in such a way as to allow it to reach this decision. 16. In this context CNP has welcomed the publication of Sir Joseph Pilling’s report of his independent strategic review of the CAA, which makes a number of recommendations relating to the CAA’s environmental responsibilities. We have written to the Secretary of State for Transport strongly to urge her to accept the key environmental recommendations, in particular that: (i) the CAA should have a general statutory duty in relation to the environment; (ii) the Secretary of State should provide a framework which oVers guidance to the CAA on how to reconcile environmental and other competing considerations; and (iii) the DfT’s guidance on environmental objectives in relation to the CAA’s air navigation functions should be reviewed to ensure that it continues to be up to date. 17. In our view (ii) and (iii) link closely to the present inquiry’s questions concerning the adequacy of the current airspace regulatory framework and our comments to the Secretary of State are therefore summarised below. 18. CNP would strongly support the Government taking measures to strengthen the alignment of aviation policy with wider government environmental policy through the DfT Guidance. In particular, we believe that it should be strengthened to properly reflect the Government’s position on nationally designated landscapes. At present, while the Guidance seeks to acknowledge the special status of National Parks (see paras 45 and 46, cited above), we believe that it does not go far enough to give real meaning to the special status conferred on these areas by law, or to the statutory duty that binds the CAA and others to have regard to National Park purposes when making decisions that could aVect them. 19. In relation to the duty, Planning Policy Statement (PPS) 7 states that: . . . National Parks have been confirmed by the Government as having the highest status of protection in relation to landscape and scenic beauty.”8 [emphasis added] Defra guidance on the duty states that it is “particularly important to the delivery of the purposes of protected areas and to the overall achievement of sustainable development in rural areas.”9 The guidance goes on to make clear that while the duty does not override other obligations or considerations which have to be taken into account by public decision-making bodies, it is intended to ensure that the purposes for which National Parks have been designated are recognised as an essential consideration in reaching decisions or undertaking activities that have an impact on them.

7 As above, para 46. 8 Planning Policy Statement 7: Sustainable Development in Rural Areas, paragraph 21. 9 Duties on relevant authorities to have regard to the purposes of National Parks, Areas of Outstanding Natural Beauty (AONBs) and the Norfolk and SuVolk Broads. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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20. We believe that the TCSW decision provides evidence that the current regulatory framework for the use of airspace is inadequate to protect National Parks in the way envisaged by the statutory protection aVorded to them elsewhere. Other aspects of the Guidance, such as how diVerent environmental considerations are weighed up and the circumstances in which decisions must be referred to the Secretary of State, would also benefit from review. While the TCSW decision raised doubt as to whether the DfT Guidance as it stands was properly followed, we believe that it also highlighted the need for a fresh assessment of the Guidance itself in order to ensure that it provides adequate protection for all nationally designated landscapes, especially National Parks, in accordance with wider government policy. 21. Sir Joseph Pilling’s report provides a timely opportunity for the current policy shortcomings to be addressed and we would ask the Committee to join us in urging the Government to look favourably upon its recommendations. 22. National Parks represent some of the most peaceful and tranquil areas of England and Wales. The value that we as a nation ascribe to such qualities will only increase in coming years as the development of urban areas continues to grow and everyday life becomes generally more cluttered with noise and stress often attributable to transport. In this context it is critical that the protection of National Parks and other nationally designated landscapes is given the highest priority in all government policy that has the potential to have a negative impact on their special qualities, but especially in areas such as aviation expansion that pose a direct threat. September 2008

Memorandum from Mike Andrews and John Sargent (AIR 02)

Airspace Change Proposal—West Suffolk I am writing to you as a resident, for 16 years, of an area renowned for its beauty and also recognised on the CPRE Tranquility Map as an extremely quiet area. I believe that these facts have contributed to the very lucrative horse industry being centered on Newmarket and its environs. When low flying planes pass overhead, which they do from time to time, the noise level is unbelievable and the animals suVer accordingly. This is not good for the well-being of the animals—or the local residents come to that—and I can see the horse racing owners and breeders moving their studs elsewhere which will aVect the finances of the area also the job and trade economy. Any area as tranquil as Wickhambrook will be extremely aware of the noise levels created by the low flying planes on the stack and exit route. Especially as low as 7,000–4,000 feet as the planes make their final approach to Stansted. I fail to understand why the cannot be considered as a holding area, where few people would be disturbed. Also the value of property in this area will be greatly diminished. I therefore recommend that the new planned route be reconsidered taking into account the impact on the tranquilly of this area and the eVect it will have on the local equine, wildlife and other animals apart from humans, not to mention the tourist industry. Please register my strong objections to the new Airspace proposals. September 2008

Memorandum from Little Thurlow Parish Council (AIR 03)

Ref: NATS Proposals for a New Flight Stack for Stansted Western Approach We would like to comment on the current proposals, as invited. This is a short submission but we have also provided a bullet-point summary, as requested.

Summary — Reasons not to disturb rural areas of outstanding beauty and tranquillity. — Possibilities of using sea areas for stacking. — Reasons not to ‘share the problem’ uniformly. — More fundamental questions of technology and operational practice. — Need for a comprehensive international review. — Duty of government to think ahead and if necessary radically. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Submission 1. The village and area in which we live is at present relatively undisturbed, but the new proposals will radically aVect that, with a dramatic eVect on our quality of life. We are not alone in this, hence we do not simply suggest that the problem be moved elsewhere to another equally beautiful rural area. 2. One obvious place where it could be moved, however, is over the sea. Stansted is after all only 35-40 miles from the coast, or approximately 10 minutes flying time, so the schedules would not be seriously aVected by that, given that journeys are in any case going to be delayed by stacking anywhere, and usually for periods longer than 10 minutes. 3. One might also argue that if stacking over land is thought to be unavoidable it would be better to stack over areas already aVected by aircraft noise. “Spreading the problem” may sound fairer but the logical conclusion of that line of argument is that all parts of the country should be adversely aVected. One can see why that is a bad argument if you apply it to other environmental and conservation issues. The Government in other contexts rightly designates certain areas as protected or conservation areas freed from all kinds of urban and industrial development, and it should do the same in this area. “Noise pollution” is a very real form of pollution. 4. But the more fundamental consideration of all is why it is necessary to stack at all in this way? With modern technology there should be no reason why flight times cannot be adjusted so that arrival times can be synchronised without the necessity to stack over land. A large proportion of the routes for Stansted are in any case from Europe and that gives the opportunity for adjustments over the sea (including a complete turn if necessary) before anyone on the ground is inconvenienced. 5. Is it not time for a complete and radical review of all the Government’s policies in this area nationwide, and indeed with our partners in Europe and North America? This is a growing problem and all the forecasts are that despite temporary setbacks air traYc will go on increasing. We have gone far past the point where it makes sense to implement local and piecemeal solutions. We should now be aiming for a far-sighted and comprehensive set of policies which demand new technological and social solutions to what can only become more pressing global problems. Thank you for your attention to this submission. September 2008

Memorandum from Redhill Aerodrome Limited (RAL) (AIR 04) Please note that RAL has addressed itself only to Questions 1, 3, 6, 7 and 8 from the list of the 11 questions in the call for written evidence.

1. Summary of Arguments 1.1 RAL believes that the Government should rely on the White Paper forecast in terms of passenger numbers in relation to long term growth, but are concerned that the substantial change in traYc distribution arising from the growth in low cost carriers has not been taken into account in terms of provision of runway capacity, particularly at Gatwick. (Q1) 1.2 RAL has little confidence that NATS will become pro-active. It believes that an Airspace Master Plan through to 2030 is desirable, but that in practice a piecemeal approach will probably need to be adopted. Otherwise, any Master Plan would need to allow for airport developments not currently foreseen to be incorporated at a later stage. (Q3) 1.3 NATS future airspace design needs to take into account planned technical developments in Europe, particularly in relation to the Single European Sky. (Q6) 1.4 RAL is suspicious of the close relationship between NATS and BAA, which possibly aVects adversely plans put forward by other airports. (Q7) 1.5 RAL believes that airspace considerations unnecessarily delay the planning process, while unsubstantiated negative assessments are permitted to damn “unfavoured” plans. (Q8)

2. Background 2.1 Redhill Aerodrome Limited (RAL) is the owner and operator of Redhill Aerodrome in Surrey. Although currently a general aviation airfield with two grass runways, members of the House of Commons Transport Committee may be aware that RAL has long sought to convert it to a single surfaced runway of 2,000 metres and operate it as a reliever second runway for Gatwick Airport. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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2.2 RAL has been frustrated by BAA’s lack of vision for Gatwick, and its inability to understand how the presence of a reliever runway could significantly improve the profitability of their own facility. Instead it has favoured development at distant Stansted. This is perhaps a function of BAA’s dominance of London and South East airport capacity. 2.3 RAL gave verbal evidence to the Committee on May 7th 2003 in connection with its report on Aviation (HC454-I, July 2003). In the Committee’s Conclusions, paragraph 259 of the Report stated that: “It could take as long as 15 years to build any new runway (in the South East). This would fail to address the very real problems that exist today. Constrained capacity at Heathrow and Gatwick will lead to further reductions in regional access to London airports. There are a range of measures, particularly feeder-reliever airports that would provide for more immediate availability of runway capacity at or in close proximity to the airports where the demand is greatest. We strongly recommend the establishment of such an airport. Its most important function would be to act as ‘London’s regional airport’”. 2.4 Two possible locations for such an airport were considered—Redhill and Northolt, but in the following paragraph, the Report noted that: “A third runway at Heathrow would entail the closure of Northolt . . The Government must urgently consider whether an extended and re-aligned runway at Northolt would provide an increase in capacity more quickly and with lower environmental impacts than a third runway at Heathrow”. 2.5 Finally, in paragraph 264, the Committee noted that: Any development will have environmental impacts. We believe those impacts will be minimised by: — making best use of existing facilities (as recognised by the subsequent Future of Aviation White Paper); — expanding existing airports on a case by case basis; and — dismissing the construction of new major airports on Greenfield sites. 2.6 RAL is in total agreement with these conclusions. Redhill is an existing facility which is underused, while the existing runway at Gatwick could be far better used by larger intercontinental aircraft. 2.7 Similar conclusions were reached by an earlier Select Committee Report in 1998. This report on Regional Air Services (Report 589-I, July 1998) concluded (paragraph 120) that further studies should be made on both Northolt and Redhill, even though “a planning application to create a feeder airport (at Redhill) was rejected by the last Government”. 2.8 A full presentation was made to the Department for Transport in 2003 as part of its pre-White Paper studies. The rejection of the proposal can be seen in paragraphs 11.117 to 11.119 of the White Paper (Cm 6046, December 2003). There is a suspicion that, at an earlier stage, drafts of the White Paper included a recommendation for a new runway at Redhill, but that pressure was brought to bear on the DfT to alter that conclusion. 2.9 The main reasons given for rejection of the plans to construct a reliever airport at Redhill (including the planning application) were concerned with airspace availability, which is why RAL is anxious to share its views on the current approach to airspace taken by NATS, the CAA and the Department for Transport. 2.10 For the benefit of the members of the Committee, the features and benefits of an expanded Redhill Airport can be summarised as follows: (a) A single 2,000 metre runway capable of handling all domestic and European flights (but not intercontinental flights) within five years. (b) The runway would be four miles north-north-east of Gatwick’s current runway, and parallel to it, minimising any chance of airspace conflict. (c) The airport would have its own passenger terminal capable of handling 200,000 flights and 20 million passengers annually (compared to 250,000 flights and 30-40 million passengers at Gatwick). (d) The passenger terminal would be linked to the existing Gatwick terminals by a dedicated rapid transit line adjacent to the existing London to Gatwick rail line at the western end of the runway. The journeys would take some six minutes, (compared to three minutes between Gatwick South and North Terminals and faster than today’s transfers between the various terminals at Heathrow). (e) The passenger terminal would also be linked to the adjacent M23 motorway to London at the eastern end of the runway by a short spur road, which would also serve the regional A&E centre at the Royal Surrey Hospital. (f) The loss of just two residential properties. The majority of the land required for the development is currently under the control of the Directors of the company. (g) A reduction of noise over Redhill and Nutfield caused by the termination of the current general aviation training circuits—a noise survey in 1994 showed that some 1,500 households were aVected by noise at 57 Leq. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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(h) The new alignment and approach paths are expected to result in an extra 20 residences being exposed at 57 Leq, but with at least 500 being taken out of the existing noise nuisance category— a net benefit to local residents. Almost all of the 57 Leq contour is over open Green Belt land. (i) The proposal would be of benefit to BAA as the owners of Gatwick Airport. With large numbers of smaller regional aircraft transferring to Redhill, the slots made available could be used by additional long-haul aircraft with greater passenger loads, enabling Gatwick Airport to make best use of its existing facilities at the same time as the facilities at Redhill are also used to best eVect. This proposal meets ALL of the requirements as outlined in paragraph 264 of the Select Committee’s conclusions to its 2003 report on Aviation, in particular in relation to making best use of existing facilities—a conclusion re-iterated in the executive summary of the subsequent White Paper. (j) This development could proceed without impacting on BAA’s agreement with West Sussex CC not to construct a second runway at Gatwick before 2019. (k) Given the speed and low cost of this proposal Redhill hopes that it will be the chosen option.

3. Response to Question 1

Question 1. (a) What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? (b) Are the White Paper’s projections for increased passenger demand still accurate? (c) Are all the measures to provide for increased passenger demand likely to be implemented? 3.1 It should be noted that although the total passenger numbers for 2007—at some 241 million—are in line with the original DfT 2000 forecasts going into the White Paper, the geographical distribution in terms of average aircraft size and airspace routes taken has changed substantially particularly as a result of the rapid growth of low cost airlines. Substantial change had already occurred at the time the White Paper was produced in 2003 due to the growth in the low cost carriers and the impacts of 9/11. RAL is concerned these distribution changes were not accounted for in the White Paper, impacting the DfT conclusions drawn on where additional airport capacity is most needed, as well as the airspace management issues for NATS. RAL would urge the Government to revisit the Transport White Paper in the light of the Airport Master Plans produced in response to it. In particular the DfT should verify that the forecast distribution of passenger demand to 2030 will be adequately matched by realistic projections of capacity and airline requirements for runway development, particularly in relation to Gatwick, thus Redhill. 3.2 It is recognised that BAA is requesting additional runways at Stansted and Heathrow in line with the expectations of the White Paper, and that the fall-back position of a second runway at Gatwick remains if the Heathrow application fails. However, there is no guarantee that planning permission (either locally or via the newly established Infrastructure Planning Commission) will be given for any of these runways. 3.3. There is thus no guarantee that the measures to provide for increased passenger demand in South East England will be implemented, or that any new runways will be in the most suitable location. RAL strongly disagrees with the BAA view that all runways in the South East are fully substitutable for each other.

4. Response to Question 3

Question 3. (a) Is the current approach to planning and regulating the use of UK airspace adequate? (b) Would an Airspace Master Plan covering the period of the White Paper be beneficial? (c) Could a piecemeal approach to individual developments necessitate additional redesigns subsequently?

Part (a) 4.1 RAL is not convinced that the current approach is adequate. Planning by NATS seems to be completely re-active and not pro-active. When requests have been made to NATS to consider how a substantial increase in movements can be accommodated at Redhill, the response is always a knee-jerk reaction that nothing is possible. At the first such request in 1993, the response was that no more than six movements an hour could be accommodated without jeopardising the movement rate at Gatwick Airport. 15 years later, the answer is similar. 4.2 This is identical to the initial response given to the original owners of London City Airport, which could not be accommodated due to the impact it would have on Heathrow. NATS have since “learnt” that the airspace around London City can comfortably handle today’s 91,000 annual movements, now apparently constrained only by the physical characteristics of the airport’s runway and taxiway—not airspace considerations. 4.3 A similar negative response was given to the initial request for a direct helicopter service between Gatwick and Heathrow—‘it would have to be routed via Biggin Hill and join the long fixed-wing approach to Heathrow’. They had to be proved wrong over time. Similarly,the SERAS proposal for an airport at CliVe was damned by NATS before any detailed airspace planning had been undertaken. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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4.4 It was only the dogged persistence of the owners of London City and the operators of Airlink that overcame the innate conservatism of NATS. We at RAL are faced with the same intransigent views, and are opposing it with the same thoroughness, putting forward the more positive views of other airspace experts such as SERCO, (who wrote a positive report in 2003), and of airspace consultants. 4.5 As for regulation, it would appear that the CAA asks NATS for its views and appears to accept them without taking second opinions, or checking with best practice in Europe and elsewhere. RAL does not believe that this is good either for the airspace sector, or for UK aviation as a whole.

Part (b) 4.6 The White Paper specifically asked for Master Plans to be drawn up for all major airports, but did not simultaneously request an airspace Master Plan. Ideally, the UK would benefit from such a plan that was based on a firm knowledge of current and projected runway developments, that was robust and that could accommodate “unknown” developments, both in runway provision and of changes in aircraft types and mix. Runway capacity and airspace capacity are crucially linked. They must be planned together. 4.7 However, it is accepted that until airport development decisions have been made, a Master Plan would be almost impossible to produce for the South East of England. The impact of a second runway at Stansted and/or a third runway at Heathrow would be so substantial that a whole new airspace pattern over a significant part of the UK would be necessary. Once these runway decisions have been taken, it may be possible to draw up a Master Plan that not only accommodates these developments, but also allows for the possible introduction of additional runways at airports such as Luton and Redhill, as proposed at the time of the White Paper, although not favoured at that time. 4.8 RAL’s concern is that any Airspace Master Plan would eVectively “freeze” the development of runways as at the time of study, and that any future developments would become impossible. For example, the tentative airspace plans for accommodating a third runway at Heathrow push more traYc to the south of Heathrow than currently happens, which will circumscribe operations at Redhill even more tightly; but if Redhill had been approved, the Master Plan would have had to be drawn up with that knowledge, and changes made to accommodate all growth equally.

Part (c) 4.9 Regrettably,RAL believes that the current approach is probably more sensible: that ideas for airspace design can be mulled over while plans for new runways are discussed, but that detailed design is only worthwhile once a decision to build a new runway has been taken. Then, NATS can work with “facts” and construct a revised airspace plan to cope with predicted traYc flows. 4.10 In the consultation for Heathrow’s Third Runway, it is clearly stated that NATS has not yet made firm decisions on how the airspace will be re-designed, but that certain generalities could be drawn. For example, Northolt would have to be closed, runway approaches to Farnborough would be aVected, and certain flows from Heathrow’s existing runways would be diverted from the north side to the south side of the airport. Once any decision to go-ahead is taken, NATS will be able to firm up these ideas into detailed plans, based on the known runway provision in South East England at that time. 4.11 It is important to note however, that NATS have committed to making Heathrow Three work, even though the detailed studies have yet to be undertaken, unlike its earlier pronouncements on London City, CliVe and Redhill. If approval is eventually given for the expansion of Redhill’s runway and air transport movements, NATS will have to commence its studies from the then status quo, possibly including a second Stansted runway and a third Heathrow runway, but it would not need to take into consideration a possible second Gatwick runway.

5. Response to Question 6

Question 6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? 5.1 Consultants retained by RAL have been active participants in the current SESAR studies and are aware of the numerous technical developments being studied to improve airspace use throughout Europe, leading eventually to the gate-to-gate concept. These would minimise the use of stacks, lead to reduced fuel usage and oVer noise benefits to residents close to airports. 5.2 Although NATS were also participants, it is not clear whether their current airspace plans take fully into account the possibilities of radical change in airspace management, including the provision of their FACTS (Future Area Control Tool Support) system. These developments will increase capacity of current airspace and would almost certainly allow developments (such as a fully-used runway at Redhill) which previously were rejected, based on existing airspace management processes and ATM systems. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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6. Response to Question 7

Question 7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play? 6.1 RAL are concerned about the close relationship between NATS and one of its major shareholders, BAA. BAA holds 4% of the shareholding in NATS following an approach by the Government in 2003 to invest a further £65 million to staunch a reduction of NATS funds shortly after privatisation. 6.2 RAL believes that if BAA had wanted Redhill to be developed so as to improve its own financial return at Gatwick, then NATS would have been more positive about the possibility of Redhill being able to handle the necessary movements. The contrast of the “can do” for Stansted and Heathrow is in sharp contrast to the “can’t do” for London City, CliVe and Redhill. 6.3 RAL is also concerned about the very close relationship between the DfT, the CAA and NATS, and the apparent lack of any depth of management knowledge to challenge NATS opinions. The possible advent of EASA as an interested partner is viewed positively by RAL.

7. Response to Question 8

Question 8. (a) Do airspace management considerations delay the planning processes in relation to airport development proposals? (b) How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? 7.1 As can be seen from earlier answers, all that NATS is currently able to oVer at the planning stage for runway developments is a set of concepts and ideas about how airspace could be designed following the go- ahead for a new runway. It will be able to give indications of areas likely to be aVected by overflying, but these will not be firmed up until after a decision has been made. In that sense, yes, airspace considerations unnecessarily delay planning the process. 7.2 In the case of Redhill, a negative assessment (based on initial thoughts and not on detailed studies) was used by the DfT in its White Paper as the sole reason to refuse to consider the undoubted benefits that can still be oVered by a feeder-reliever runway at Redhill. If this view had not been given, the DfT would have no other reason to go along with BAA’s view that it did not want additional further competition from Redhill (White Paper, paragraphs 11.117—11.119). 7.3 Airport managements with the inside track to senior DfT oYcials appear to work (successfully) against valid proposals from other airports. 7.4 Redhill, although not considered five years ago, is as strong a runner, if not stronger today. RAL would welcome the opportunity to give additional verbal evidence to the Select Committee if requested. September 2008

Memorandum from Gatwick Area Conservation Campaign (AIR 05)

Summary — The White Paper forecasts are inaccurate due to the price of oil, the lack of tax, and the underestimate of climate change costs. — Flights over rural areas, and the concentration of flight paths on narrow tracks, cause disproportionate disturbance and annoyance. It should therefore not be assumed that rural areas provide unlimited space for new flight paths.

Introduction 1. GACC is the main environmental group concerned with Gatwick Airport. Founded in 1965, we have over forty years experience of trying to find rational solutions to the problems caused an major airport. Our members include over 100 councils and environmental groups covering an area about twenty miles radius around Gatwick. 2. We wish to comment on two items mentioned by the Select Committee as matters in which they are interested. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Forecasts

Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented? 3. We believe that the White Paper projections, and indeed also the Forecasts of UK Passenger Demand produced by the Department for Transport in December 2007, are seriously inaccurate for the following reasons. 4. The White Paper was based on a forecast cost of oil (or aviation fuel) of $25 per barrel. The DfT forecasts depend on the unlikely assumption that the price of oil falls to $53 per barrel. Although the cost of oil has fallen from its peak earlier this year, few experts would now predict that it would fall to $53, let alone £25. 5. The forecasts are also based on the unlikely assumption that during the next 25 years there is no increase in tax on air travel in order to raise revenue. 6. Also that any tax imposed for climate change reasons (or the cost of emissions trading permits) will be at an exceptionally low rate—based on the DEFRA social cost of carbon which in turn is based on the unlikely assumption that all other countries take drastic action to reduce their CO2 emissions, with no need for the UK to take a lead. 7. These points are spelt out in the booklet Fallible Forecasts written by the Aviation Economics Group.

Rural Areas

How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? 8. We have considerable experience on these issues, having been involved in matters relating to Gatwick flight paths for over 40 years. We welcome the fact that consultation is now required for new flight paths: many flight paths at Gatwick were established before consultation was required. 9. The consultation recently carried out by NATS for Terminal Control Area North, although it did not directly aVect the Gatwick area, appeared adequate in its coverage. 10. Most flight paths to and from Gatwick are over rural areas. Gatwick is surrounded on three sides by Areas of Outstanding Natural Beauty, and most aircraft approaching or departing fly over these areas. We consider that it would be incorrect to assume that there is a simple numerical relationship between the number of people aVected when flights are re-directed from over towns to over rural areas. Aircraft noise in rural areas tends to be more annoying for two reasons. First there is a lower background noise. Second there is a greater expectation of peace and quiet. 11. The expectation of peace and quiet in the countryside is the reason why many people chose to live there. This is documented in literature and in tens of thousands of house advertisements. Therefore there is greater annoyance when this peace is destroyed by aircraft noise. The annoyance becomes even greater when it is a result of a deliberate change in the use of air space. There is resentment because the previous tranquillity has been deliberately destroyed, and also because house values fall in the aVected areas, locking people into their properties so that they cannot move away without financial loss.

Narrower Flight Paths and New Routes 12. The concentration of aircraft on narrow routes is causing an increasing problem. The policy established in the early 1970’s was that there is an environmental benefit in confining aircraft to specific routes. In recent years, however, the improvements in aircraft navigation have narrowed the swathes and this will become even more apparent with the introduction of P-RNAV. This means that all the noise and annoyance is concentrated on comparatively few people. While many benefit, the unlucky few suVer misery. A great feeling of injustice is created. One of the basic human rights—to the peaceful enjoyment of one’s home—is infringed. 13. Where people buy a house, knowing that it is under a flight path, they normally pay a lower price, and accept the situation. But when a change in routes is imposed on innocent and unsuspecting people they find their house devalued, and cannot move without suVering loss. They therefore feel trapped by the aircraft, and the sense of resentment is magnified. 14. These points are confirmed by the high level of opposition to the new flight paths recently proposed by NATS for Terminal Control Area North. Over 15,000 responses were submitted with over 80% against the new proposals, with the main concern about the impact on rural areas and on tranquillity. 15. The balance between conflicting interests cannot be struck by counting heads: the magnitude of the benefit or dis-benefit needs to be assessed. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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16. Although, as explained above, we do not consider the doubling or trebling of air travel as envisaged in the Air Transport White Paper is likely to occur, if it did it would mean a vast increase in the number of flight paths over the UK, or a vast increase in the number of aircraft using existing flight paths. This would mean that the public opposition to aviation expansion would be on a far wider scale. September 2008

Memorandum from the Manchester Airports Group plc (AIR 06)

1. Introduction and Executive Summary

1.1 This is the submission of the Manchester Airports Group plc (MAG) to the Call for Written Evidence issued by the House of Commons Transport Committee in connection with its inquiry into the use of airspace.

1.2 MAG is the UK’s second largest airport operator and comprises the airports of Manchester, East Midlands, Humberside and Bournemouth. MAG handled over 29 million passengers in 2007–08, with Manchester alone accounting for over 22 million passengers travelling to over 220 destinations, more than any other UK airport.

1.3 MAG is publicly owned by the 10 local authorities of Greater Manchester. These shareholders require us to grow the business profitably, to enhance the value of the business; and to maximise the economic and social contribution to the regions it serves.

1.4 The main points of this submission are as follows: — The developments outlined in the 2003 White Paper require a substantial increase in airspace capacity for civil aviation. — There should be a national Airspace Master Plan. — The CAA’s Directorate of Airspace Policy should drive the production of such a plan, with others (NERL, airports, other industry stakeholders) providing a supportive role. — More military airspace should be released for civilian purposes. — Increases in airspace capacity or reorganisation, will deliver substantial climate change benefits, and are a “win-win” solution. — “Mid level airspace” flying should be discounted when considering environmental (specifically noise nuisance) factors. — The EU’s Single European Sky II package should be supported in principle. — New technology and procedures, and quicker planning approvals for airport projects will have a role in reducing delays. The process for airspace change and masterplanning needs to run at the same pace. — Commercial aviation’s requirements should take precedence over recreational and other flying, and should follow the SES policy proposals for prioritising airspace use. — The world-wide shortage of controllers will cause diYculties, though to an extent these may be alleviated by technology and the release of airspace. — Government should fund the production of the national airspace Master Plan.

1.5 The management of airspace, both in respect of en-route functions and for local air traYc control purposes, is heavily dependant on the use of radio spectrum frequencies for both voice communication, navigation and to ensure flight safety. MAG views with concern the proposed introduction by Ofcom of a charging mechanism (“Administered Incentive Pricing”) for the use of radio spectrum for aeronautical purposes from 2009 and will be registering its strong objections to Ofcom in our response to its recent consultation paper. We are particularly concerned with the way that Ofcom has handled the consultation process over this proposal which has resulted in airports apparently being omitted from the consultation process until very late in the day.

This proposal, when implemented, will result in significant cost increases for airports (circa £1.2 million for Manchester Airport alone) being imposed at relatively short notice. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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2. Responses to Questions

2.1 What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate. Are all measures to provide for increased passenger demand likely to be implemented? The 2003 White Paper projected increases in air travel of between two and three-fold in the years up to 2030. Subject to shorter term fluctuations to reflect economic cycles, MAG believes that these forecasts are still valid and will be reflected in the further development of the UK airports industry in order to meet that demand. The White Paper recognised the need for a structured programme for the redesign of UK airspace that would help protect safety standards, relieve current constraints, take account of environmental impacts and accommodate the forecast increase in air transport movements where additional capacity was supported in the White Paper. It is essential that the UK has such a structured airspace programme. The White Paper (paragraphs 12.26–12.27) places the responsibility for planning the necessary structured re-design of UK airspace and the introduction of enhanced technologies and systems, firmly in the hands of the Civil Aviation Authority (CAA). In doing this, the White Paper acknowledges that the CAA will need to involve other parties, including both NATS en-route (NERL) and airport operators in working up its proposals. MAG does not believe that this responsibility has yet been fulfilled by the CAA. The CAA’s current Directorate of Airspace Policy, where arguably the responsibility for such strategic planning lies, is currently constituted as a policy and regulatory body, relying on others, principally NERL and in limited cases, airports to put forward proposals. Although the CAA, NERL and the Department for Transport have set in place the Future Airspace Study to establish the parameters for strategic airspace planning until 2030, this initiative is still ‘work in progress’, the results of it are yet to be seen and MAG is not aware of the timescale for its completion. If the Future Airspace Study results in an eVective Master Plan for UK airspace, then this fact needs to be more widely publicised. MAG is unaware of any consultation initiatives either by the CAA or NERL about any “national master plan” for UK airspace. In the apparent vacuum created by the absence of a national master plan for airspace, such planning as is undertaken is done by NERL, and is necessarily done on a piecemeal basis, in response to shortages identified locally. Notably, NERL has a limited resource for this type of development and is not in a position to be able to accelerate such work. MAG does not believe that this approach will enable the necessary increases in airspace capacity to be achieved in the longer term. Airspace is one of the four key capacity drivers that govern the ability of the industry to meet the needs of its users. The others being runways; terminals and surface access. Plans and strategies to deliver the necessary uplift in capacity of these elements have already been prepared by airport operators through their Masterplans. Those plans could be frustrated by the failure to adopt a similar approach to airspace. Manchester Airport suVers to an extent from an outdated airspace structure designed to handle forecast traYc levels predicted in the 1980s.10 At peak times, airspace can be a constraint on airport capacity. There are conflicts between departure and arrival routes that require complex coordination between Manchester and Liverpool traYc as well as between aircraft flying through the area in the same controlled airspace. NERL’s current programme of capacity enhancement includes a restructuring of the Terminal Movement Area (TMA) for the North West, and should have a relieving eVect in the medium term. However, as indicated above, this is an Upper Airspace based piecemeal approach, and MAG would prefer the need for such an approach to be lessened by the production and maintenance of a national airspace masterplan.

2.2 Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for air traYc control? Safety in the skies can never be compromised, but MAG is of the view that within the current arrangements it will not be possible to substantially increase overall airspace capacity, without increasing the number and length of delays inherent in the “system”. Operationally, there is a good interface between civilian and military airspace utilisation, but at the strategic level, this interface is less beneficial. There is a strong perception of military precedence when conflicting demands for airspace occur, which appears to leave the civilian sector disadvantaged. This may be a result from legacy/historical factors. The release of military airspace to civilian use would enable more direct routings of flights and increase the amount of capacity available to commercial operators. Such changes would have both operational and environmental benefits. They are a “win-win” solution, which require no apparent sacrifices from air travel users.

10 See the Department for Transport Improving the Air Passenger Experience—an analysis of end to end journeys with a focus on Manchester Airport, published September 2008, pages 36 and 43. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Short term releases of military airspace for civilian use, for example that happens in certain areas at weekends, whilst operationally useful, oVer no long term certainty or increase in the overall planned capacity of the system.

2.3 Is the current approach to planning and regulating the use of airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional re-designs subsequently? MAG does not believe that the current approach to planning UK airspace is adequate. It is piecemeal and incremental, lacks a clear strategic direction and is bureaucratically cumbersome. It suVers from similar deficiencies as the current UK Planning system, and like that system has become increasingly complex and risk averse recently, with an increasing propensity for matters to be referred to Judicial Review. The type of Master Plan that MAG advocates should take as its starting point the presumption that the developments outlined in the 2003 White Paper, will be delivered. This national policy would then provide a strategic framework and set a presumption in favour of airspace changes that accorded with the plan (again paralleling the town and country planning system).

2.4 How are the eVects of aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? The overriding principle that applies (as it does at the present) is that no environmental degradation should take place as a result of such proposals, and in the worst case scenario a position of neutrality should be regarded as the minimum. Those aVected by such proposals should be adequately consulted, but an important factor to be considered is the height at which aircraft are considered to be capable of causing a noise nuisance. Traditionally this was regarded as aircraft flying in “lower level airspace” (ie up to 7,000 feet), but MAG notes with alarm the view in some quarters that aircraft flying in “mid level airspace” (seven to 17,000 feet) should also be considered a source of nuisance (and in spite of modern aircraft being much quieter than those of 10-20 years ago). MAG would oppose any such move. Many short haul routes, eg Manchester— Heathrow, would be caught in their entirety by such a change, either because such flights are kept artificially low because the space higher up is too congested, or because they are operated by turboprop aircraft or regional jets that do not fly above such levels. Taken to its logical conclusion, such a development could necessitate consulting the entire population aVected between the two airports. Striking the balance between conflicting interests is covered by Government policy and MAG takes the view that the existing arrangements should prevail. It greatly complicates and slows down the process if each airspace change has to argue from “first principles” in respect of the need for change or benefits thereof. An overall UK airspace Masterplan is therefore required.

2.5 How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? There is some international cooperation that has benefits in this area, in particular between the UK and the Netherlands and the UK and the Republic of Ireland. MAG supports the view that airspace should be managed on a wider basis than following national boundaries and supports, at a high level, the moves being taken by the EU to achieve further progress in this area through the recent Single European Sky II package. It needs to be recognised that heavy demands are made on UK airspace by the large volumes of overflying traYc destined for many parts of Europe from over the North Atlantic. This imposes constraints on UK users and increases the demands on the capability of the UK’s systems. This eVectively can and will lead to airspace being denied to UK-originating traYc and to delays being imposed on such traYc.

2.6 What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities be realised? Could environmental benefits be gained as a result of such improvements? Wasteful flying can be reduced by release of additional airspace from current military use, by new Air TraYc Control technologies and procedures, eg, Continuous Descent Approaches (CDA), by reorganising and planning airspace on a national or supra-national basis, and by speeding up the planning approval process for major airport projects so that airport capacity is not unduly restricted. MAG believes that there are significant environmental benefits to be gained from implementing all these proposals. The most significant benefits will be from more direct routing (estimated to reduce CO2 emissions by up to 10%) and Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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by improved flight profile and approach procedures (between 3.1 and 6.6% per cent benefit),11 which are proven procedures requiring no new technology or investment. But the expansion of their use is now constrained by having to operate within historic airspace boundaries and designs. Improved flight profile and approach procedures such as CDA also means less noise, less disturbance to residents and lower fuel burn.

2.7 In relation to the re-design of UK airspace, is the allocation of roles of each of the interested parties— Department for Transport, the CAA, airport operators, NATS, etc, appropriate and clearly understood? Are the structure of the parties appropriate for undertaking the roles that they should play? MAG does not think that the roles of the parties are clearly understood insofar as none of the parties has taken a strategic ‘lead’ responsibility for airspace planning and design, eVectively driving the whole process forward. MAG believes this to be primarily a CAA responsibility, and such a role is clearly implied by the 2003 White Paper, with NERL and DfT acting in a supportive capacity. MAG is of the opinion that this function should not be regarded as matter of equal joint responsibility; such a process would cause confusion and delay. There is no fundamental reason why such masterplanning and airspace regulation cannot be carried out by the same body, provided the appropriate safeguards are maintained to prevent conflicts of interest. As an airport operator, MAG does not believe that the current process for overall airspace capacity planning works well, for the reasons outlined in para 2.3 above. MAG has to react to the deficiencies of the current piecemeal airspace planning process, which is unsatisfactory, slow and lacks clarity. Currently only NERL has all the data on flight delays, and determines priorities for airspace change, yet the current system is less than clear about how some of these arise.

2.8 Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure planning Commission and the relevant National Policy Statements on airport planning? Airspace management considerations do not normally aVect planning processes for airport development proposals, although a recent exception was the case involving Coventry Airport. Deficiencies in airspace capacity will, in the longer term, have an eVect on whether airports are able to bring forward development proposals. If airspace is the weakest link in the capacity chain then this negates investment and improvements in the capacity of the other key elements. Delays in bringing forward such proposals will adversely aVect the contribution that airports can make towards stimulating regional development. MAG is not aware of how National Policy Statements will take into account airspace capacity issues, and would prefer to see a National Policy Statement on airspace that successfully addresses the matter, or its inclusion in the Aviation National Policy Statement.

2.9 What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe & eYcient increases in capacity at the UK’s major airports/How should an appropriate balance between conflicting priorities be determined? There are very few implications for these types of aviation activity because most rely on flying at very low altitudes where (VFR) procedures are the norm, and where interference with and use of controlled airspace is unlikely. Where there is a conflict, commercial aviation should take precedence. Recent history shows that the interests of the users of this type of aviation activity are arguably more than adequately catered for under current arrangements. Indeed MAG believes that other users are accommodated sometimes at the expense of commercial aviation. We note that these users are represented proportionately more than commercial aviation and airport interests at the forums sponsored by the CAA’s DAP.

2.10 Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? There is a world-wide shortage of air traYc controllers and this will impact on the future development of additional airspace capacity, unless technological changes, structural changes and release of defence- controlled airspace can enable better utilisation of existing staYng resources. Whether such changes fully compensate for growth in demand for airspace, and result in a reduced demand for controllers, is doubtful. Arguably, better airspace design is more eYcient and needs less controllers. Automation in aircraft could lead to less reliance on traditional ATC methods.

11 See EU communication COM(2008) 389 final. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Failure to address airspace capacity shortage will, paradoxically, cause an increase in the short term demands for both air traYc controllers—in order to control complex and congested airspace, and will also lead to a requirement to build additional apron and taxiway capacity at airports—to enable aircraft to be held on the ground for longer periods whilst waiting for slots to become available for the en-route sector of any air route.

2.11 Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? MAG considers that the responsibility for funding airspace planning falls squarely on the shoulder of Government. It is up to Government to ensure that the necessary structural planning of UK airspace is granted suYcient funding so that the overall long term interests of UK plc are not disadvantaged. MAG does not consider that the funding of such planning should fall on current users either via airports or via NERL. Such a source of funding would encourage a continuation of the current short term localised approach. The airports are responsible for delivering the other 3 main aspects of capacity; airspace is a truly national resource. October 2008

Memorandum from Shropshire County Council (AIR 07)

Summary — Shropshire County Council (SCC) has an interest in the impact of increasing Civil Air TraYc over Shropshire with regard to its eVect on tranquillity in a rural county and consequences for carbon emissions and climate change targets. — The Civil Aviation Authority (CAA) implemented West End Area Airspace changes in March 2006, the result in Shropshire being a 21% overall increase in air traYc over-flight of the Shropshire Hills Area of Outstanding Natural Beauty(AONB). — Some residents perceive a significant loss of tranquillity in a rural county and have made complaints accordingly. — Shropshire County Council ask Government to commission research and detailed studies on measuring tranquillity and mitigating impacts of aircraft noise on tranquillity, and also to seek the production and evaluation of noise criteria with regard to air traYc.

Background 1. Civil Air TraYc over the County of Shropshire has been considered by Shropshire County Council, with regard to increasing frequency and noise intrusion, most recently at its Cabinet meeting on 24 September 2008, and prior to that at the Economy and Environment Scrutiny Panel meeting on 11 September 2008. 2. The background to our interest in this topic came about in March 2006, when the (CAA) and National Air TraYc Services (NATS) implemented the West End Airspace changes. The principle aims of the changes were to improve air safety and eYciency in the face of increasing demand for commercial air travel, and also address the needs of the Ministry of Defence (MoD). In June 2008 the CAA issued the West End Airspace Change Review report on the impacts of the changes. 3. This response to the Transport Select Committee Inquiry into the use of airspace relates primarily to the issue of how the eVects and aircraft noise and emissions are taken into account when changes are made to the use of airspace and how the balance between conflicting interests should be struck.

Impacts of Recent Airspace Changes over Shropshire 4. The CAA report (West End Airspace Change Review; 30 June 2008) confirms that the redesign and revised arrangements to the airspace, both above and below flight level FL245 (24,500ft) were based on a need to reduce delays to commercial aircraft and deliver a substantial increase in Air TraYc Services (ATS) route capacity of 30%. From the MOD perspective suitable airspace sharing arrangements were established to ensure existing and future operational capability. 5. The report details areas of contention to the changes, relating to the environment, and makes reference to the concerns of SCC and the Shropshire Hills AONB. It concluded that it considered it impracticable to avoid over-flight of aVected AONB’s in the proposal due to the complexity of achieving this in practice. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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6. The volume of air traYc over-flying the county is increasing year on year. On analysis, the impact of the change on the Shropshire Hills AONB is that a slightly larger area is over-flown than before and the base of controlled airspace overlying the eastern side is lower. The overall increase in flights is 21% (an additional 47 flights per day). The County Council is seeking an explanation from the CAA as to why the increase was so much greater in Shropshire than for other sensitive areas, and the UK as a whole. 7. Some residents who live below the flight paths find the level of increase to be very intrusive in a designated area. The increase in civil aviation, together with the busy routine activity of the MOD has generated some strong comment from individuals concerned. We also have received numerous complaints. However it is apparent that individuals’ perceptions of the extent of the problem vary. The Council aYrms its support for the work of the armed forces in Shropshire and would not wish to impinge on military activities but, nevertheless, hopes that the forces will be sensitive wherever possible to the impact of operations on the community. 8. Shropshire welcomes the fact that, when compared to other similar sectors, analysis of safety records, show that the West End sectors have seen a reduction in the number of incident reports, as a result of the changes to airspace introduced in March 2006.

Environmental Considerations 9. We understand that there is a paucity of available research and models for the appropriate consideration of the issues around tranquillity and noise intrusion from aircraft, as it aVects communities on the ground. 10. We understand that the CAA had commenced dialogue with Campaign for the Protection of Rural England (CPRE) to gain an understanding of better measurement of tranquillity with regard to air traYc noise. This was promised back in 2006, but to date no progress has been reported. There remains a need for government to commission detailed studies on measuring tranquillity, methods of mitigating the impacts of aircraft noise and also the production and evaluation of noise criteria with regard to air traYc. 11. While it is clear and appropriate that a wide range of environmental bodies are routinely consulted about airspace change proposals, together with public and private bodies beneath the flight paths, it remains extremely diYcult to achieve consideration of, or mitigations for, loss of tranquillity. Economic and aviation factors are considered of greater significance. Better informed guidance and objective measurement of impacts on tranquillity is needed to help strike the balance between conflicting interests. The County Council is further concerned about the wider implications of increasing Air TraYc on national climate change targets.

Conclusions Shropshire County Council welcomes the Transport Select Committee inquiry into the use of airspace. The County Council believes that the lack of research into the issue of air traYc noise and tranquillity is an obstacle to meaningful consultation and evaluation of impacts, and request that government take steps to commission appropriate studies and develop methodologies in this area. The County Council understands the strong views about how changes to airspace over Shropshire aVects our residents, together with the complexity of striking a balance between MOD needs, local communities, the increasing demand for air travel and the economy and the environment. October 2008

Memorandum from the Ministry of Defence (AIR 08)

Overview 1. The Transport Select Committee’s Inquiry into the use of Airspace concentrates on exploring ways of meeting the rising demands of commercial aviation, however, it is essential that that any future demands of commercial aviation are balanced against the overriding need to maintain and develop the UK’s Military Capability, in particular National Security. The singular most important element underpinning the MoD’s strategic aspirations and requirements detailed below is access to airspace that will enable all arms of the MoD to “train as they would fight” in order to counter immediate threats to the UK and to be fully prepared to meet any future challenges. Accordingly, the MoD’s responses to the specific questions posed by the Inquiry should, at all times, be framed by the strategic context outlined below. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Future Air and Space Operational Concept 2. The UK’s air and space power capability out to 2020 is described in the Future Air and Space Operational Concept (FASOC). An Agile Air Force is the core of the capability encompassing Air Power elements from all 3 Services integrated to deliver future air and space power. Agile air power is fundamental to the UK’s future Military Capability. 3. The FASOC describes the development of the UK’s air and space contribution to Joint and Coalition operations. High-level policy direction derives from the Strategic Defence Review and the New Chapter, Defence Strategic Guidance 2003 and the Defence White Papers 03 and 04. It is further guided by the UK Joint Vision, the Joint High Level Operational Concept and the UK Military EVects-Based Operations Concept, and informed by other emerging concepts. It is consistent with, and links to, the Future Maritime Operational Concept the Future Land Operational Concept and developing Future Logistics Operational Concept. 4. Defence planning acknowledges the increased likelihood of deploying forces beyond the core regions to deliver a small-scale military response across the globe to counter asymmetric threats. Moreover, as a more closely defined force for good, our humanitarian eVorts are likely to be in demand world-wide.

The Defence Aim 5. The UK’s air and space capability contributes to the Defence Aim: To deliver security for the people of the United Kingdom and Overseas Territories by defending them, including against terrorism, and to act as a force for good by strengthening international peace and security. 6. The UK achieves the Defence Aim by being able to meet 18 Military Tasks which are grouped under the headings of Standing Strategic Tasks, Standing Home Commitments, Standing Overseas Commitments and Contingency Operations Overseas. Air power underpins the delivery of Joint capability across the majority of Military Tasks. Air Power’s unique attribute is that it oVers operational choice without, necessarily, any commitment to action or to deploy troops on the ground.

Agile Air Power

7. To meet the demands of the strategic environment, the UK’s air power capability must be strategically, operationally and tactically agile. To deliver agility aVordably, the structures, processes and equipment must be utilised across the widest range of roles and suYcient personnel must be trained to support and exploit the breadth of air power’s capability. 8. Defence Planning Assumptions identify the type and scale of operations that must be met concurrently in addition to the Standing Home Commitments and Standing Strategic Tasks which must continue to be met. Current guidance is that an adaptive force structure must be developed that can routinely and rapidly meet the most likely and frequent scenarios while retaining the ability to generate appropriate forces for the most demanding and deliberate, but less likely and less frequent, operations. In the FASOC timeframe, structures, processes and equipment must also be designed to be suYciently flexible so as to be able to respond as threats, technology and alliances evolve. The greatest risk to UK security is that the strategic environment will change faster than the UK can or will acquire and apply resources to meet that threat. An inability to access airspace where and when it is needed would significantly undermine military preparedness.

National Security

9. Air Power’s principal Standing Home Commitments Military Task is the protection of UK sovereignty and security at home. The UK Airspace Security task objective is: To provide a continuous recognised air picture and an air policing capability, providing for the interception and possible destruction of rogue and hostile aircraft, to maintain the integrity of the UK’s airspace. 10. The task is co-ordinated by the Home OYce and involves critical military support to, and close co- ordination between, Other Government Departments (OGDs) and both military and civilian airspace control agencies, including those of neighbouring nations. The speed with which a threat to the UK’s airspace security can emerge drives the need to develop highly responsive, well co-ordinated Command and Control structures, processes and people capable of an integrated, time-critical and appropriate response. A responsive, flexible, potentially lethal counter-air capability cued by persistent surveillance of the air, and realised through a networked capability across the military/civilian interface, is vital to ensure protection, especially from an asymmetric threat, and, importantly, to provide eVective deterrence. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Military Airspace Utilisation 11. Any future airspace structure should be developed in line with European Airspace strategies. These strategies acknowledge the general defence and security needs and aim at dedicating suYcient airspace for military purposes. The core principles for military use of European airspace include: — Freedom to operate at any time in all areas. — Special handling in particular for priority flights and for time-critical missions, but also for military aircraft whose equipment is not fully up to civil standards. — Possibility of conducting uncontrolled VFR flights, including in managed airspace. — Temporary airspace reservations for UAVs, in-flight refuelling, air combat training, high-energy flying and other activities incompatible with the normal application of the rules of the air as close as practicable to the respective airfield. — Airspace restrictions for activities not related to aviation, like the protection of areas of national interest, air-to-ground firing ranges, air-to-air gunfire and missile firing areas etc. 12. The military need for airspace is determined on day-to-day basis by a number of factors such as available equipment, available personnel and meteorological conditions. SuYcient airspace must therefore be available when conditions are favourable. The location of the airspace is also of vital importance, not only with regard to cost eVectiveness but also the time needed for the transit to remote areas. If too much time is used for the transit, the time available for training will be inadequate, resulting in mission ineVectiveness, which in turn requires that mission to be re-flown. 13. The MoD does however seek to distribute its aviation training activity as widely as possible across the entire land and sea area of the UK in an attempt to minimise the environmental and noise impact that this has on the wider community. On occasion, flying activity is restricted geographically by the requirement to use military ground facilities or the necessary interaction with ground troops or maritime platforms within static training areas; furthermore, military aircraft necessarily avoid major centres of population, designated industrial sites and conservation areas as well as avoiding major civil air routes and areas. 14. The adaptable and flexible capability to conduct diVering operational tasks is achievable only because of the specialist training and experience gained through the conduct of training activity within UK airspace and over the adjacent seas. Current limitations in the fidelity of simulation and an inability to fully rehearse the complex missions and interactions required between multiple aircraft, ground forces or other government agencies continues to demand and justify the vital requirement for autonomous and semi- autonomous, non-synthetic training across the full airspace block. This essential activity necessitates flying from low-level to high altitude, manoeuvring the aircraft using its full flight envelope in order to achieve the requisite variety of skills to enable UK military aircrew to conduct the broad spectrum of operations, throughout the world, as directed by the Government.

Summary 15. The FASOC describes how the UK seeks to develop both the core attributes of air power in order to conduct actions to achieve, or contribute to, desired decisive campaign eVects. At home, air and space capabilities, working closely with OGDs will maintain national security by securing UK airspace and countering novel asymmetric and conventional threats. Further afield, developing crises and the need to neutralise emerging terrorist and WMD threats around the globe will require rapid intervention by Very High Readiness forces, notably air power elements. Air power oVers speed, deployability, reach and sustainability. Consequently, streamlined Joint training in relation to the new operational environment will be fundamental, not only in maximising the utility and impact of air power, but also in making the best of Defence assets. To reiterate, in order to achieve these strategic goals the MoD needs access, now and in the future, to significant volumes of appropriately sized and sited airspace in the UK.

Response to Questions

1. What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented? (a) The White Paper calls for development of regional airports; this could place an unacceptable burden on the airspace management system. Most commercial air transport is reluctant to operate outside controlled airspace and so this brings an increasing requirement for the establishment of zones of controlled airspace around the airports and significant volumes of controlled airspace to connect the regional airports to the main airways system. This reservation of airspace for a comparatively small number of air transport flights excludes other airspace users and could severely restrict the MoD’s ability to operate. The MoD contends that segregation of this activity is but one method of managing the integration and deconfliction of the contrasting requirements Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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of airspace users. The MoD is fully engaged in the Airspace Safety Initiative in which the introduction of new Air TraYc Services Outside Controlled Airspace and other initiatives are specifically aimed at further assuring the safety of commercial air transport operations outside controlled airspace. The last resort should be the establishment of controlled airspace. (b) Although the MoD does not have suYcient knowledge to comment authoritatively on the veracity of the White Paper’s projections we would expect that the current economic diYculties could slow the growth in passenger numbers; however, we would expect that it will inevitably pick up again. (c) Similarly, having observed the significant diYculties encountered by recent and current large-scale airspace changes during the consultation and post-implementation phases, it is highly likely that airport and airspace development will be severely constrained or delayed.

2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for air traYc control? (a) Inside controlled airspace the safety of any long-term or projected increase in the utilisation of a specific area of airspace is determined by the stringently tested procedures and safety management systems in place. On a day-to day basis the capacity should be determined by a combination of procedures, agreements and ultimately flow control; accordingly, safety should be assured. (b) Outside controlled airspace (Class G), the number, type and nature of aviation activity is more diYcult to predict. It is predominantly a “see-and-avoid” environment although widespread and significant assistance is available from a range of Air TraYc Services. This is the environment within which the MoD conducts the overwhelming majority of its activity. Activity ranges from large scale pan-Defence multinational exercises at all levels to the most basic of flying training. Class G airspace oVers unprecedented and essential tactical freedom and flexibility. (c) An airspace strategy driven by the needs of commercial air transport will inevitably lead to the imposition of controlled airspace and the consequent loss of Class G airspace. This has the clear eVect of excluding non-commercial users from controlled airspace and thus constraining the MoD’s ability to train and operate. Of equal concern is that the reduced volume of Class G airspace must still accommodate the existing and potentially increasing number of non- commercial users. Whilst the MoD is making stringent eVorts to ensure safety through the fitment of technological safety nets such as collision warning systems, we have a growing concern that Class G airspace is being “squeezed” with the potential for the collision risk to be increased. (d) The MoD always endeavours to provide a balanced response to airspace change proposals that impinge on its operations in Class G airspace. UK airspace is a very finite resource and although an airspace change associated with a regional airport may seem reasonably benign in isolation, the MoD is becoming increasingly aware of the potential for a cumulative detrimental eVect on its operational eVectiveness. Accordingly, it is becoming increasingly diYcult for the MoD to reach acceptable compromises with regional developers. (e) The current UK interface arrangements, not just for air traYc control but for Airspace Policy in the round, between civil and military aviation authorities are excellent; arguably they are without precedent and set a global benchmark. The secondment of MoD staV to the CAA is intended to ensure, on a day-to-day basis, that DAP is able to call upon military advice and MoD views in formulating national airspace policy. The following supporting, institutional and operational arrangements are also designed to ensure proper representation of MoD interests: (f) Supporting Arrangements. A number of documents underpin the inter-relationship between MoD, the Licence holder (NATS), other ATS service providers and the CAA. — Directions to the CAA. The Directions given by the Secretary of State for Transport and the Secretary of State for Defence set out the CAA’s air navigation functions. The Directions given under section 66(1) of the Transport Act 2000 Act (the Act) constitute the formal statement of the responsibilities of the DAP,in particular with regard to the promotion of safe, eVective and eYcient co-ordination of air traYc services through the JANSC; consultation arrangements (in particular with the Secretary of State for Defence); and environmental obligations. — CAA/MoD Memorandum of Understanding (MoU). The MoU details the basis on which the MoD provides air traYc management (ATM) services to non-military airspace users on behalf of the CAA, the Licence holder, or otherwise in support of the joint and integrated arrangements. — NATS/MoD Contract. Under this Arrangement certain ATM related services are provided by NATS to MoD on a commercial basis. The terms of the Contract also require NATS to reimburse the MoD for performing some services that would otherwise be their responsibility as the ATC Licence holder. — NATS/MoD Operating Protocol. The holder of the ATS Licence is required to draw up, in consultation with the MoD, an Operating Protocol setting out the co-operative arrangements through which a joint and integrated approach to the provision of ATM services will be developed, implemented and sustained. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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(g) Institutional arrangements include: — CAA Board. The CAA exercises control of its constituent regulatory Groups through the CAA Board. The Director of Airspace Policy is an executive Member of the CAA. The Assistant Chief of the Air StaV (ACAS) is a non-executive Member of the CAA and is the nominated Member for national security for the purposes of Section 67 of the Act. — Appointment of the Director of Airspace Policy. The Director of Airspace Policy is a Member of the CAA appointed by the Secretary of State for Transport. The nomination for the purposes of Section 66 of the Act to perform on the CAA’s behalf its specified air navigation functions is subject to the approval of the Secretary of State for Defence. — Airspace Policy Committee. Policy oversight of the DAP is exercised through the CAA’s Airspace Policy Committee which is a Committee of the CAA Board. The Director of the Air StaV provides the MoD representation. — Joint Air Navigation Services Council (JANSC). The constitution and functions of the JANSC are detailed in an Appendix to the CAA Directions. The purpose of the JANSC is to oversee arrangements for the joint and integrated provision of air traYc services. The Director of Airspace Policy is required to convene and chair meetings at least six-monthly with representation from the MoD and the Licence holder; Air OYcer Battlespace Management is the MoD JANSC member. — Classification of Airspace. In relation to airspace issues, the Directions require the CAA to seek MoD approval before implementing any expansion or change in the classification of airspace that might have an adverse eVect on operational capability. — Airspace and Safety Initiative (ASI). The ASI is a joint CAA, MoD, NATS, AOA, GA eVort to investigate and tackle the major safety issues in UK airspace. (h) Operational Arrangements. The CAA/MoD MoU documents the areas of operational interface between the MoD and CAA. There are also a large number of airspace policy and aviation spectrum matters where dialogue between the MoD and the CAA will be required before implementation is possible. This is facilitated through the secondment of MoD personnel to the DAP and participation in the many collaborative and consultative fora involving the CAA, MoD and other representatives of the aviation industry. (i) The MoD provides expert participation at key UK and European airspace and air traYc management policy fora. Furthermore, the NATS/MoD led Joint Future Airspace Design Team has enabled MoD consultation and involvement from the outset in NATS’ recent large-scale airspace design and management projects.

3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Would a piecemeal approach to individual developments necessitate additional redesigns subsequently? (a) The current approach to airspace planning and regulation is adequate. However, outwith the large- scale airspace changes initiated by NATS, other smaller (piecemeal) airspace changes or initiatives are based on specific and unrelated business cases. Whilst, in isolation these may solve a particular region-specific problem inevitably there are knock-on consequences downstream and in adjacent airspace. Through its involvement in the Airspace Change Process the MoD seeks to provide an impact assessment based on a broad national airspace perspective taking into account the potential knock-on eVects that a change may have in another part of the country.However, this assessment is still reactive and competed without full knowledge of what other regional changes may be pending. Clearly,a strategic plan for the development and utilisation of UK Airspace is required that reflects and balances the needs of all users framed by any strategic Government-set priorities. (b) The MoD has contributed to the Future Airspace Study which we understood was intended to examine airspace planning issues from a more strategic standpoint. However, it’s focus appears to changed little from its original remit as the South East Airspace Study which concentrated on facilitating the growth of commercial air transport in the South and South East of England. The recently formed UK/Ireland Functional Airspace Block Airspace Design Working Group may aVord an opportunity to examine airspace usage more strategically. (c) The MoD would welcome and assist in the formulation of a DfT-led Airspace Master Plan. Such a Plan should, first of all, determine the pan-Government priorities for airspace use and then reflect and balance the requirements of all airspace users not just commercial air transport. As set out in the introduction the MoD is very clear on its strategic direction and the critical role that access to appropriately sized and sited airspace plays in our ability to deliver the Defence Aim. It is essential that the any Airspace Master Plan incorporates, from the outset, the MoD’s current and future airspace requirements. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? (a) The Airspace Change Process Guidance Document (CAP 725) provides comprehensive and definitive guidance on the consultation process, including environmental factors. (b) Through the Airspace Change Process the MoD is able to review proposed airspace changes of all shapes and sizes and provide response and comment that can influence and inform the final decision. The MoD is content that historically this process has proved to be reasonably fair and equitable. However, the MoD is growing increasingly uneasy that a political imperative to accommodate commercial air transport may sway the balance away from Defence needs; indeed the focus of this Inquiry is a prime example. (c) As a last resort Section 67 of the Transport Act 2000 enables the national security nominee on the CAA Board (ACAS) to have an issue referred to the Secretary of State for Transport if there is concern that a decision could have an eVect contrary to the interests of national security.

5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? (a) The management of airspace in each individual European State can aVect flights throughout the continent. Conditional Routes (CDRs) are a good example where a leg through one state may be open, however it is closed downstream owing to a diVerent state having activity in a Danger Area. Pan-European airspace management, possibly in the form of a Functional Airspace Block should address this to some degree. All CDRs require alternate routes, therefore a flight will make its destination, however it may well not be along the most economic path; flights into the UK are aVected in the same way.The primary issue is how the flights are presented. If they are bottlenecked through a choke point owing to another State’s airspace management, then potentially there can be sector overloads, delays and restrictions. This also places additional pressure on the UK structure to find alternate means to ease the pressure. This could be requiring Areas reserved for military use not to be booked for certain periods. This is covered in the concept of Flexible Use of Airspace; however, the situation can be forced upon the UK from other States’ actions. (b) New systems are being developed for a more European view of airspace management. The UK, including significant MoD representation, is integrally involved in a forthcoming trial which seeks to improve airspace management and ATC flow management. The trial will incorporate a newly established Military Liaison OYcer (MILO). The MILO will sit within the Central Flow Management Unit to oVer advice on Pan-European military activity. Eurocontrol are developing numerous other initiatives which are designed to facilitate integrated European airspace management. In addition the development of a single European Aeronautical Information database and an updated Airspace Usage Plan should improve European airspace management. All of these developments are supplementary to current practices with our neighbouring states, such as the daily process with the French Airspace Management Cell and the UK/Ireland Functional Airspace Block.

6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? (a) This is not an area where the MoD can oVer significant authoritative comment. However, we are aware that direct routing throughout UK airspace for overflights is a design concept ongoing at present. Despite obvious benefits to the Airline Operators the overall impact needs to be carefully and thoroughly assessed. Direct routing across the Atlantic to mainland Europe would undoubtedly pass directly through the North Sea Managed Danger Areas. National policy and strategy would need to be reviewed for priorities and protocols, and it is imperative that the MoD is engaged from the outset in the design process.

7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties-Department for Transport, the CAA, airport operators, NATS, etc-appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play? (Firstly, it is of concern that the MoD is not listed above as a key interested party.) (a) The roles, responsibilities for Airspace and Air Navigation spring from the Transport Act 2000 and are further described in the CAA’s Air Navigation Directions. The Airspace Charter (CAP 724) and Airspace Change Process (CAP 725) provide another level of detail again. The roles and responsibilities and processes to be followed by organisations involved in airspace design are Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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comprehensive and clear. The MoD seconds a significant number of experienced personnel to the CAA to ensure that on a day-to-day basis DAP is able to call upon military advice and MoD views in formulating national airspace policy.

8. Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? (a) Under the Airspace Change Process airspace management considerations are an integral and essential part of any airport development proposal and therefore the time taken to satisfy that requirement cannot be considered as a ‘delay’. The MoD is not familiar with the requirements of the Infrastructure Planning Commission however, we would expect the Airspace Change Process to be followed.

9. What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined? (a) The MoD would be interested to learn which airports in the UK the Transport Select Committee would classify as “Major”. The MoD considers any airport that would currently meet a major classification already has its operation fully safeguarded by the provision of significant volumes of controlled airspace including the London and Scottish TMAs and the associated Airway and Upper Air Route structure. (b) Any aspiration to initiate and develop a greenfield “major” regional airport operation away from the existing controlled airspace structure and to provide safety and eYciency by the establishment of exclusive controlled airspace will have significant and almost certainly unacceptable consequences for existing airspace users in that region. Controlled airspace should only be established when it is absolutely essential taking into account the minimum volume of airspace necessary and proposed times of operation. (c) On the principle of “Polluter Pays” it is for sponsor of the changes to put into place measures that mitigate any consequences of their changes. If controlled airspace is established there should be a greater requirement for the change sponsors to demonstrate that they are able to facilitate access by other users. Accordingly, as part of the approval the CAA needs to ensure that airports provide fully resourced ATC arrangements so that only operational/safety constraints limit other users’ access to the airspace and not “controller capacity” or equipment limitations. (d) Furthermore, when deciding to grant an airport controlled airspace the CAA should consider the previously described “squeeze” eVect that it will have on other Class G users and require airspace change sponsors to specifically address this through the provision of an ATS for ac in the vicinity of their operation. In line with Flexible Use principles, where necessary the times of activation of controlled airspace should be limited to peak flow times to strike a balance between the various users’ requirements. (e) The initial balance of conflicting priorities should first and foremost be in line with nationally agreed strategic priorities ie Government aspirations to develop a region economically and a key enabler being the development of an air link set against national security interests. Once that is agreed, tactical and specific case-by-case conflicts can be resolved by collaboration and arbitration but set within the strategic guidelines.

10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? (a) Increases in airport capacity must be made with appropriate resources, especially qualified personnel. A programme of airport expansion without adequate resources will not enable the expected increased capacity to be realised without jeopardising safety. Moreover there could be an expectation (misplaced) that any gap in capacity causing safety concerns such as a lack of radar capability would be met by the MoD.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? (a) There are parallels with other elements of national transport infrastructure eg roads and rail. For the national aviation infrastructure such as en-route airspace, revenue raised from navigation charges should be used to fund work in support of maintaining and developing that network. Similarly, any organisation profiting directly from that network should be appropriately “taxed”. For regional airports, the airport/operators should fund the work. The scale, complexity and risks Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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of the project together with ongoing costs of providing suYcient ATC staV would then ensure that the decision to proceed would only be taken if there was a high level of confidence that the anticipated traYc increases would happen. October 2008

Memorandum from Chiltern Countryside Group (AIR 09) The Chiltern Countryside Group represents people who live, work and enjoy leisure pursuits throughout the Chilterns. The Steering Group comprises aviation and transport consultants, commercial pilots and professionals in technology, media, healthcare & education.

Summary of Evidence — Current economic conditions render the projections of the 2003 White Paper inaccurate and unlikely to be fulfilled. The time should be used to address current constraints such as Holds, which impact on highly congested airspace in the SE. — Safety will be compromised if more aircraft movements are allowed in already over-crowded airspace such as TCN in the SE. — Current approach to planning use of UK airspace is piecemeal and thus will require redesigns at regular intervals. A wider picture with a “can do” approach would be more economical & potentially more environmentally beneficial in the longer term. — NATS does not have clear understanding of Government guidelines, particular with regard to overflights of AONB and population. — Review should be made of all airports with 24 hour operating licences and serious consideration given to the adverse eVect these have on the population overflown. — Funding should be made available to commission the development of noise measuring metrics that correctly take into account background noise, so that relevant, accurate data can be supplied to the public and other interested bodies. — Consultations should be carried out with wider access of information to the general public, MPs, Councils, Conservation and residents groups. NATS should be prepared and informed appropriately so that questions from the public & organisations can be answered fully before the closing date of consultation. The public should be given an amount of time in which to respond, relative to the length of time taken for preparation of the consultation. — Greater consultation should be undertaken with interested bodies, whilst the consultative document is being prepared. Commissioned agents need to be transparent, accessible and open to public scrutiny. — Review of procedures for short haul flights, holding procedures and their location, the use by ATC of Continuous Descent Approaches & the impact of PR-NAV on residents beneath these routes should be undertaken. — Clear definition of the roles and responsibilities of interested parties, eg CAA, NATS, DfT should be given. The general public do not have confidence that NATS can act as an unbiased commissioned agent for Consultation & as the operator of any changes. An independent body, not the CAA, should make the final decision on any changes. — Right of appeal should be more accessible without a costly Judicial Review; the appointment of an Ombudsman would fulfil an important role in any necessary arbitration. — Any redesigns of airspace must be managed safely but also minimize environmental impact, through ongoing dialogue during the design change process. — If further airport development has to happen, this would be more eVective at regional airports outside the congested SE. — As additional airport capacity is currently not required, a wiser & more appropriate decision would be to review changes which could reduce & simplify the workload of ATC, without increasing pollution to residents and the environment. — Funding should be provided by those who will benefit from the changes, ie the airlines and airport operators. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Development of Points Covered Above 1. Due to the current global economic situation and particularly, the price of oil and turbulent financial markets, the projections of the 2003 White Paper are not accurate and will not be fulfilled. Therefore measures which had previously been considered necessary to provide for these are no longer required. Time should be used to address current issues, not future ones, eg present specific constraints in TCN area of airspace, such as the location of the Heathrow holding beacons. (ref: section 0.5, 0.8, 2.10 CCG Technical Report 1; sections 2, 4 CCG Technical Report 2.) 2. Safety will be compromised if more aircraft movements are allowed in already congested areas such as the TCN airspace. Safety will also be compromised if airports in densely populated areas such as Heathrow are expanded with additional flights and runways. As aircraft are most proximate to each other during take oV and approach to landing, developing airports in conurbations increases risk to resident populations & places greater stress upon ATC and pilots. (ref: section 2.1 CCG People’s Response doc; section 1 CCG Technical Report 2.) 2.1 CAP772 identifies a 13km Safeguard around designated airports in which these airports can influence planning and land use to minimise birdstrikes. The aviation industry has a responsibility to minimise birdstrikes. Therefore the design of long distance flight paths at 3,000 feet above ground level outside the 13km Safeguard erodes this safety measure, as aircraft would be flying only a few hundred feet above what is currently acceptable within the Safeguard. 3. The current approach to planning use of UK airspace seems to set limits on what is possible—there appears to be no “can do” ethos or even, “let’s see what can be done”. The lack of a holistic approach inevitably requires continuous redesigns. Serious consideration should be given to a wider picture approach where historical operational constraints which impact on several areas, such as holding procedures, can be reviewed for greater benefit. The concept of “winning a battle but not the war” seems relevant to the current approach. An Airspace Master Plan with appropriate consultation at all levels, including environmental bodies at the initial stage, could be beneficial. (ref: section 0.5, 2.8, 2.9, 4.4 CCG TR 1; section 2 CCG TR 2.) 4.1 We can only speak for the TCN Consultation on this subject. The consequential eVects of aircraft pollution (visual, aural and air quality) upon valued landscapes, rural market towns and settlements was not priority. NATS does not appear to display a clear and consistent understanding of how to interpret current Government guidelines as given in CAA Publication 725—Guidance on the Airspace Change Process, the Countryside and Rights of Way Act 2000, Department of Transport: Guidance to the CAA on Environmental Objectives Relating to the Exercise of its Air Navigation Functions 2002, nor EU Directive 2002/30. (ref: sections 2,3,4 CCG People’s Response doc.) 4.2 No consideration was given to the potentially extremely detrimental eVect on mental and physical health of night operations from UK airports with 24 hour operating licences. Such operations are only necessary in emergency; embargo, or strict limits, should be imposed on flights during the EC recognised night time hours of 23.00-6.00am. The adverse eVect on residents’ health will place additional burdens upon Health Care and Social Services, at taxpayers’ expense. Benefits, if any, will be limited to airlines. No consideration was given to the possibility of increased air traYc. (ref: sections 2.8, 3.4 CCG People’s Response doc.) 4.3 Worst case scenario figures on height levels were given in a form, meaningless to residents living under current and projected flightpaths, as this gives permission for worst case low level flights & reduces the rights of the resident when disturbed by noise. Figures and facts should be accurately and consistently presented, eg height levels should be measured from the same start point throughout the Consultation document. Measurement should be made of background noise, as it is scientifically recognised that the same volume of noise introduced into a tranquil, silent environment will be far more intrusive, than against a background which is already noisy. Recent studies have shown that people today have lower tolerance levels of noise that in the past, which reflects the increasingly noisy society in which we now live. If no such measurements are currently available, these should be commissioned and funded adequately so that proper data can be supplied to the public and other interested bodies. (ref: section 3.4, 3.5 CCG People’s Response doc.) 4.4 Proper public consultations should be carried out with public meetings organised by the commissioned agent (eg NATS); individual mailshots should be sent out to every home within areas of great change ie. those where routes/holding procedures are being introduced for the first time, or considerably modified. Knowledge of existing routes/holding procedures, & therefore current impact, should be incorporated into new designs, so that a full appreciation of the whole, 24 hour, 365 days pa impact for residents is part of the plan. (ref: section 1. CCG People’s Response doc.) Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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4.5 MPs and Councils should be properly briefed by professionals; the commissioned agent should have professional staV available to present changes and give full briefings at Council/Public Meetings and to local & national resident/environmental bodies and charities. (ref: section 1, CCG People’s Response doc.) 4.6 SuYcient staV, trained and knowledgeable about the consultation, should be employed by the commissioned agent so that questions from the public and organisations can be answered fully by phone, e$mail or letter before the closing date. (ref: section 1, CCG People’s Response doc.) 4.6 The time-scale of the consultation should reflect the complexity of the changes ie if the changes have taken four years to prepare, then 25% of that time would seem an appropriate amount for the public to respond. (ref: section 1, CCG People’s Response doc.) 4.7 The area’s interested bodies eg County Councils, Conservation Boards, environmental and resident groups should be more thoroughly consulted when the Consultation is being written, so that local knowledge can be utilised and particular issues addressed, thus minimising opposition and conflict after publication of the Consultation document. (ref: section 1, CCG People’s Response doc.) 4.8 MPs and Councillors should have time to acquire the necessary information to brief their constituents thoroughly, seek their views and if appropriate, set up Working Parties within their constituencies or boroughs. Elected representatives should be engaged in discussion at the earliest opportunity, together with charities and other environmental bodies with key interests either nationally, or within the specific area. The widest possible publicity should be undertaken to ensure that the public gains access to relevant facts & information. Commissioned agents need to be transparent, accessible and open. (ref: section 1, CCG People’s Response doc.) 4.9 To achieve a reasoned balance between conflicting interests—if the above suggestions were carried out in good time at the right stage, then many of the conflicting interests could be resolved by discussion and negotiation. If this happens, then a balance between conflicting interests is more likely to be achieved. 5.1. Arrival and en-route holding delays could be minimised by ensuring that short haul departures are co-ordinated so that landing can be achieved without delay at the destination airport. This would reduce flight times, fuel and emissions, in line with current & projected European initiatives. 5.2 Constant Descent Approaches should be the norm and a primary ATC objective, not withdrawn unless exceptional circumstances prevail. This would minimise disturbance for those residents living close to airports. Numbers of flights should be reduced to a position where holding is not necessary, or can be accomplished at higher flight levels. 5.3 Whilst PR-NAV can have the advantage of keeping aircraft within a tight routing pattern, this is, in itself, extremely disadvantageous for residents living underneath the PR-NAV route. This is of great concern for mental and physical health if residents are aVected by all flights, regardless of wind direction and if the airport concerned holds a 24 hour operational licence. This scenario would apply to some residents under the original proposals of the TCN Consultation. Greater consideration must be given to their detrimental eVect on residents if it is intended that PR-NAV routes become the norm. (ref: sections 3.4, 3.5, 3.6, section 4 CCG TR 1.) 5.4 Holding procedures should be redesigned to cause the minimum of disturbance to residents. Even at 7,000–10,000 feet aircraft are very audible, especially in rural tranquil areas, or at night. Any increase for holding that can be achieved brings environmental benefits as it significantly reduces fuel-burn, noise and pollution. (ref: section 4, CCG TR 1, Proposals CCG TR 2.) 6. The roles and responsibilities of the interested parties are not clearly defined. The general public do not understand the relationship between DfT, NATS, CAA and airport operators. The public, quite rightly, find it very diYcult to believe that redesigns and consultations are unbiased when 41.9% of NATS is owned by a consortium of airlines and the rest by Government. These airlines naturally demand maximum use of airspace with scant regard for the environmental impact. The relationship between NATS and CAA should be more clearly separated. NATS, who are responsible for the changes, should not be commissioned to design them and the final decision should not rest with the CAA, but with an independent body. The general public does not understand what role the DfT play in consultation. (ref: section 1.5 CCG People’s Response doc.) 6.1 The public, or other aVected bodies, should have right of appeal, which does not involve a very costly Judicial Review. EVectively, the cost of such Court action precludes this from any but the most wealthy, which is an unfair situation. If an Ombudsman was appointed to look at individual and collective complaints, this would not only ensure that only serious concerns were raised, but would also provide the public with a financially realistic legal channel in which to do this. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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7. The redesigned airspace has to be managed safely and eVectively to minimize environmental impact. Unless this can be achieved, redesigns are valueless. On-going dialogue between management and designers should be in place throughout the design change process. 8. If further airport development has to take place, greater consideration should be given to regional airports and their associated transport infrastructure, outside the already overcrowded South East. 9. As additional airport capacity is currently not required, it would seem a wiser & more appropriate decision to fund research & re-design into those changes such as Holds, which can reduce and simplify the work load of ATC, rather than recruit and train staV who may not be required in the foreseeable future. 10. Funding should be provided by those who are going to benefit from the changes. As the changes will not directly benefit the general public, funding should not be drawn from public taxes.

References 1. People’s Response to the NATS TCN Consultation, published Chiltern Countryside Group June 2008. 2. Technical Report 1: Response to NATS TCN Consultation, published Chiltern Countryside Group June 2008. 3. Technical Report 2: Response to Interim Feedback Report NATS TCN Consultation 2008, published Chiltern Countryside Group September 2008. October 2008

Memorandum from Marilyn M Fletcher BSc PhD (AIR 10)

Summary (a) As airspace is increasingly utilised, there is pressure to design flight paths that occupy low-altitude air space instead of allowing aircraft to climb. This causes increased noise and visual pollution, and increases the potential for birdstrike. (b) Large high-flying birds are increasing in number in the UK, including raptors (Red Kite and Buzzard) and geese species. (c) An increase in the population of large high-flying birds and air traYc, particularly if flight paths are designed below 3,000 feet agl (above ground level), increase the risk of birdstrike. (d) Damage to an engine at low altitude and not in the vicinity of an airport may not allow suYcient time or space for the aircraft to recover or to make an emergency landing, resulting in a crash. The risk factors (aircraft and large high-flying birds) are predicted to increase each year. A directive should be considered presuming against long distance flying at 3,000 feet amsl (above mean sea level). (e) Currently there is a 13km Safeguard (CAP772) around designated aerodromes in which aerodromes can influence planning and land use decisions in order to minimise birdstrike. The aviation industry is dependent on the Safeguard to help minimise birdstrike. Designing long distance flight paths below 3,000 feet agl outside the 13km Safeguard erodes the present safety arrangements: aircraft would be flying for long distances outside the Safeguard, yet only a few hundred feet above what is currently considered acceptable within the Safeguard. (f) Clarification of para. 4.4 CAP772 is required. (g) The recent update (Sept 2008) of CAP772 did not include identification of Red Kite and Raven for bird controllers at airports. This may need rectifying. (h) The topography of land over flown at low altitude is not currently included in the “Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions”. This should be reviewed. (i) At present there is a lack of clarity in the interpretation of paragraph 45 of “Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions”. This will result in flight paths being clustered over National Parks and Areas of Outstanding Natural Beauty (AONBs). (j) The law is clear with regard to the CAA’s duty to the Countryside and Rights of Way Act (CROW Act) 2000 (Schedule 1 Part 11 Section 14e). However, NATS has disputed its own duty to the CROW Act. This should be clarified. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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1. Low-altitude flying increases the potential for birdstrike: (a) As airspace is increasingly utilised, there is pressure to design flight paths that lie at lower altitudes than is currently the case. In order to maximise airspace, it is envisaged that the development of low-altitude flight paths may be permitted that continue for long distances from departure airports instead of allowing aircraft to climb rapidly. Such development will cause increased noise and visual pollution over large areas. (b) As a Zoologist, university lecturer in Biological Sciences and member of a local conservation group, I would like to draw your attention to the potential for increased birdstrike if relatively long distances of low-altitude flying are designed. Flight paths designed for long distances below 3,000 feet agl are of greatest concern. In the USA, it is recognised that the height at which nearly all birdstrikes occur is below 3,000 feet agl (US Federal Aviation Administration Wildlife Hazard Management Manual 2005). Although care should be exercised in comparing continents, up to 3,000 feet agl. is also the height at which raptors can generally be found in Britain (details below). (c) The increasing pressure to design relatively long distances of low-altitude flying is exemplified by proposals in the recent TCN Consultation. Here NATS has proposed that aircraft can fly at 3,000 feet amsl. along half the length of the Chiltern Hills. The Chilterns are formed by an escarpment intersected by several river valleys, which in eVect divide it into a series of plateaux. These lie at 600 to 700 feet amsl. Thus if the proposals go ahead, aircraft will be flying 2,300 to 2,400 feet above the ground along the lengths of the plateaux. This will occur up to twenty miles from the departure airport, Luton. (d) I can find no directives which alert NATS to the presumption that flying for long distances below 3,000 feet agl increases the potential for birdstrike. The Chilterns is a designated AONB one of whose functions is to encourage conservation/growth of local fauna. Flying 2,300 to 2,400 feet above the ground for relatively long distances increases the chance of birdstrike. (e) Large raptors (Red Kite and Buzzard) and geese species (particularly Canada Geese) are increasing in numbers nationally: (i) “Red Kites Soar in 2008” is one of the RSPB’s “Top Stories”.(1) The re-introduction of kite (amber conservation status) into the Chilterns and elsewhere in the UK is a huge success in conservation terms.(2) In the Chilterns kite are increasing rapidly: in 2005 there was a total population of 250 breeding pairs (1,500 individuals including juveniles and non-breeding adults).(3) The population of breeding pairs has doubled in just three years and is now in excess of 500 (Southern England Red Kite Group). Extrapolating from this, the total number of individuals in the Chilterns in 2008 may be 3,000. The kite population in the Chilterns is currently at its most concentrated around Stokenchurch/ the M40, which was its original re-introduction site in 1989. The Red Kite has yet to exploit its distribution to its full potential. This is because kite, like other birds of prey, have an inbuilt tendency to breed close to where they were reared, which means that they are relatively slow to colonise new areas.(2) However, their territory is spreading.(3) Red Kite can be seen every day (albeit in considerably smaller numbers, as yet, than a few miles further South) in the area proposed by NATS for aircraft to fly below 3,000 feet agl.(3) Kite are readily adaptable.(2) Providing persecution is minimised, it is thought that there is no reason why the Red Kite should not become a familiar sight over much of lowland England.(3) (ii) The Buzzard is increasing rapidly now, and is predicted to do so in the long term.(4) It has spread into the south and east of Britain. Buzzards are apparently attracted to Red Kite. It is likely that they will continue to populate areas where kite are present. (iii) Canada Geese have undergone a dramatic increase in population (CAA’s Safety Regulation Group’s “Large Flocking Birds: an International Conflict between Conservation and Air Safety”).(5) Other species of geese are also increasing in the UK. (iv) Ravens are increasing in lowland England.(7) Again, they seem to be attracted to kite. (f) The wingspan range of these species is 4 to 5.5 foot. In the case of an aircraft engine engulfing one of them, the Canada Goose would probably do the most damage, being the heaviest. However, the raptors and Raven would also cause considerable damage, their long wings and body weight not being dissimilar, in terms of potential damage, to the long-limbed Heron. The Heron is thought to be the species ingested by a commercial aircraft in March 2007 causing an emergency landing at Manchester Airport.(8) Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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(g) The height that raptors fly is dependent on the production of thermals. Buzzards fly at an average of 1,300 feet in the UK, but can be found over 3,300 feet on warm clear days, or even higher.(9) In general, Red Kite forage at a lower height than Buzzards, quite often fairly close to the ground. However, kite also like to soar high, possibly when making their way to foraging areas. A study in Northern Germany on the maximum height to which raptors fly found Red Kite 3,300 feet above ground level, compared with Buzzard at 4,300 feet agl.(10) Kite have been struck by military and light aircraft in the UK,(2) presumably as have other species discussed here, although I do not know at what height. Booker Airport, High Wycombe, has apparently had problems with kite. I could find no references to the altitudes that Ravens fly. However, Ravens are attracted to Red Kite accompanying them in flight, “spiralling upwards together until disappearing from view”.(11) Canada Geese can fly extremely high when migrating (9,000 feet), although most in the UK, I believe, are non-migratory.Canada Geese fly in small flocks within the UK to exploit food sources/ nesting areas/habitat, and to form winter flocks on lakes and reservoirs. I do not know how high this species flies on such trips. The projected increase in wet summers and the resulting flooding will presumably further increase available habitat, and therefore, probably, the population of this species. Large reservoirs (eg Tring, Bucks) sometimes attract flocks of nationally-rare varieties of migrating geese. Are these monitored? Some swan species fly at high altitude during migration (Whooper Swan—a UK species). I do not know how high Mute Swans fly. (h) The greatest danger to aircraft is the presence of large flocking birds because of their potential to cause multiple engine failure resulting in a catastrophic air accident. Canada Geese and other water birds fly in small flocks (skeins). Raptors and ravens attract one another, and form small aerial social groups.(11) (i) Most cases of birdstrike currently occur in the vicinity of an airport, where an emergency landing can take place if a single engine is involved.(8) In contrast, an aircraft on a low-altitude flight path with birdstrike to a single engine may be tens of miles from an airport. Such damage to an aircraft at low altitude and not in the vicinity of an airport may not allow it suYcient time and space to recover or to make an emergency landing, resulting in a crash. (j) Safeguarding Currently there is a 13km zone or Safeguard, around designated civil and military aerodromes (CAP772 Birdstrike Risk Management for Aerodromes).(12) The Safeguard is an area over which airports can influence planning and land management decisions which may attract species liable to cause birdstrike. CAP772 states “The 13km circle is based on a statistic that 99% of birdstrikes occur below a height of 2,000 feet, and that an aircraft on normal approach would descend into this circle at approximately this distance from the runway.” (i) Caution should be exercised with the above statistic. The increase in large high-flying birds, and the pressure to increase long distance flying below 3,000 feet agl. will aVect this. (ii) The description of the Safeguard is not clear. However, as I understand it, the Safeguard can be described as a short cylinder of airspace; its radius is 13km; its height is 2,000 feet; at the centre of one of its bases lies the aerodrome. This cylinder of airspace is where aircraft are believed to be most likely to expect birds. It is surely, then, not acceptable practice for aircraft to fly outside the Safeguard for long distances at 3,000 feet amsl., where they may encounter raised ground at several hundred feet amsl. For example, in the Chilterns, aircraft will be flying a long distance from the Safeguard at only 300 or 400 feet above what is considered acceptable in the Safeguard, and without any of the protection oVered by the Safeguard. Action: Improve wording of CAP772 “…an aircraft on normal approach would descend into this circle at a height of 2,000 feet at approximately 13km from the runway.” Caution: The aviation industry is dependent on the Safeguard (CAP772) to help minimise birdstrike. Designing long distance flight paths below 3,000 feet agl. outside the 13km Safeguard erodes the present safety arrangements: aircraft would be flying for long distances outside the Safeguard yet only a few hundred feet above what is currently considered acceptable within the Safeguard. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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(k) CAA up-to-date? The CAA states “it is fully cognisant of the safety risk to aircraft operations posed by birdstrikes”. CAP772 is concerned with birdstrike risk assessment and mitigation and is aimed at aerodromes. Species identification is described as being “essential” by the CAA (para. 5.1) in order to minimise further risk. However, among the 33 species which bird controllers at airports are trained to identify, Red Kite and Raven are not mentioned. This is despite the chapter on species identification being published only last month and the increase in kite as an RSPB “Top Story”. It is obviously important for the CAA to be aware of recent changes in the UK bird population. Action: Consider amending CAP772 to include Red Kite and Ravens. (l) An increase in air traYc (particularly if flight paths are designed below 3,000 feet agl) and an increase in the UK population of large high-flying birds increases the risk of birdstrike. Flight paths should be designed to take aircraft above 3,000 feet agl. as soon as possible. Aircraft should not be kept down for tens of miles in a stratum of airspace far from the airport vicinity where they will occasionally encounter large birds. The projected increase in air traYc (for example one commercial plane every six minutes at peak periods over the Chilterns at 2,300 to 2,400 feet agl) makes such an encounter a possibility, and the risk factors (numbers of aircraft and large high- flying birds) are predicted to rise each year. Action: A directive should be considered presuming against long distance flying at 3,000 feet amsl.

2. Topography (a) The topography of land over flown at low altitude should be considered for inclusion in the “Guidelines to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions”. Topography is not currently included in this document, which was published in 2002 and has not been altered since. Suggested wording: Action: “Local topography should be taken into consideration when designing flight paths at low altitudes in controlled airspace, in order to minimise the impact on the environment of low flying aircraft.”

3. Countryside and Rights of Way Act (Crow Act) 2000 section 85 The law is clear with regard to the CAA’s duty to the CROW Act 2000 Section 85: the CAA’s duty is embedded in the act (Schedule 1 Part 11 Section 14e). However, NATS has disputed its own duty to the Act. (TCN Consultation Initial Feedback Report Section 26.7).(13) Action: It is not logical or practical for one organisation involved in airspace change to be subject to the CROW Act 2000, and for another to declare that it is not. This should be clarified. 4. Paragraph 45—“Guidelines to the CAA on Environmental Objectives Relating to the Exercise of its Air Navigation Functions” states: “Government policy will continue to focus on minimising over-flight of more densely populated areas below 7,000 feet. However, where it is possible to avoid over-flight of National Parks and AONBs below this altitude without adding to the environmental burdens on more densely populated areas, it clearly makes sense to do so.” (a) A letter from the Minister of State for Transport, Rosie Winterton, to the Chilterns Conservation Board (2 August 2008) clarifies the interpretation of paragraph 45. She states that “more densely populated” and “congested” are interchangeable. This interpretation means that in designing flight paths, over-flight of congested areas (large towns and cities) should be minimised below 7,000 feet. (b) In contrast, NATS has interpreted paragraph 45 in the comparative sense of “more densely populated” to mean that flight paths should be sited so aircraft over-fly wherever fewer people live. This is demonstrated in the recent TCN Consultation where NATS believes it is following government guidelines by moving the centre-lines of flight paths for Westerly and Easterly Luton Departures bound for the SW from a position over the small market towns of Princes Risborough (population 8,000) and Wendover (population 7,000) to a position over the Chilterns AONB. These small towns lie at a lower altitude than the Chilterns and cannot be described as “congested”. Nevertheless, because the Chilterns route is less densely populated than the existing Wendover/Princes Risborough/associated low lying countryside route, NATS believed, and still do believe (TCN Initial Feedback Report para. 7.2.3), that the proposed flight paths over the Chilterns will now comply with government guidelines. This move will result in the proposed flight paths conflicting with other air traYc, so that aircraft on the proposed flight paths will need to remain at lower altitudes for far longer than at present (including the potential for Wendover and Princes Risborough to be over flown at a lower altitude than at present during oV-peak periods eg. night-time) (Figs. 8,9,16 and 17 NATS TCN Consultation Document).(14) Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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(c) If the reader interchanges the word “congested” for “more densely populated” (as stated by the Minister of State), it is clear that in moving the flight paths over the Chilterns AONB, NATS has contravened paragraph 45 of the government’s guidelines. (d) The inevitable result of pursuing the policy of over-flying less densely populated areas interpreted in the comparative sense, as NATS has done, is that as airspace is increasingly utilised, flight paths will become clustered over National Parks and AONBs. Because there are restrictions on the amount of building that can be carried out on these designated lands, they are inevitably less densely populated. The aggregation of flight paths over National Parks and AONB’s is clearly not what the government intends. Action: Clarification of paragraph 45 by inserting the word “congested” (as is used in paragraph 46) for “more densely populated”. Finally, I am not an ornithologist. The information provided should be verified. Marilyn M Fletcher BSc PhD October 2008

References (1) http://www.rspb.org (2) Carter (2007) The Red Kite, Arlequin Press. (3) Carter and Whitlow (2005) Red Kites in the Chilterns, English Nature and the Chilterns Conservation Board. (4) http://www.bto.org/birdtrends2007/wcrbuzza.htm (5) http://www.caa.co.uk/docs/1437/srg—acp—00018-01-030303.pdf (6) http://www.bto.org/birdtrends2007/wcrmutsw.htm (7) http://www.bto.org/birdtrends2003/wcrraven.htm (8) http://uk.youtube.com/watch?v%hpSuPDWswNs (9) http://www.rspb.org.uk/advice/expert/previous/buzzard.asp (10) Kusters and Scheller (1998) Birdstrikes with Military Aircraft and Flight Altitudes of Raptors in Germany, International Birdstrike Committee 24/WP 26. (11) http://www.birdsofbritain.co.uk/features/red-kite2.asp (12) http://www.caa.co.uk/docs/33/CAP772.pdf (13) http://www.consultation.nats.co.uk/uploads/ Initial%20Feedback%20Report%2022%20July%202008(1).pdf (14) http://www.consultation.nats.co.uk/uploads/TCN-PartF-CHILTERNS-and-LUTON-20march08.pdf

Memorandum from Ashmansworth Parish Council (AIR 11)

Summary Our most immediate impressions of CAA and the manner in which they work are related to their handling of the manner in which they have handled a request by NATS to extend airspace in Southern England. In addition, this has led us to examine their approach to similar cases elsewhere. As a result we have developed the following concerns which we would like your committee to consider: — National and European Legislation provides demands, including environmental aspects, that CAA must obey in choosing air traYc routes. It is submitted that CAA has not always paid suYcient attention to this. — As indicated in the announcement of this Enquiry, CAA has a close relationship with NATS. It is submitted that this relationship is too intimate in that it appears that CAA nearly always support any proposal from NATS, irrespective of the merits of the individual case. It appears that evidence from other sources, even that which is developed by environmental specialists, is downgraded and largely dismissed. — When proposing changes to airspace routings, NATS usually holds an enquiry and on the basis of their results, requests CAA for approval of the changes. It appears that NATS frequently fail to conduct the enquiry in the manner laid down by CAA and fail to take any account of key issues raised in the enquiry. CAA seem to gloss over errors in the NATS’ process and always appear to support NATS’ conclusions. This results in respondents to that enquiry wasting their expectations, time and money in preparing a case. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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— There is no reasonable, aVordable appeal process against decisions of CAA. — Details of some of these shortcomings were given by our MP Sir George Young in the adjournment debate on 19 November last year.

Submission 1. The UK is one of the most crowded countries in the world and population densities in our cities are high. However, we are blessed with a limited number of tranquil areas, especially those designated as National Parks and Areas of Outstanding Natural Beauty, where pollution and particularly noise levels, are much lower and highly prized by those who visit or live there. An aircraft flying over a very quiet area may generate levels of noise suYcient to upset people whereas the same level of noise might pass totally unnoticed over a city. There is legislation in place to protect such areas but CAA fail to take account of ambient noise levels of each area. When considering the relative impact of noise over diVerent routes, currently tranquil areas, especially National Parks and AONBs, must be given priority. The most sensitive areas should ideally be avoided altogether. 2. NATS is a commercial company with clear targets to meet. They generally perform well in meeting their own objectives, but we rely on them being regulated fairly by CAA, since there may be a conflict between commercial desires and environmental concerns or national well-being. For many years (from the creation of CAA in 1972 until 2001), NATS was part of CAA but now they have been given clearly distinct roles. However, it is felt that there are still considerable close relationships between staV in the two organisations. This results in a natural tendency for CAA to support any request from NATS. CAA should demonstrate their integrity as a regulator by acting fairly and not always supporting requests from NATS. 3. When NATS wishes to reorganise airspace routes, they hold a Consultation, which gives the impression of being democratic. However, our experience is that NATS goes through the motions, but then ignores most arguments against their case and is then supported by CAA approving the proposal from NATS. Complainants may spend large sums of money and much time in preparing a case against such proposals when they feel justified. If the result is inevitably against any objection to a proposal from NATS, then this money, time and eVort is wasted, which increases a feeling of cynicism against government. There is a widespread opinion, based on experience of a number of recent cases, that CAA and NATS are very arrogant in their handling of questions and objections. Often these questions are ignored and relevant information (needed to develop a balanced case) which is requested from NATS is denied. CAA do not appear to take this into account when reaching their final decisions. CAA eVectively acts as judge and jury. CAA should demand that NATS respond more fairly to requests for information and to any reasonable criticism they receive. 4. While accepting that endless appeals cost money and waste time, there should at least be a simple appeal process following CAA’s decisions. This process should be accessible to concerned members of the public without involving them in unreasonable expense. At present, the only form of appeal is Judicial Review which can only be applied against alleged failure of process, not disagreement with decision. In addition, the expense of a Judicial Review can be prohibitive, eVectively denying members of the public the right of appeal. Where a complaint is based on environmental objections, we contend that the Aarhus Convention applies and that the cost of any legal action must not be prohibitively expensive. We request that a simple legal appeal process be adopted that can be aVorded by normal people, without costing them or CAA unwarranted expense. We request the Parliamentary Transport Committee to note the four points listed above and to implement the reasonable actions requested. October 2008

Memorandum from Virgin Atlantic Airways Ltd (AIR 12) 1. Virgin Atlantic is pleased to submit evidence to the House of Commons Transport Select Committee Inquiry into the use of airspace. As the UK’s second largest airline, Virgin Atlantic is well placed to respond to the Committee’s request for views on this issue. 2. Virgin Atlantic’s answers to the questions asked by the Committee in its call for written evidence are set out below.

What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented? 3. To deliver the additional capacity envisaged in the 2003 White Paper, a number of complex airspace reviews are likely to be required to guarantee the safe and eYcient management of UK airspace. To ensure that the airspace changes necessary are delivered, a more streamlined airspace change process is required. Virgin Atlantic is concerned with the seemingly overly conservative approach to how airspace use is planned. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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We agree that the Directorate of Airspace Policy (DAP) should be careful and thorough but, in our view, decisions take too long to be made. We believe this primarily stems from a lack of resources to administer and produce requirements, for example with procedure design. 4. We are now entering a period when airspace is particularly heavily used and ever more congested, particularly in the South-East of England. Virgin Atlantic is of the view that the traditional way that the CAA’s Airspace Policy team has approached the regulation of airspace is simply too slow. It has taken typically four to five years to make any changes—this is too cumbersome and does not respond adequately to the demands of the market. The needs of DAP’s commercial stakeholders should be a priority. Route eYciency, which has important cost implications for airlines, is often regarded by DAP as a bonus rather than a core part of the decision-making process. DAP should be allowed to adopt a more dynamic airspace change process to ensure greater speed and simplification of airspace change processes. In particular, we acknowledge the importance of environmental issues and consultation for lower airspace. 5. Virgin Atlantic recognises that recent economic turmoil has potentially softened short run passenger demand. However, Virgin Atlantic does not anticipate that these short run eVects will substantially alter the long run forecast demand profile outlined in the 2003 White Paper and the White Paper progress report (2006). 6. Many airport infrastructure and airspace measures will be necessary to fulfil anticipated passenger demand as set out in the 2003 White Paper. Necessary airspace measures should be implemented at the earliest opportunity to ensure that airspace management does not act as a barrier to increase capacity in line with the projections of the 2003 White Paper. In addition, airspace changes should be undertaken to ensure suYcient airspace capacity to deliver the diVerent variations in capacity expansion which may arise. Airspace improvements often have the additional bonus of having environmental benefits.

Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for air traYc control?

7. For Virgin Atlantic safety is our highest priority in any decision regarding the utilisation, management or changes in airspace, as it is with our own airline operation. Airspace utilisation can only be increased if safety margins are assured. However, increased airspace capacity can be delivered whilst maintaining safety through airspace change processes and investment in aircraft and ground technology. Airspace changes can include standardising routes and reduced complexity. For example, by using modern technology (eg P- RNAV) to optimise routeings, significant benefits in terms of safety and additional capacity could be delivered.

8. The increased involvement of Europe through the Single European Skies (SES) initiative is adding complexity to what is already a complicated relationship between DAP, the military and commercial and general aviation users of UK airspace. In Virgin Atlantic’s view, DAP on the whole appreciates the importance of commercial air transport to the UK economy, but at times we believe that the historical pre- eminence of military requirements is still evident. The current air traYc control interface between military and civilian arrangements works well. Overall, DAP manages the tensions between the conflicting users well, but more could be done to improve route eYciencies. SES will, we hope, make a major contribution to this. Virgin Atlantic does not foresee that increases in capacity would undermine this interface.

Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently?

9. Virgin Atlantic believes that the current approach to planning and regulating UK airspace is adequate. However, the processes followed by DAP in regulating UK airspace could be streamlined. We recognise the need to consult and that consultation should take place with the appropriate parties. However, we believe that measures could be taken to reduce the burdensome nature of some DfT and DAP processes to increase the speed of change and to ensure that regulatory oversight is appropriately targeted. Such measures would enable DAP to be more agile to react to altered capacity requirements.

10. Virgin Atlantic believes that an airspace masterplan would be an advantageous development. Such a masterplan would provide a helpful framework to ensure that all aspects of the 2003 White Paper are delivered. However, it would need to be based on realistic assumptions of the likely delivery timescales and commercial realities of the proposals suggested in the White Paper with regards to future airport infrastructure and passenger demand. A piecemeal approach to airspace redesign may require future redesigns or may lead to unnecessary complexity or ineYcient routeings being maintained. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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How are the eVects of aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? 11. Extensive consultation processes are undertaken when airspace changes are proposed. As a key component, the eVects of aircraft noise and emissions are taken into account. Virgin Atlantic supports the principle that when assessing airspace redesign a number of environmental benefits should be optimised whilst ensuring safety and delivering operational requirements. In particular, we recognise the need to minimise noise impacts on local populations and reduce fuel burn (and therefore emissions). 12. All relevant stakeholders should be consulted or have the opportunity to comment on proposed airspace changes. In particular airspace users, airports and the general public, where they are aVected should be consulted. 13. We recognise that it is necessary to make a judgement when balancing conflicting factors. In principle, Government Policy should guide this process. We were pleased to note that in the recent Terminal Control North Consultation, NATS set out some broad criteria in order to balance conflicting interests. NATS proposed the redesign of the TCN area by prioritising flights on routes: — below 4,000 feet to avoid large populations; — between 4,000-7,000 feet to where possible mitigate noise impact whilst also reducing fuel burn and emissions; and — above 7,000 feet to increase fuel eYciency and reduce emissions. 14. By setting out broad principles, NATS was able to propose an airspace redesign which balanced safety, capacity, growth and operational requirements, whilst also having regard for environmental factors. 15. Virgin Atlantic is concerned that not enough attention is given by DAP to Environmental Impact Assessments and Regulatory Impact Assessments before decisions are taken. Nowadays these should be a basic input to any significant regulatory action.

How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? 16. Airspace across Europe is fragmented between a large number of airspace sectors. Aircraft passing through each sector are managed by the associated air traYc control agency before responsibility is passed onto the next agency. Due to the fragmented nature of airspace management, this potentially leads to sub- optimal flows into the UK. 17. Developments within the Single European Sky (SES) programme and the development of Functional Airspace Blocks (FABs) are intended to reduce the complexity of European airspace management and consolidate appropriate airspace sectors. These developments will create airspace management improvements, for example, the exploration of a UK/Eire FAB will increase the eYciency of airspace management, ensure better flows of air traYc into and through UK airspace and provide better, more eYcient routeings. 18. A UK airspace masterplan, and any subsequent proposals to change UK airspace, will need to have regard to and fit within the developments proposed as part of the SES and the evolution of FABs in Europe.

What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? 19. A significant proportion of modern aircraft are able to operate in more automated and advanced airspace. However, the use of advanced technology onboard has been constrained by the lack of investment in associated ground infrastructure. SES will allow for the development and use of new techniques and technologies to improve eYciency, particularly with regard to delivering advanced ground infrastructure. 20. By consolidating complimentary airspace sectors, FABs seek to create more eYcient, direct routeings through complex airspace sectors, reducing wasteful flying. 21. Utilising existing runways more eYciently (eg through mixed mode) and adding new runways will create opportunities to reduce unnecessary holding in stacks and ground delays. Ensuring investment in technology and a commitment by EU governments is necessary to ensure that such opportunities are realised. 22. Technology enhancements, improved techniques, simplified airspace with more direct routeings alongside reduced ground and airborne holding will all lead to significant environmental improvements. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties-Department for Transport, the CAA, airport operators, NATS, etc-appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play? 23. Virgin Atlantic is satisfied that the allocation of roles between interested parties is adequate. However, we are not convinced that the various roles or responsibilities are clear or understood by all stakeholders, particularly in relation to ongoing airspace management developments. 24. Roles and responsibilities between stakeholders have been allowed to develop organically in response to ongoing airspace changes. This has in some instances led to a degree of fragmentation between interested parties and in some areas roles and responsibilities with regard to airspace redesign have not kept up with the pace or type of airspace changes. 25. It is Virgin Atlantic’s opinion that given the significant changes that European airspace management will undergo, as a result of SES and the development of FABs, it may be healthy to review the structure, roles and responsibilities of stakeholders to check that these are consistent and eVective to deliver necessary airspace change.

Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? 26. Airports that take forward airport development proposals are better placed than Virgin Atlantic to judge how far airspace management considerations delay the planning processes in relation to the proposals.

What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined? 27. Consultation processes on airspace change and management take into consideration the requirements of all users of the airspace. All airspace users as interested parties are invited to respond to airspace consultations. The consultation process would seek to manage and optimise competing airspace demands. Strategic decisions on the use of airspace should flow from national Government policy.

Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? 28. Virgin Atlantic does not envisage that airport capacity and airspace change developments will be hindered by recruitment or training issues. NATS would be commercially incentivised to manage recruitment and training programmes to ensure that airspace changes are implemented.

Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? 29. Strategic airspace changes should be funded by government, airports and the suppliers of air traYc management services. Government should fund airspace change processes to ensure that wider objectives of national policy are delivered, eg benefits to the wider economy and environmental criteria. Although the level of funding required to deliver additional airspace capacity is uncertain, Virgin Atlantic does not envisage any issues in respect of the availability of funding, as air traYc management providers will be commercially incentivised to undertake airspace redesign to increase airspace capacity. October 2008

Memorandum from Save Our Peace and Quiet (SOPAQ) (AIR 13) — This submission has been prepared by the campaign group SOPAQ which was set up in West SuVolk in response to the NATS proposals to site an aircraft stacking hold over West SuVolk. — SOPAQ, along with many other residents from the area, campaigned vigorously to make people aware of the proposals and their potential impact on residents from increased aircraft noise and aircraft emissions. — SOPAQ is particularly concerned about expansion of airports and the eVects on the environment in terms of noise and air pollution and would like to submit its response to the following questions: Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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1. How are the eVects of aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? NATS consulted residents about their views on the potential impact of its proposals. According to the NATS feedback report issued in July 2008 578 responses were received by representative groups such as parish, district and county councils who represent a large number of residents. 14,647 members of the public also responded individually. Of those who responded 86% were opposed to the proposals. The main reason for opposition was concern about noise in rural areas where tranquillity is valued. SOPAQ believes that residents who will be aVected by changes to the use of airspace should be consulted as widely as possible but is concerned that any consultation is of little value should the findings be ignored. NATS has recently announced that it is still evaluating the feedback it has received. The initial feedback report from NATS acknowledged concerns about noise and tranquillity but as yet no information has been released as to whether these concerns will be reflected in any changes to the original design of the holds or indeed whether the need for holding will be reconsidered in the light of such strong opposition. Whilst SOPAQ accepts that it is diYcult to strike a balance between conflicting interests, it believes that the positioning of aircraft holds over tranquil rural areas will have a damaging impact on the environment and quality of life. Whilst the rationale of minimising the number of people aVected by aircraft noise is understood, the ambient noise levels in rural areas are considerably less than in built up areas and any increase in noise is noticeable. If the proposals go ahead some of the most beautiful and tranquil areas in the East of England will be lost forever. InsuYcient consideration has been given to the importance of these areas of “calm” both for local residents and visitors from towns and cities. The United Kingdom is already facing huge pressure to build more housing and for urban development. It is vital to preserve the countryside for people to enjoy in the future. SOPAQ is also concerned about the aVect on health of the noise pollution which will result from the NATS proposals. The World Health Organisation has carried out research which suggests that 3% of heart attack deaths can be attributed to stress induced by noise pollution.12 For residents living in areas which at present have virtually no ambient noise, the potential impact on wellbeing and health should be taken into consideration. With the noise of a typical aircraft flying at 4000ft (the lowest height limit given by NATS for the Stansted Western arrivals hold) being given as 69dB, equivalent to a car driving 40 miles per hour 23 feet away, the level of disturbance will be way in excess of noise experienced in quiet rural areas. Very little information was given in the initial consultation document about the possible aVects on air quality. An increase in aircraft flying over rural areas must be detrimental air quality. SOPAQ believes that we should all be questioning whether the continuing expansion of air travel is sustainable. With growing concerns about climate change and the very real dangers to our world as we know it, there is now clear evidence that air travel is the fastest growing source of green house gases. According to the Friends of the Earth report Aviation and Global Climate Change’ aviation is the fastest growing source of carbon dioxide in the UK. Carbon Emissions from UK aviation increased by 11% in 2004 alone13 and are estimated to increase four fold between 2000 and 2050.14 Friends of the Earth has recently launched its Big Ask campaign calling for the government to include aviation emissions in its Climate Change bill. If aviation emissions are excluded, and indeed if aviation is allowed to continue to expand, the potential impact on the environment will be huge. Aviation emissions have between two and four times the impact of carbon emissions alone due to complex chemical reactions at altitude.15 Any improvements in managing the reduction of aviation emissions will be countered by the current growth in passengers of 6.4% per year.16 The Environmental Change Institute at Oxford University recently concluded that it will be impossible to meet the UK’s 60% carbon reduction 2050 climate target without curbing aviation growth.17 Allowing unrestricted airport expansion is contrary to the UK’s stated intention of tackling climate change. Once airport expansion goes ahead it will be impossible to reverse the eVects of aviation emissions on climate change as passenger numbers increase. As a nation we should be looking at ways to reduce our dependency on air travel and find alternative greener methods such as rail travel, particularly within UK and Western Europe.

2. What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented? SOPAQ believes that we should all be questioning whether expansion of air travel is realistic in view of the current problems being faced by the aviation industry. Since the NATS proposals were introduced, there has been a massive increase in the cost of oil and a number of airlines have already been forced to reduce their services and others have collapsed. As the “credit crunch” begins to aVect more and more people, flying

12 Quantifying the burden of disease from environmental noisew second technical meeting report—World Health Organisation. 13 DEFRA figures including international flights. 14 Predict and decide: aviation, climate change and UK policy p 14. 15 Predict and decide: aviation, climate change and UK policy pp 16–17. 16 Eurostat figures p 49 Growth Scenarios. 17 Predict and decide: aviation, climate change and UK policy. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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will become a luxury that fewer people can aVord. Although the government has predicted an increase in the number of passengers passing through UK airports, is this now likely? Do government figures include the number of people transiting through UK airports en route to other destinations? Over the past year figures for Stansted airport show a reduction in passenger numbers, not an increase, thus calling to question whether the predictions are accurate and whether expansion is necessary. In August 2008, the number of passenger movements through Stansted decreased by 4.7% and air transport movements (passenger and cargo) were down by 8%.18 These figures reflect a continuing downward trend which began in October 2007 calling into question predictions of an increase in passenger demand. As people become more aware of the environmental impact of air travel SOPAQ believes that people will try to find ways to reduce the number of flights they take and find alternative methods of travel.

3. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? SOPAQ believes that holding is not an eYcient method of managing flights in terms of increased fuel consumption, as aircraft divert from direct flight paths into the holds and during holding, as well as the environmental impact of aircraft holding on air quality and noise levels. October 2008

Memorandum from Natural England (AIR 14)

Summary 1. Natural England is concerned by the potential landscape and biodiversity impacts of airport expansion and the airspace changes required to accommodate this expansion. 2. The lack of a methodology to assess the impacts of increased overflying at diVerent altitudes on the tranquillity of protected landscapes and open countryside means that the impacts and their significance cannot be clearly established. 3. We support the proposal for an Airspace Masterplan and recommend that a Strategic Environmental Assessment of this plan is carried out which will help to establish the direct, indirect and cumulative environmental impacts of airspace change.

Evidence 4. Natural England has been charged with the responsibility to ensure that England’s unique natural environment including its flora and fauna, land and seascapes, geology and soils are protected and improved. Natural England’s purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. 5. Our evidence relates to two of the inquiry questions in particular: (i) Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? (ii) How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? 6. Current Government policy supports a doubling of air passenger flights by 2030 with significant expansion at Heathrow and Stansted. With the recent Competition Commission conclusion that BAA’s ownership of seven UK airports is counter-competitive, expansion at Gatwick may also be brought forward. Whilst the statutory processes for this expansion have yet to proceed, the policy context provides strong support for expansion focused in the south east of England. In addition, many regional airports are vigorously pursuing expansion plans in accordance with the Air Transport White paper. It is therefore likely that a significant amount of expansion will proceed, although there are many variables that may aVect this such as the forthcoming Climate Change Bill, the economic climate and fuel prices. 7. Natural England is concerned by the potential landscape and biodiversity impacts of airport expansion and the airspace changes required to accommodate this expansion. We have recently objected to the expansion plans for Stansted, London Ashford and Bournemouth Airports due to potential impacts on nationally and internationally protected sites and species caused by the proposals. Further expansion at

18 www.baa.com—Stansted Passenger and ATM statistics. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Heathrow will damage local landscape character and adversely aVect local biodiversity. If they proceed, these expansion plans are likely to lead to a further increase in overflying of protected landscapes and environmentally sensitive sites. 8. Recent airspace changes by NATS (National Air TraYc Control Services) to accommodate growing numbers of flights are already leading to increased overflying of the New Forest National Park, the North Wessex Downs, the Cotswolds, the Mendips, the Quantock Hills, the Blackdown Hills, the Shropshire Hills and the East Devon Areas of Outstanding Natural Beauty (AONBs). If the proposals set out in the recent NATS consultation on the TCN (Terminal Control North) airspace are accepted, they will also lead to increased overflying of the Chilterns AONB at less than 7,000 feet in order to reduce overflying of Wendover and Princes Risborough from Luton departure flights. Some protected landscapes are benefiting from a reduction in overflying as a result of these recent changes—for example, the Dedham Vale AONB should experience a decrease if the TCN proposals are implemented. Overall, the level of overflying of protected landscapes is increasing. 9. It is worth noting the legislation backing the protection of these landscapes. National Parks (NPs) & Areas of Outstanding Natural Beauty (AONBs) have been confirmed by the Government as having the highest status of protection in relation to landscape and scenic beauty. Each of these designated areas has specific statutory purposes which help to ensure their continued protection. National Park purposes are to conserve and enhance their natural beauty, wildlife and cultural heritage and to promote opportunities for the understanding and enjoyment of their special qualities by the public. The statutory purpose of AONBs is to conserve and enhance the natural beauty of their area. In both instances this includes the concept of tranquillity. 10. Each of the Acts relating to these areas places a general statutory duty on all relevant authorities & bodies, requiring them to have regard to their purposes as set out above. The statutory duties are provided for in Section 11A (2) of the National Parks and Access to the Countryside Act 1949 (National Parks) & Section 85 of the Countryside and Rights of Way Act (CROW) 2000 (AONBs). For National Park and AONB duties the Civil Aviation Authority (under s.19 of, and Schedule 2 to the Civil Aviation Act 1982), is regarded as a statutory undertaker. 11. We recognise that airspace changes are largely a technical response to changes on the ground, and that if national policy supports airport expansion, NATS will be required to accommodate the resulting increase in flights in the safest possible way. The trend towards increased overflying of protected landscapes and open countryside is at least in part due to the Department for Transport’s guidance to the Civil Aviation Authority, which supports the avoidance of overflying environmentally sensitive areas only where it is economical and safe to do so, and where it will not result in more heavily populated areas suVering greater disturbance.19 12. This means that it will be England’s less populated areas that absorb the impacts of continuing changes to airspace. Natural England is concerned that the ongoing expansion of airports, flights and airspace will impact negatively on biodiversity, landscape and recreation, causing visual intrusion, loss of tranquillity, and increases in noise and air pollution. 13. It is important and in keeping with other aspects of Government policy to protect these designated areas from negative impacts. The EU Directive on Environmental Noise 2002 states that member states should maintain environmental noise quality where it is currently good. The Government’s rural policies state that “protecting the countryside from further intrusion of noise is not a luxury”20 and identify tranquillity as one of the key elements that we value about the countryside, with the tranquillity and attractiveness of the countryside oVering “a major opportunity for rural businesses in the recreation and tourism sector”.21 Tranquillity is often used in Landscape Character Assessments (LCAs) to describe the special quality of a landscape. The Campaign to Protect Rural England’s (CPRE) research into tranquillity has shown that the presence of aircraft undermines tranquillity by bringing man-made noise and visual intrusion into a “natural environment”.22 14. Noise is measured by its impacts on the population and so sparsely populated areas are not deemed to be greatly aVected. Natural England is concerned by this on two points: — Aircraft noise remains out of place in the countryside and is an intrusion that impacts on people’s enjoyment of the countryside. Even if decibel levels remain under the threshold for community annoyance, there is the key issue of low level aircraft noise becoming more frequent due to shorter gaps between each flight. — As air travel growth continues, the pressures to overfly and move stacks to less populated areas in order to ease the impacts on populated areas will increase. It is not clear how the countryside and designated landscapes will be protected from this.

19 Guidance to the Civil Aviation Authority on Environmental Objectives relating to the exercise of its air navigation functions (Department for Transport, 2002). 20 Rural White paper, 2000 Defra page 111, Section 9.4. 21 Rural Strategy, 2004 Defra page 34. 22 CPRE Tranquillity mapping, 2006 http://www.cpre.org.uk/campaigns/landscape/tranquillity/our-tranquillity-map- explained. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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15. We have responded to a number of recent airspace change and air traYc control consultations expressing these concerns. Airspace consultations do consider the impact of their proposals on tranquillity and generally recognise that tranquillity, despite its subjective nature, is a decreasing and highly valued resource that should be protected. However, whilst the resulting decisions have acknowledged tranquillity as an issue and also our concerns about its loss, they have always proceeded with the original proposals unchanged. The lack of a methodology to assess the impacts of increased overflying at diVerent altitudes on the tranquillity of protected landscapes and open countryside means that the impacts and their significance cannot be clearly established. 16. Regarding the TSC’s question of an Airspace Masterplan (AMP), we have previously urged NATS to raise the long term implications of changes to airspace for designated landscapes and the wider countryside with the CAA and DfT, and have called for an assessment of the cumulative eVects that will be caused by airspace changes to accommodate the Air Transport White Paper’s expansion plans. We have recommended that additional work is undertaken into the eVects that growth in air travel is likely to have on the demand for expanded air space over designated landscapes and other high quality rural landscapes, beyond 2018. We therefore support the TSC’s suggestion of an Airspace Masterplan. 17. However, airport masterplans, which set out individual airport’s expansion plans over a set timescale, have no statutory status and do not require any type of environmental assessment—Strategic Environmental Assessment (SEA) being the most appropriate. We recommend that the AMP should be subject to an SEA, whether or not it has statutory status. This should be seen as good practice and in keeping with the sprit of existing CAA guidance that seeks to assess the environmental implications of changes to airspace. October 2008

Joint memorandum from the Air Safety Group (ASG) and the Parliamentary Advisory Council for Transport Safety (PACTS) (AIR 15)

Summary This response to the House of Commons inquiry comes from both the Air Safety Group and the Parliamentary Advisory Council for Transport Safety and concentrates on the safety issues. The main concerns in the response relate to the following areas: — concerns over the increasing complexity of the air traYc controller task; — safety in uncontrolled airspace; — the mandatory carriage of Mode S Transponders and TCAS; — just Culture and Incident reporting; — civil/military incidents; — the safety of Unmanned Aerial Vehicles and Very Light Jets; — the lack of capacity in the South East of the UK and its impact on runway utilisation, resilience, aircraft stacking, inter-arrival times and safety margins; and — consultation and decision making regarding airspace design and airport development and the resulting delay in addressing capacity constraints, and therefore safety concerns.

Response to Questions Posed by the Inquiry [Note that Questions from the Inquiry are shown in Italics]

Q1. What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented? 1.1 The White Paper forecasts have been relatively accurate in terms of predicting overall passenger growth but there has been substantial change since 2001 in the traYc distribution across the UK arising from impacts of 9/11 and the growth in the low cost carriers. These distribution eVects would not have been taken into account in the 2000 forecasts on which the conclusions of the White Paper were made. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Q2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for air traYc control?

Increased Complexity

2.1 The main concerns here relate to the increasing complexity of the controller task, and the increasing reliance on safety net systems (eg STCA and TCAS), which were originally designed as an extra layer, but have now become embedded as part of the whole risk management strategy. 2.2 Regarding complexity, our concern is that as the controller task becomes more complex and he/she has to increasingly rely on computer tools (such as FACTS, being developed by NATS), so the ability to revert to manual mode becomes more problematic. Whilst ATC systems have become more reliable over the years, they are not immune from failure, as evidenced by the recent computer problems at Swanwick on 25th September. Once the system becomes so complex such that the air traYc controller can no longer hold the picture in his head, the impacts of a computer failure become much more problematic. It is akin, when driving, to placing too much reliance on a satellite navigation system, without actually following where one is. For example, there are many recorded incidents of drivers blindly following their sat-navs and turning onto railway lines. 2.3 Regarding safety net systems, the risk classification of an Airprox is largely determined by the closest point of approach of the two aircraft concerned. If two aircraft are inadvertently on conflicting paths, but minimum separation is never eroded, due to activation of a safety net (eg through the pilot’s response to his TCAS or to instructions from ATC), the risk of collision will be deemed low. But this risk classification applies to that incident only—the fact remains that the causal events of the incident happened and could happen again when no safety nets are present. We believe it is important that these underlying trends are monitored in order that the true risk of increasing airspace complexity can be estimated. Another good example would be level busts, where an aircraft climbs or descends to the wrong flight level. If there is another aircraft in the vicinity at the same flight level, it might result in an Airprox, but if there happens to be no other aircraft present, it is deemed of no risk. In both cases, an error has occurred but in the second case it was just fortuitous that no other aircraft was present.

Safety in Uncontrolled Airspace

2.4 We strongly support the Airspace & Safety Initiative (ASI) set up jointly by the CAA, NATS, the Airport Operator’s Association, General Aviation and Ministry of Defence. We also support the developments regarding Air TraYc Services Outside Controlled Airspace (ATSOCAS). Uncontrolled airspace is being increasingly used by commercial flights from regional airports and it is critical that similar levels of safety can be assured compared to controlled airspace. 2.5 We believe the priorities for the ASI and ATSOCAS are to find feasible solutions that will allow the extension of the mandatory carriage of Mode S Transponders and TCAS to as many aircraft types and airspace users as possible. Carriage of a Mode S Transponder is critical for the detection of airspace infringements (a current concern to NATS, CAA SRG and Eurocontrol SRC), and for the detection by STCA and TCAS safety net systems. Carriage of transponders would also help alleviate radar return interference concerns from the development of Wind Farms.

Civil/Military Issues

2.6 In terms of civil/military ATM co-operation, we believe that the UK model is one of best practice within Europe, but this is an assertion without proof. There are incidents where military aircraft infringe controlled airspace or incidents arising from the Flexible Use of Airspace where civil aircraft infringe danger areas. We believe these incidents, along with all civil/military Airproxes should be separately monitored and trends established. Whilst the Airprox Board and MOD do an excellent job of investigating individual incidents, it is equally important that the trends in the underlying causes are identified and shared.

Incident Reporting

2.7 It is very important that the “just culture” for reporting of incidents is maintained. The UK again leads by example, but there are many countries in Europe where incident reporting falls short of even minimum requirements. The UK needs to continue to support the Eurocontrol and ICAO initiatives on this and use its influence to ensure that just culture becomes enshrined in European Law. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Unmanned Aerial Vehicles (UAVs) 2.8 We are aware of a number of initiatives on this important subject in the UK and Europe, including within Eurocontrol, NATO and the European Defence Agency. We are not aware however of how “joined up” these initiatives are. The use of UAVs is growing and represents a potential safety hazard for the future. We believe that the results from these initiatives should be shared so that the potential failure modes of UAV operations can be understood. Airworthiness, Operations and ATM regulations need to be developed at the European level through EASA.

Very Light Jets (VLJs) 2.9 There are similar concerns over the safety of Very Light Jets and the impact these will have on the complexity of the controller task.

Q3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently? 3.1 This would be a good idea but unfortunately is not feasible. Until firm airport development decisions are made for the South East of England, it would be impossible to produce an airspace management plan. For example, the impact of a second runway at Stansted and/or a third runway at Heathrow would be so substantial that a whole new airspace pattern over a significant part of the UK would be necessary.

Q4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? 4.1 Safety is also an issue here. Whilst environmental concerns are legitimate, safety considerations should be paramount. The airspace planning consultation process (CAP725) is becoming ever more protracted. It is increasingly diYcult to develop routes that satisfy conflicting environmental needs to avoid both tranquil and built-up areas. The need for route development, coupled with the provision of additional airspace capacity, arises in response to increasing complexity and congestion. The latter can quickly become safety issues, if the provision of additional capacity is delayed due to the protracted consultation process.

Q5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? 5.1 No safety-related comments to make on this issue.

Q6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? 6.1 Stacking is a safety issue as well as an environmental one. In terms of runway utilisation, Heathrow and Gatwick are the most eYcient dual and single runway airports in the world, but this comes at a cost of congestion, delay and reduced resilience to unplanned events such as strikes, adverse weather and terrorist incidents. Stacking is necessary to ensure that queues are maintained and that the runways remain fully utilised, but this level of utilisation also means that inter-arrival times are reduced to a minimum, thereby eroding the safety margin for error. 6.2 The congestion and stacking issue can be tackled in one of two ways, either through changes in air traYc management (ATM) or by increasing the available runway capacity. 6.3 The increasingly protracted planning enquiries to provide additional runway capacity in the South East mean that the current congestion at the London airports has become the “accepted norm”, rather than the “imperative to address” that it should be. If there was a mid-air collision due to airspace congestion in the South East, it would more likely result in a call to impose reduced runway utilisation rates (ie treating the symptom) rather than providing the impetus to build new runways (ie addressing the cause). But this would be the wrong response, since if new runways were provided, part of this additional capacity could be used to improve resilience and safety margins by reducing the need for stacking. It would be important to safeguard this element of the additional capacity against the commercial pressures to increase utilisation rates to cover the pent-up demand. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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6.4 In terms of ATM, NATS needs to press ahead with the development of their Future Area Control Tools Support (FACTS) system. In addition, the Government needs to continue to provide support to the development of the European Single European Sky and the implementation of the ATM Master Plan developed under SESAR. These long term initiatives are all aimed at developing new concepts of operation that will impact on “gate to gate planning” with just in time arrivals that will reduce the need for stacking.

Q7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties-Department for Transport, the CAA, airport operators, NATS, etc-appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play? 7.1 Yes, it is important that, as part of the CAA, the Directorate of Airspace Policy oversees the process to ensure an equitable treatment of all airspace users.

Q8. Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? 8.1 The following principles should be adopted. Decisions on airport development need to be made first. This provides the certainty of the airspace management task. Whilst ATM feasibility issues need to be considered when making decisions regarding airport development, more detailed ATM design should be completed while the additional airport capacity is being built. Trying to do detailed design at the decision phase would be costly and potentially a waste of time. It would add to the procrastination over decisions, further lengthening the status quo over capacity while demand increases, leading to further congestion and the reduction of safety margins.

Q9. What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined? 9.1 Bicycles, cars and buses all adopt the same rules of the road, and airspace users should do the same in terms of airspace. While cost and feasibility issues of safety equipage are important considerations for recreational flying, the safety issues should be paramount. The consequences of a mid-air collision between a B737 and a Cessna 400 are fatal to both parties.

Q10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? 10.1 Yes, see response to Q8.

Q11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? 11.1 As long as airspace changes are done equitably, all airspace users should contribute to the costs of the changes. This should be achieved through the airspace user charge. 11.2 Airspace change provides benefits to all users in terms of reducing complexity and route ineYciencies, and in increasing safety. But it is recognised that not all airspace users will receive the same benefits from airspace change, and for some, the costs associated with additional equipage required may be proportionally larger. In this respect, the weight factor in the airspace user charge should be maintained in order to reflect both the ability to pay and the cost/benefit ratio of the change to each user. October 2008

Memorandum from the Guild of Air TraYc Control OYcers (GATCO) (AIR 16)

1. Executive Summary The bullet points below provide a high level summary of the GATCO input to the inquiry by the House of Commons Transport Committee into the use of airspace. — GATCO believes that the 2003 White Paper and associated Airport Master plans will require significant development of UK airspace in the near future. Such development will need appropriate levels of funding and resource in order to be progressed in a timely and eVective manner. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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— The economic downturn is likely to result in an interim decrease in Air TraYc Movements. This will have the eVect of delaying growth in demand by a couple of years, in the opinion of the Guild. — Safety is paramount in the provision of Air TraYc Control and the handling of aircraft in UK airspace. GATCO believes that adherence to well established Safety Management Systems, monitored by an independent safety regulator, is key to ensure that the excellent safety performance in the UK is maintained as airspace is further developed. — Safety, eYciency, capacity and improved environmental performance are now the key drivers behind airspace change. In the past, the main driver has been capacity with resectorisations being the principal way of achieving improvements. The focus is now on improving the eYciency of existing sectors. — GATCO believes that an airspace master plan, developed and maintained by those responsible for managing the airspace, namely the Air TraYc Service Providers in general and NATS in particular, would enable a cohesive approach to future airspace development. — The Guild recognises the rise in profile of environmental performance, including noise, emissions and visual pollution. However, the guidance for taking environmental factors into account when developing airspace is subject to frequent change and is lacking in prescriptive content. Clear policy on this subject is needed. — GATCO is concerned that the airspace change process is unduly complex, requiring significant amounts of time, investment and resource. It is believed that the complexity and sheer size of the process may deter some smaller Air TraYc Service Providers from instigating airspace change. This may mean that potential safety benefits are not being realised. — The Guild sees the role of new technologies and concepts, such as Arrival Management (AMAN) systems, Performance Based Navigation, Continuous Descent Approach and Controlled Time of Arrival, as being key to progressing improvements to the management of UK airspace in the future.

2. Introduction and Scope

The Guild of Air TraYc Control OYcers welcomes the opportunity to provide input regarding the use and management of airspace. This paper constitutes the GATCO response to the House of Commons Transport Committee’s inquiry into the use of airspace.

3. Discussion

3.1 Question 1

What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented?

The demand portrayed in the 2003 White Paper is determined by forecast growth and by the intentions outlined in various airport master plans. These master plans are normally progressed in isolation from surrounding airspace and tend not to take airspace constraints or issues into account. The recent downturn in the economy is having an impact on the demand for air travel. Some operators have also ceased trading as a result of financial diYculties. This has resulted in the number of Air TraYc Movements starting to decline. GATCO believes that the impact on airspace demand has eVectively been put back by two years. However, the content of the airport master plans makes it clear that significant development of UK airspace will be required to support such plans.

3.2 Question 2

Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for air traYc control?

GATCO’s view is that safety must be maintained as airspace is increasingly utilised. It is always paramount to ensure the safety of aircraft and the people that they carry. The safety culture and systems used in the management of the UK airspace are probably the best in the world. The continued application of the Safety Management Systems (SMS) used by the Air TraYc Service Providers in the UK, together with the regulation of these SMS by the CAA’s Safety Regulation Group should ensure that safety is maintained. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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As safety must be ensure, the use of airspace must be regulated on both a tactical and a strategic basis to ensure that the amount of traYc utilising the airspace is not allowed to get to levels that cannot be safely handled by the Air TraYc Control system. The Air TraYc Service Providers, especially NATS in the en-route environment, together with the regulatory authority, Director Airspace Policy, are fundamental in achieving this. The interface between military and civilian Air TraYc Control is generally of a good standard in the UK. Some of the area functions are conducted from a single, integrated operations room, namely the Area Control Room at the Swanwick centre. Arrangements, such as Airspace Management Cell, ensure that the use of joint airspace is coordinated between civil and military ATC. Flexible Use of Airspace is already practiced in the UK, ensuring that airspace is shared in an eYcient manner between military and civil users.

3.3 Question 3

Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently? GATCO believes that the planning of UK airspace has been undertaken in the past in response to increasing demand. The planning of airspace developments has previously been focused on providing additional capacity and resectorisation, ie the division of a given volume of airspace into multiple sectors, has been a key means of achieving this. However, the benefits of resectorisation are now reducing due to diminishing returns as there is a finite amount of additional capacity to be had from splitting into more sectors. The way forward for capacity gains is through improved eYciency of the finite airspace in the UK. The historical focus on the provision of additional capacity is now changing as new factors need to be taken into account. Safety continues to be paramount in any airspace development. An increased interest in environmental issues means that consideration to environmental factors, such as noise, emissions and visual pollution, is now a core component of airspace development. Planning airspace today consider changes as a three legged stool, with the legs being safety, capacity and the environment. The Guild believes that an airspace master plan for airspace developments is required for the future, rather than the piecemeal approach that has been adopted in the past. However, the owners of this master plan should be those who have the expertise to produce such a plan and the capability to implement the changes that it calls for. GATCO suggests that such a master plan should be in the remit of the Air TraYc Service Providers, and that NATS, as the largest ATSP is probably best placed to develop and own such a strategy. Any proposed airspace master plan should be progressed in conjunction with the latest information available as to the intentions of airport development.

3.4 Question 4

How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? Environmental factors, including aircraft noise and emissions, have rapidly risen up the list of considerations when designing airspace. Draft guidance is available from the Civil Aviation Authority for environmental considerations. However, the guidance is still “woolly” and provides little in the way of actual hard and fast criteria that could be adhered to and subsequently measured against. GATCO believes that guidance for environmental considerations should be developed further so it is no longer “draft” but becomes actual policy, containing published criteria that can be taken into account when developing airspace and that can subsequently be used to measure environmental performance against. GATCO feels that the draft guidance that is available is overly protective of the environment, forcing new airspace developments to be designed in such a way that are not ideal from the perspective of applying Air TraYc Control, nor from the operating eYciency of the airspace users. The established consultation process is complex and requires a lot of time, resource and money for a consultation to be undertaken in compliance with the process. The sheer size and cost of the task may, GATCO believes, deter some Air TraYc Service Providers from attempting to develop their airspace. This is detrimental, as airspace developments on the whole improve safety,eYciency and capacity.The consultation process should be made simpler, thereby allowing for Air TraYc Service Providers to progress developments more easily, especially when there is a safety driver behind the change. The Guild’s position is that environmental issues should never be permitted to compromise the safety of Air TraYc Control and aircraft in general. For instance, runway selection for environmental reasons should not be undertaken if it results in a reduction in safety. An example could be a runway being selected without a Precision Approach capability in marginal weather conditions due to noise considerations. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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3.5 Question 5

How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? GATCO believes that there is an integral link between the UK and the rest of Europe as far as airspace is concerned. The presentation of traYc between the UK and the adjacent airspace volumes is critical. General flows of aircraft need to be co-ordinated on a regional basis. Many airspace developments in the UK will have a significant impact on flows of traYc to and from continental Europe and vice versa. Large airspace developments, especially in the South East of the UK or in the en-route area environment, need to be co-ordinated with adjacent Air TraYc Service Providers. Airspace development projects are often set up to include the States/Air TraYc Service Providers that will be impacted. In addition, there are various groups at Eurocontrol where such developments can be discussed. The Guild supports the concept of Functional Airspace Blocks (FABs), on the proviso that they are established to provide clear operational benefits, rather than for other non operational reasons, eg cost reduction.

3.6 Question 6

What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? There are numerous new concepts and technologies that are in the process of being developed. Programmes such as SESAR will be instrumental in progressing these R&D activities, resulting in interoperable procedures and systems being rolled out throughout the core European area. The deployment of Arrival Management (AMAN) systems will assist in smoothing the delivery of traYc into UK terminal airspace. By metering traYc through fixes, enabled by earlier planning and control of inbound aircraft, the bunching that currently occurs can be largely eliminated. Metering can be achieved by Air TraYc Controllers providing tactical instructions, namely speed control or path stretching, to aircraft. An emerging capability on board aircraft is to operate to a Controlled Time of Arrival (CTA). For aircraft that have such a capability, the controller would simply issue a time to pass through the metering fix and the Flight Management System on board the aircraft would then adhere to this constraint (assuming it is a realistic one in the first place). Any residual bunches can be further smoothed by the deployment of techniques such as RNAV Point Merge, which may oVer a viable alternative to the use of the low level holds that are in use today around the busiest UK airports. The use of Performance Based Navigation, such as Precision Area Navigation (P-RNAV), enables routes to be spaced closer together. This in turn improves the eYciency of the airspace and can raise capacity through a given sector. RNP approaches may also oVer an opportunity to undertake simultaneous Continuous Descent Approaches to closely spaced parallel runways, such as those in use at Heathrow. Such use of new technology/concepts would enable capacity to be increased whilst reducing the environmental impact at the same time. Whilst some aircraft are currently capable of conducting the procedures outlined above, it is important that the vast majority of aircraft are able to do so in the future. For this reason, GATCO encourages the consideration of applicable mandates in order to enable a position to be reached whereby the vast majority of airspace users are suitably equipped.

3.7 Question 7

In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play? Through its regular liaison with the Department for Transport, the CAA, NATS, other Air TraYc Service Providers and airport operators, GATCO is in a good position to understand the roles and responsibilities that each of these parties has with regard to the redesign of UK airspace. However, the Guild can understand why other organisations and the public at large may not have this same level of visibility regarding who does what when it comes to airspace redesign. GATCO notes the extensive eVorts made during recent airspace developments and associated consultations to try and engage with organisations and the public and to make them aware of the roles and responsibilities of the main parties involved. Whilst the Guild welcomes such eVorts at increasing visibility of the processes being followed, there is a perceived danger that the sheer size of the airspace development/ consultation process may get to a point where it becomes very diYcult to progress any change at all. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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3.8 Question 8

Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? The Guild is not in a position to provide a detailed answer to the above question as it has limited involvement in planning processes around airport developments. However, the perception is that if airspace management considerations are not taken into account at an early stage in the planning of airport developments, then airspace constraints can have a significant impact later in the process. GATCO would welcome the inclusion of consideration of the potential impact on airspace and its management when airports are developing their master plans.

3.9 Question 9

What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined? There is a finite amount of airspace available in the UK and it is under considerable pressure from a variety of airspace users, particularly in the South East. There is a pressing need to safely grow capacity at the main airports in the UK in a manner that minimises the impact on the environment. The limited amount of airspace makes it a challenge to accommodate the requirements of all airspace users at all times. Due to this competing demand for airspace, there is a need to ensure that all airspace users have a fair and equitable access to it, as far as is reasonably practicable. Air TraYc Service Providers attempt to ensure fair and equitable access to all airspace users, but the practicalities of ATC mean that it is necessary in some instances to restrict the use of certain airspace to certain users. The airspace regulator, Directorate of Airspace Policy, has a key role to play in ensuring that any airspace change is subject to consultation and that access to airspace is provided on a fair and equitable basis as far as is reasonably possible.

3.10 Question 10

Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? The Guild believes that there are relatively low numbers of ATC staV with the expertise and knowledge to undertake large-scale, often technically complex, airspace developments. In addition, it can be problematic gaining the release of operational controllers from their core ATC tasks to assist in airspace developments. This is due to a general overall lack of qualified Air TraYc Controllers. This limitation in number of suitably qualified people will make it diYcult to continue progressing airspace developments in parallel with the demand from the drivers of safety, eYciency, capacity and the environment.

3.11 Question 11

Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? Airspace is a national asset. It is used by a wide variety of users, including the military, general aviation and commercial operations. GATCO believes that some changes in airspace that are required because of national policy or in order to support government decisions should be paid for from a central fund, in a similar way to the funding provided for other national infrastructure assets. Smaller changes to airspace required by specific airports, airspace users or Air TraYc Service Providers should be funded by either by the instigator of the change or by the end user through existing charging mechanisms, such as the en-route charging facility. Airspace development is a fairly costly exercise, due to the necessary conduct of simulations and the consultation process. However, when compared to the costs of maintaining and developing other national infrastructure assets, the cost of airspace change is put into perspective. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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In order to obtain the perceived safety, eYciency, capacity and environmental benefits from airspace development GATCO encourages that appropriate levels of investment are made. There are significant challenges to the development and management of UK airspace in the near future and it will be necessary to provide appropriate funding and resource to handle these challenges. November 2008

Memorandum from The 2M Group (AIR 17) The 2M Group would like to respond to the announcement by the Transport Select Committee on the 21st July 2008 that it will be conducting an inquiry into the use of airspace. This submission reflects the concerns expressed by elected representatives of the 2M group about the way in which proposed changes in airspace are currently managed in the United Kingdom. These concerns arise both from the way in which aviation transport policy has been formulated in the 2003 Air Transport White Paper and from experience gained from recent proposals for airspace change around London and The Home Counties—Terminal Control North (TCN). 2M believes there are major flaws in the airspace change consultation and decision making processes. The flaws remain despite previous comments and recommendations of the Select Committee and a root and branch review of the CAA by the Government as recently as July this year. 2Ms concerns can be summarised as follows: (a) Lack of democratic accountability for airspace change decisions. (b) Lack of a true appeal process before an independent tribunal in relation to DAP decisions following airspace change consultation. (c) No apparent vision for future airspace needs. (d) Fundamental flaws in the NATS/CAA airspace change consultation process. 2M has detailed concerns about each of the above matters which are amplified below.

(a)Lack of Democratic Accountability

The Select Committee has noted this anomaly on a previous occasion in 2006. Airspace changes can and do adversely aVect the quality of life of thousands of UK citizens. Decisions of this magnitude should be subject to close parliamentary scrutiny and the accountability for the impact of such changes belongs at an appropriate level in government. 2M believes such responsibility should rest with the Secretary of State for Transport. The current arrangements which vest the executive decision for airspace changes with an unelected CAA oYcial (The Director of Airspace Policy) are considered undemocratic. The fact that DAP appointments are made by the Secretary of the State under published guidelines does not in the view of 2M provide the required amount of accountability. 2M believes that in this respect the Transport Act 2000 is badly drafted and should be amended.

(b)Lack of Appeal Process to Air Space Changes

This is a related point on natural justice on which the select committee has also previously commented. Currently it is only possible for potentially aggrieved parties to a proposed airspace change to challenge the proposals by way of Judicial Review. As both the committee and the subsequent Pilling Report have confirmed the Judicial Review process is limited in scope. Few applicants succeed where the courts judge the challenge to be on merits issues or matters of scientific debate or opinions between experts. An example of the diYculties that were faced by potential litigants in the recent TCN consultation relates to the use by NATS of out of date noise information and failure to base its assessment of noise impact on the latest government noise study. For this consultation NATS relied the current (2007) version of CAA 725 “Guidance on the Application of the Airspace Change Process” in order to formulate an environmental impact assessment for the TCN proposals. However CAP 725 relies on 25-year-old research with respect to community annoyance and aircraft. There is increasing evidence (including the government’s own 2007 ANASE study) to suggest that people are more sensitive to aircraft noise than was the case 25 years ago. This also applies to the perceived impact of aircraft, even at quite high altitudes, on tranquil areas which become newly overflown on a regular basis. Conventional wisdom on this issue as described in CAP 725 is now out of date. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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(c)Flawed Airspace Change Consultation Process The Select Committee has also previously commented on the Airspace Change consultation process. 2M is concerned that the NATS promise of a “new style” consultation in 2008 simply did not materialise in the recent TCN consultation. The consultation documentation was impenetrably complex for local people. It was also beyond the levels of expertise and comprehension of many local authority oYcers. The documentation was in fact very similar to that produced by the 2006 Terminal Control South West (TCSW) proposals in 2007. The TCN consultation was further complicated by NATS relying on local authorities to in eVect coordinate local consultation. NATS personnel unhelpfully refused to attend local public meetings organised by local authorities, instead oVering to “brief” senior local authority oYcers on the proposals. However much of the documentation was so complex that it could not be unpacked by the local authority oYcers concerned within the timescale allowed for the consultation. A number of local authorities incurred expenditure in employing consultants to work through the vast amount of data on noise for example in order to understand what impact the proposals were likely to mean in noise terms for communities newly overflown. Arguably the TCN consultation did not even comply with the NATS guidelines as set out in CAP 725, no alternative solutions being oVered to the main proposal. For example no investigations appeared to have been made into the possibilities of “stacking ” aircraft beyond the UK coast rather than over land.

(d)Lack of Vision for Airspace Requirements 2M is concerned that changes in UK airspace are being made in piecemeal fashion, often with what appears to be for minimal gain in capacity but to the detriment of many who find their homes and areas tranquillity adversely aVected by overflying aircraft. Meanwhile the bigger picture in terms of what will need to happen in order to realise the sort of airspace capacity envisaged in the Air Transport White Paper (ATWP) remains outside the public domain. Many communities will it seems remain in the dark about future airspace changes until an airport operator decides to submit a formal planning application for terminal or runway capacity. It seems that it is only at this time that indicative airspace change proposals may be identified as part of the Environmental Impact Assessment. However air space change assessments currently fall outside of the matters to be determined by an inspector through the planning inquiry process with NATS/CAA conducting a separate consultation within the CAP725 assessment framework. This in eVect means that airspace proposals produced for environmental assessment purposes can only ever be regarded as indicative and the extent to which the merits of the proposals can be tested through the public inquiry process is questionable. The Government has recently consulted on a range of initiatives for expanding Heathrow. These include proposals for the airport operator to adopt “Mixed Mode” operations. It is believed that this could happen as soon as 2010. Currently no information has been put in the public domain to inform residents what airspace changes will be required should the go ahead for mixed mode be given. 2M is also concerned that the potential future influence of the European airspace agency (Eurocontrol) over UK airspace has not been spelt out in either the ATWP or any of the recent government consultations. Currently there appears to be little joined up thinking between the UK aviation policies based upon expansion and the EUs plans for airspace provision. 2M believes that a Master plan is therefore required for future airspace provision. October 2008

Memorandum from Great Thurlow Parish Council (AIR 18) We hereby submit our observations as follows: 1. Points of acceptance. 2. Objections. 3. Suggestions. 4. Conclusion.

1. Points of Acceptance (a) As a generalisation we accept the necessity for civil flying and the opportunities created for cheap air travel and employment. (b) We accept that safety is of prime importance and emergencies are excepted. (c) We accept that the location of various airports is fixed. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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2. Objections The area of contention for us is the principle of “stacking”. We feel that to “pile up” a number of aircraft in a “hold” over a very specific and local area is both anti-social and unnecessary. Specifically we are concerned by the plan to create the hold for the Western Approach to Stansted. The disturbance over an area recognised for its peace and tranquillity will be unacceptably intrusive and detrimental to the local community, tourism and the extensive and valuable equine industry. Stacking results in a notable decrease in quality of life for a concentrated few. We are prepared to suggest alternatives to stacking that would result in a barely perceptible diVerence in air traYc to a larger number of people on the ground.

3. Suggestions (a) Our suggestions for solving the problems of stacking commence with the basic fact that Stansted is only some 40 miles from the coast. At a speed of 240 miles per hour this is only about 10 minutes flying time. Are we to believe that the air traYc controllers do not know before those 10 minutes that an aircraft will be early? The answer therefore must be that a turn or circuit could be made over the sea, especially as the greatest proportion of flights into Stansted are coming from Europe. (b) If you claim that the sea is too far from Stansted, why not “take a turn” over a non specific area? The air space over East Anglia is vast and the area is multiplied many times if you use it in layers, say tenfold, in two thousand feet increments from 7K to 27K. The region is not that saturated with air traYc, particularly as you claim stacking will only be used occasionally at peak times. If all aircraft were fitted with transponders to fly over say 5000 feet, air traYc control would know where potential problems were. This would mean that the chances of any specific area having more than one aircraft overhead for an unacceptable period would be minimal. (c) In anticipation that both of the above suggestions answers to the above are unacceptable, we oVer a further option for consideration—create a “holding zone”, say five miles wide, either side of the approach flight path and allow aircraft to circle (hold) in a number of sites progressively along the flight path. In layman’s terms rather like the eddies behind an eights rowing boat at speed (four either side). We enclose a very basic plan to show how an area of about ten miles by forty miles, astride the approach flight path could provide eight “holds”, those to the left are suYxed L and those to the right are suYxed R. The number refers to the height in feet. It would be possible to overlay a second holding zone with the eight say four thousand feet higher, ie AR9, BR11, CR15 etc. From an operating viewpoint, by definition no aircraft would be on the flight path during holding operations; no aircraft would be more than five miles from the approach flight path, aircraft would “move along” holding zones from D to A and at the same time descend in increments of 2000ft to the airport as called by air traYc control. This simple scheme generates sixteen holds thus greatly diluting the intrusion on the ground. The areas that would be aVected by holding noise are already adjacent to the existing flight paths and are therefore already subject to some disturbance.

4. Conclusion We apologise for the “layman’s” nature of this submission but our observations are based on common sense. We recognise that these proposals would need adjusting and modifying by the experts but are oVered as a basic starting point as a preference to a stack. We do not feel confident that NATS have explored every option to avoid stacking and they have taken the easy, quick and previously accepted option. With greater problems, better solutions are needed. October 2008

Memorandum from the National Trust (AIR 19)

Summary 1. The National Trust welcomes the Committee’s inquiry into the use of airspace. Over the past year the National Trust has been actively involved in discussions with the National Air TraYc Service (NATS), the Civil Aviation Authority (CAA), the Department for Transport, Local Authorities and many local community and environmental organisations regarding the impacts of the proposed changes and the long term future of airspace management and aviation growth. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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2. The current TCN proposals would have a direct impact at a number of National Trust properties including Osterley Park, London; Wimpole Hall and Wicken Fen, Cambridgeshire; Ickworth Hall Estate, SuVolk and the Ashridge Estate and Coombe Hill in Buckinghamshire. These sites receive approximately 1,500,000 visitors a year who value these places for their tranquillity and the opportunity they oVer for people to get away from the intensity of modern life and ‘recharge their batteries’. 3. The National Trust is particularly concerned that the current proposals will significantly undermine people’s ability to benefit from these tranquil places and that the frameworks within which airspace is managed do not adequately address this. 4. In order to reconcile an increasingly important, complex and controversial area of public interest The National Trust considers that there is a need for the following key actions: (i) A new participative public debate about the positive and negative impacts of aviation expansion and airspace management which would lead to a new set of policies and guidance with broad public support and understanding. (ii) The development of a new model for assessing the environmental impacts of aviation and airspace management including an improved methodology for measuring tranquillity which reflects the public’s view on what is intrusive rather than relying wholly on scientific measures. (iii) An immediate assessment of the potential impacts of ‘gate to gate’ and other related technology on public green spaces and sensitive natural and historic environments in order that these factors can be fully embedded in the development and implementation of any new air traYc control systems and processes. (iv) A review of the role, responsibilities and ownership of the National Air TraYc Service. (v) The modernisation of the structures and accountability of the Civil Aviation Association in line with the recommendations of the Pilling review including the introduction of a clear responsibility in relation to the environment. 5. At the heart of many of these issues is the unsustainable growth in aviation. The National Trust endorses the findings of the Sustainable Development Commission report, Breaking the Holding Pattern and believes that there is an urgent need for a rethink of the Government’s aviation policy and its impact on people’s quality of life. By taking a step back and examining these issues the proposed review will help Government take account of the aviation sector’s contribution to the UK’s climate change targets as well as balancing the wider set of public policy issues.

The Role of the National Trust 6. The National Trust is Europe’s largest conservation body with over 3.5 million members, 50,000 volunteers, an annual turnover approaching £400 million and a presence throughout England, Wales and Northern Ireland. We currently protect and manage on behalf of the nation over 250,000 hectares of countryside and 1,100km of coastline together with a significant proportion of the country’s designated sites and buildings of historic significance. This includes six World Heritage Sites, over 6,000 listed buildings, 1,200 scheduled ancient monuments, 149 registered museums and 8% of all registered historic parks and gardens. 7. Our property portfolio is hugely diverse, ranging from some of the nation’s most iconic and well- known sites to some of the more ordinary and everyday elements of our rich and diverse cultural heritage.

Demand and the White Paper 8. The National Trust’s discussions with NATS and our response to the consultation on changes to the Terminal Control North area have highlighted our concern that the current proposals for the management of airspace have not adequately taken account of the increase in flight numbers that would be associated with airport expansion, whether increasing the number of runways at Heathrow and Stansted or increasing runway capacity through changing the operation of existing runways. 9. We are extremely concerned that given the four years it has taken NATS to develop the existing consultation proposals which only cope with incremental growth, the further expansion of aviation will see significant impacts on highly valued green spaces and sensitive historic environments. 10. Assuming safety is not to be compromised, under either the incremental or step change growth planned within the Air Transport White Paper, it seems likely that even less weight will be given to the impact of aviation on natural green spaces or people’s quality of life generally when managing airspace in the future. 11. The National Trust believes this is wrong and that there a number of public interest issues beyond simply satisfying the demand for air travel and that greater weight should be given to these factors when considering the routes and density of flights as this would better reflect the balance of public interest. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Safety and Military uses

12. The National Trust is not well placed to comment on the issue of the interface between military and civil aviation arrangements other than to say that military uses of airspace also have impacts on people’s quality of life and the tranquillity of green spaces across the UK. It is therefore important that the impact of all airspace users are considered together rather than in isolation. 13. We recognise the paramount importance of maintaining safety standards however we would draw the committee’s attention to the wider impacts that may result, in particular the impacts on people’s quality of life and the loss of tranquillity in the countryside and at important historic sites. 14. In order to balance these interests it may be necessary to more fundamentally review the numbers of aircraft using UK air space.

Planning and Regulation

15. The National Trust believes that the current approach to planning and regulating the use of UK airspace is inadequate and has fallen well behind the standards adopted in other areas of public policy such as the land use planning system. 16. The current policies and guidance have insuYcient detail on: (a) a metric for appraising tranquillity, (b) a full and robust methodology for the appraisal of environmental impacts, (c) the requirement for an evidence base (as would befit an Environmental Statement), and (d) consideration of “issues and options” as would be required if this were a land-use policy matter, which reveal alternatives and give appropriate weight to a variety of options, including no change options. 17. We believe that a far better system is required on the formulation of airspace routing and that a necessary pre-requisite of this is that a more appropriate and thorough set of policies and guidelines is put in place. 18. These guidelines would need to provide a framework for the full and frank appraisal of impact upon issues such as landscape quality, numbers of people aVected and impact on tranquillity. 19. The key guidance document in relation to airspace management change is the Civil Aviation Authority’s Airspace Change Process (CAP 725). Whilst we recognise that the guidance does begin to address some of the issues highlighted above it does not provide suYcient balance or clear guidance on weighting and there is still an overarching assumption that change to facilitate increased capacity in the skies is a good thing. 20. The National Trust supports the fact that CAP 725 Appendix B refers to the guiding principles of the latest UK Sustainable Development Strategy (UK SDS). In section 1 para 8 the guidance states that for a policy to be sustainable it must reflect all five of the guiding principles of the UK SDS. 21. The TCN proposals will be an interesting test case for the strength of the guidance. We cannot see how the significant impact of these proposals on open green spaces, the lack of rigour applied to assessing the impacts of noise on tranquil areas, the lack of detailed consultation on the potential impacts and the increase in the number of people aVected by aircraft noise would respect any of the principles of: — living within environmental limits; — ensuring a strong, healthy and just society; — achieving a sustainable economy; — promoting good governance; and — using sound science responsibly. 22. We have also been surprised by the lack of any real requirement to put forward options or alternatives including an assessment of the no change option. For example, it would have been possible to have presented an option which highlighted the advantages and disadvantages of not making changes to the continuous decent approaches to Stansted which under the current proposals will have a significant impact on west London. 23. The proposals could also have looked at changes to the Bovingdon stack which could have given more flexibility to mitigate the impacts over the Chilterns. Whilst we understand that managing the airspace is complicated this should not be an excuse to operate on the very edge of the guidance and to provide no opportunity for the public or a publicly accountable body to make a judgement on which options are in the wider public interest. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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24. The National Trust understands that piecemeal development will lead to subsequent redesigns and that due to the complexity of the airspace small changes in one area could result in significant change and impact elsewhere. 25. We would again the highlight the importance of a more robust methodology for assessing impacts and for a much greater degree of public engagement in order to better understand how the public interest is best served.

The Effects of Aircraft Noise and Emissions 26. One of the factors raised in the recent work of the Sustainable Development Commission is the lack of agreement regarding the assessment of noise. The National Trust is extremely sceptical about the relevance of current methods used to measure noise. The Trust’s case, put forward at the recent Public Inquiry into the expansion of Stansted Airport, is that the increase of noise as indicated by noise contours based on decibels, takes no account of the impact in relation to the human appreciation of the ambient noise level, nor the frequency of that impact. For instance, an increase in noise level in a built-up area where the background noise is already subject to noisy influences would have a far less impact on the population than where the same level of increased noise to be transferred to a tranquil area of countryside. 27. As the Campaign to Protect Rural England has stated in its publication Saving Tranquil Places, published in 2006, “these tranquil places are important for our mental and physical health, our wellbeing and our economy”. A survey of 1,300 countryside visitors was used to explore people’s perceptions of tranquillity and the results informed the CPRE publication. The survey revealed that seeing low flying aircraft, and hearing low flying aircraft, were in the top eight responses of intrusions into tranquillity. 28. The National Trust recognises that the relationship between noise impacts, air quality and emissions is a complex one. For example flying aircraft in straight lines is more eYcient in terms of fuel consumption which reduces harmful emissions but might have a greater impact on tranquil areas just as reducing noise impacts by increasing the rate of ascent from an airport may worsen local air quality. 29. Striking the right balance will always be diYcult in these circumstances and it is because of this complexity that the National Trust believes there should be a more widespread and active dialogue designed to develop a new set of policies and guidance for making these judgements. 30. We would argue that the best people to help get the balance of public interest right are the public. As an appropriate approach to a complex area of public interest we would point to the relatively recent debate and formulation of policy around GM crops which was informed by an active public engagement programme.

The Application of New Techniques and Technologies 31. The National Trust understands that there may be environmental gains from the introduction of new technology, however, we would highlight the complexity of these environmental issues and would also draw the committees attention to possible negative impacts of introducing technological innovation. For example, whilst we understand that implementing PR-NAV may bring advantages in the eYcient and safe management of air traYc the introduction of or changes to PR-NAV routes in relation to easterly operations from Heathrow to the North and North East would have impacts on Osterley Park and the residents of the London Borough of Hounslow. 32. Technologies such as PR-NAV are designed to more accurately control the path of aircraft. Through discussions with the CAA we understand that this increased emphasis on predetermining flight paths is likely to the only way that airspace can be managed should aviation growth continue at its current rate. 33. We understand that within the next few years it is likely that a “gate to gate” system will be developed whereby aircraft will be given predetermined and computer controlled routes in space and time. As they pull back from the gate aircraft will fly this exact route until they pull up to the arrival gate. Whilst we understand that this would enable the eYcient use of airspace we are extremely concerned that such a system will take even less account of what is below the aircraft. 34. If such a system were to operate we believe that there should be a widespread public debate about the advantages and disadvantages of concentrating or dispersing aircraft and that in developing the “slots” in space and time there should be due regard for the impacts these will have on the public and the natural and historic environment below.

Roles and Responsibilities 35. Whilst a thorough reading of CAA CAP725 makes it reasonably clear where the roles and responsibilities of the various bodies lie, the National Trust considers that the structures or the parties are far from appropriate in terms of undertaking the roles that they are asked to fulfil and that the governance arrangements and degree of accountability within the sector are not appropriate for the scale and impact on public life. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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36. In relation to the National Air TraYc Service who are the principle proposer of airspace changes we are particularly concerned by the degree of influence exerted by the airlines and airport operators through their part ownership of the organisation. 37. We question whether it is appropriate that an organisation which is responsible for managing the eYciency of airspace and which therefore exerts significant influence on the quality of millions of people’s lives across the UK should be part owned by the aviation industry who have almost no responsibility or accountability for the impacts that their businesses have on the public’s quality of life in relation to noise and the value placed on tranquil areas. 38. Whilst we understand that a “Chinese wall” exists within NATS it also surprising that they should be asked to try and balance a wide range of public interests in terms of their quasi regulatory role in en-route airspace management whilst at the same time having to compete for the business, of their own owners, in terms of managing airspace movements within airport boundaries. 39. In relation to the Civil Aviation Authority the National Trust believes that whilst the organisation is clearly attempting to act in the wider public interest the organisational structures and accountability within the organisation are not fit for purpose given the growing impacts of aviation on public life. 40. The National Trust considers that the recent Report of the Strategic Review of the CAA by Sir Joseph Pilling is a thorough assessment of the situation and we would support his recommendations in relation to improving the structures and accountability of the CAA. 41. In particular we welcome the recommendation that the CAA should have a specific responsibility in relation to the environment. In order for it to successfully discharge any such duty we would recommend reviewing the way in which the CAA engages with the public and environmental organisations whether government agencies or NGOs. 42. Particular emphasis might also be given to the future make up of any executive or non-executive boards in order to ensure that the balance of environmental and social interests are represented at a strategic level.

The Planning System 43. The National Trust is not aware that air space management considerations delay the planning process, however, we do believe that airspace management issues should form an integral part of the process by which any planning decision is determined. 44. It would seem to make little sense to go to the expense of a major planning application with the associated public inquiry without fully understanding whether the development is deliverable in terms of airspace management or whether the required airspace management changes would have an inappropriate level of impact on people’s quality of life. 45. The National Trust is also interested in the relationship between airspace management considerations, the new IPC and the development of any NPS. We consider that airspace management should certainly be a consideration in the development of any NPS and that airspace management impacts should be a consideration for any developments considered by the IPC.

The Implications for Smaller Airfields 46. The impacts of smaller aircraft and airfields on the tranquillity of green spaces should not be underplayed. The low altitude and slow speed of these aircraft mean that they can have a disproportionately high impact in terms of noise. October 2008

Memorandum from the New Forest National Park Authority (AIR 20)

1. Summary — The New Forest National Park Authority’s main concerns about current and future projected use of airspace relate to the impact on National Parks and other protected landscapes. — The existing government guidance to the Civil Aviation Authority on environmental considerations, which is now six years old, must be updated to reflect the protection aVorded to National Parks in statute. — The airspace change process would also benefit from greater clarity regarding the roles of the Department for Transport, the Civil Aviation Authority, the National Air TraYc Services, the involvement of wider stakeholders in the decision making process, and the 12 month operational review. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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2. Introduction 2.1 The New Forest National Park Authority welcomes the Committee’s inquiry into the use of airspace and the opportunity to submit evidence. The National Park Authority has recently been involved in the Sustainable Development Commission’s review of aviation, culminating in the recent publication of Contested Evidence: The case for an independent review of aviation policy. The work of the Sustainable Development Commission highlights the need for dialogue before major decisions on the future of air travel in the United Kingdom can be made, and to this end the Transport Select Committee’s inquiry is particularly timely. 2.2 The New Forest National Park is located beneath some of Britain’s most congested airspace and the National Park Authority has recent experience of the airspace change process, following the Civil Aviation Authority’s endorsement earlier this year of the Terminal Control South West (TCSW) airspace change proposals. This change has resulted in the area of controlled airspace being extended over some of the more tranquil areas of the National Park, allowing aircraft to cross the New Forest at heights as low as 5,500 feet. The National Park Authority prepared evidence detailing the impacts the airspace change would have on the special qualities of the New Forest, and this experience highlighted a number of major areas of concern.

3. National Parks and Aviation Policy 3.1 Although the special status aVorded to National Parks and other protected landscapes in national legislation is mentioned within existing aviation policy,our experience is the impact on a protected landscape is aVorded little weight in current decision making. The Civil Aviation Authority is required under the Transport Act 2000 to take account of government guidance on environmental objectives in carrying out its air navigation functions. This guidance to the Civil Aviation on environmental objectives relating to the exercise of its air navigation function was issued by the Department of Transport in 2002, stating, “The Government’s aim is to give stronger protection to the most valued landscapes in designated national parks and areas of outstanding natural beauty. Therefore, whenever practicable the DAP should pursue policies that will help to preserve the tranquillity of the countryside where this does not increase significantly the environmental burdens on congested areas.”—paragraph 46. 3.2 Section 62(2) of the Environment Act states that in making decisions that could aVect National Park, relevant bodies (including the Civil Aviation Authority) must have regard to the two statutory National Park purposes as set out in section 5 of the National Parks and Access to the Countryside Act 1949, as amended by section 61 of the Environment Act 1995, namely: — to conserve and enhance the natural beauty, wildlife and cultural heritage of the National Park; and — to promote opportunities for the public understanding and enjoyment of the special qualities of the National Park. Clearly decisions over the use of airspace above National Parks can have significant impacts on the delivery of the two statutory Park purposes, and this has been highlighted by the recent Terminal Control South West Airspace decision aVecting the New Forest National Park. 3.3 The National Park Authority commends a number of recommendations in Sir Joseph Pilling’s recent independent review of the Civil Aviation Authority (2008). In particular, the Authority believes there is an urgent need to update the current government guidance on environmental objectives (which is now six years old), and the need for a clearer framework on how the CAA should reconcile competing considerations.

4. Inquiry Questions 4.1 Given the Authority’s recent experiences of the airspace process, responses are given to the following interlinked Committee questions.

Is the current approach to planning and regulating the use of UK airspace adequate?

How are the eVects of aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted? How should the balance between conflicting interests be struck? 4.2 The Authority’s recent involvement in the airspace change process leads it to conclude that the current approach to regulating airspace is inadequate in terms of the level of protection aVorded to National Parks and other nationally designated landscapes. Despite their legal duty to have regard to the statutory National Park purposes, the Civil Aviation Authority endorsed the TCSW airspace change that has resulted in aircraft crossing the National Park at heights as low as 5,500 feet. This decision places no limits on aircraft numbers using this new area of controlled airspace (although hours of operation are currently restricted), and the expansion proposals at Bournemouth and Southampton Airports will result in increasing aircraft movements at low levels over the New Forest National Park. The National Park Authority’s detailed noise impact assessment concluded that the impacts of the airspace change would be audible across the whole part of the National Park not previously overflown. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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4.3 The Authority is concerned that the existing Department for Transport guidance on environmental objectives (2002), which the CAA is specifically required to take into account, could be interpreted by the regulator in such a way as to allow it to reach this decision. In this context, the National Park Authority welcomes a number of recommendations in Sir Joseph Pilling’s report on the Civil Aviation Authority, in particular: (i) the Secretary of State should provide a framework which oVers guidance to the CAA on how to reconcile environmental and other competing considerations; and (ii) the Department for Transport’s guidance on environmental objectives in relation to the CAA’s air navigation functions should be reviewed to ensure that it continues to be up to date. 4.4 The New Forest National Park Authority would strongly support the Government taking measures to strengthen the alignment of aviation policy with wider government policy on protected landscapes. The current government guidance to the Civil Aviation Authority acknowledges the special status of National Parks, but goes no further. The guidance should be amended to ensure consistency with the Civil Aviation Authority’s statutory duty to have regard to the National Park purposes when making decisions. Although this duty does not override other obligations or considerations, it is intended to ensure that the purposes for which National Parks have been designated are fully recognised in reaching decisions that have an impact on them. 4.5 The whole airspace change process also lacks accountability under current arrangements. Civil Aviation Authority guidance on the application of the airspace change process (CAP 725, March 2007) makes it clear that an operational review should take place 12 months after the introduction of an airspace change, and that the Director of Airspace Policy “…may invite organisations aVected by the change to participate or contribute to the review . . .” The Civil Aviation Authority’s Airspace Charter (CAP 724, November 2007), confirms that, “. . . in particular it will be necessary to assess if the anticipated environmental benefits have been delivered.” The National Park Authority wrote to the Civil Aviation Authority earlier this year to request involvement in the operational review of the Terminal Control South West Airspace Change, given the legal duty the CAA have to have regard to Park purposes in making decisions, but this request was turned down. The Authority therefore has little confidence that the review will comprehensively review all of the environmental impacts of the change.

Is the allocation of roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS etc—appropriate and clearly understood? 4.6 The Authority’s involvement in the consultation and decision making process for the Terminal Control South West airspace proposals also illustrated the current lack of clarity over the roles of the Civil Aviation Authority, the National Air TraYc Services (NATS) and the Department for Transport. The relationship between NATS, as the proposer of airspace changes, and the Civil Aviation Authority—the regulatory authority responsible for approving changes—appeared close and external bodies looking to comment on the process had no sense of independent accountability. It was also not clear how the Civil Aviation Authority’s Environmental Research and Consultancy Department (ERCD) could have undertaken an independent environmental assessment of the airspace proposals while still being under the wing of the Civil Aviation Authority. 4.7 In terms of the role of the Department for Transport, the National Park Authority and many others wrote to the Secretary of State for Transport in early 2008 requesting that the Terminal Control South West airspace decision be referred to her given the potentially significant detrimental eVect on the environment the changes would have. This was seen as the only means of gaining public accountability of the airspace change process, but the request was again not acceded to.

5. Conclusion 5.1 The Sir Joseph Pilling Review and the Transport Select Committee inquiry provide a timely opportunity for the current shortcomings in airspace regulation to be addressed. The protection aVorded to National Parks and other nationally designated landscapes should be given the highest priority in government aviation and airspace policy. The opportunity should also be taken to review the airspace change procedure to ensure environmental considerations are given due weight through a transparent and publicly accountable process. October 2008 Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Memorandum from the Department for Transport (AIR 21) 1. The Department for Transport (“the Department”) notes that the House of Commons Transport Committee is conducting an inquiry into the use of airspace. The Department takes a keen interest in this issue whilst recognising that the planning and regulation of airspace is primarily the responsibility of the Directorate of Airspace Policy (DAP) within the Civil Aviation Authority (CAA), the independent aviation regulator. 2. The Future of Air Transport White Paper (“the White Paper”), published in 2003, set out the Government’s strategic framework for the development of air travel over the next 30 years. This balances projected travel demand from business and leisure sectors and the requirements of the UK economy with the need to have regard to environmental consequences of air travel. This sustainable approach: — recognises the importance of air travel to our national and regional economic prosperity, and that not providing additional capacity where it is needed would significantly damage the economy and national prosperity; — reflects people’s desire to travel further and more often by air, and to take advantage of the aVordability of air travel and the opportunities this brings; — seeks to reduce and minimise the impacts of airports on those who live nearby, and on the natural environment; — ensures that, over time, aviation pays the external cost its activities impose on society at large—in other words, that the price of air travel reflects its environmental and social impacts; — minimises the need for airport development in new locations by making best use of existing capacity where possible; — respects the rights and interests of those aVected by airport development; and — provides greater certainty for all concerned in the planning of future airport capacity, but at the same time is suYciently flexible to recognise and adapt to the uncertainties inherent in long-term planning. 3. The Government recognised that additional airport capacity would need to be matched by a corresponding increase in airspace capacity.That is why we looked to the CAA to bring forward a structured programme for the redesign of UK airspace that would help protect safety standards, relieve current constraints, take account of environmental impacts and accommodate the forecast increase in air transport movements where additional capacity was supported. 4. In December 2006, the Government published the Future of Air Transport Progress Report (“the Progress Report”) setting out progress in key areas. In terms of airspace capacity, it recognised that the Department would consider, with the CAA and NATS, the air navigation services provider, the impact of forecast growth on the South-East airspace as a whole in the period up to 2030. 5. The Government remains committed to the strategy set out in the White Paper which strikes the right balance between economic, social and environmental goals. We welcome this opportunity to set out how airspace capacity issues are being addressed. 6. The Memorandum follows the general order but with some grouping of the questions on which the Committee has invited evidence.

What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented?

7. The CAA’s DAP is responsible for the planning and regulation of all UK airspace and, in so doing, takes account of air passenger demand forecasts produced by the Department. 8. The forecasts of UK air passenger demand underpinning the White Paper were updated in the Progress Report. This noted that the 2003 forecasts had accurately predicted demand to 2005, and showed the forecast of significant growth in air passenger demand was robust to a range of sensitivity tests, including variations in economic growth and oil prices. The forecasts were again updated with latest data in the 2007 UK Air Passenger Demand and CO2 Forecasts report, which confirmed the forecast of significant demand growth. The 2008 CAA report ‘Recent Trends in Growth of UK Air Passenger Demand’ concluded that recent slower growth in air passenger demand is due to short term cyclical factors, not a change to the longer term trend of growth. The Department expects to publish new forecasts, taking account of latest economic projections, alongside the decision on the future development of Heathrow later this year. 9. The White Paper also invited airport operators to produce new or revised master plans explaining how their modernisation and development proposals would help inform regional and local planning processes, and how they would take account of local impacts and the wider environmental impacts of air travel. The Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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White Paper recommended that these should include details of the necessary environmental controls and mitigation plans, proposals for improved surface access, and, where appropriate, measures to address blight. In most cases, the masterplans did not address airspace requirements. The Department is aware that CAA and NATS are of the view that, were all of the south-east airport development plans to come to fruition, there would not be suYcient airspace capacity to accommodate the scale of predicted growth on the basis of current and predicted technology. However, airport masterplans are aspirational and it is unlikely that all airport developments will be implemented. Furthermore, we have worked closely with CAA and NATS to ensure that proposals for development at Heathrow and Stansted are fully workable. 10. Given the above, it is diYcult at this stage to quantify precise changes to the management of airspace that could be required as a result of the additional airport capacity outlined in the White Paper.

Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for air traYc control?

11. Aviation safety is the top priority for the Government, regulator and air navigation service providers. The CAA’s Safety Regulation Group (SRG) works in partnership with the industry to continually improve aviation safety in the UK and, in partnership with the European Aviation Safety Agency (EASA), across Europe. SRG’s strategic objective is to ensure that the UK’s excellent aviation safety performance is, at least, sustained at its present level. Its independent rigorous safety regulation of all UK air navigation service providers is increasingly becoming the world-wide model. 12. The European Commission published the Single European Sky II (SES II) package in June 2008 (Com(2008) 389). This package included the objective of establishing a single safety framework for Europe, centred on EASA, in order to improve safety levels alongside the increase in air traYc. EASA was established in 2003 and currently has responsibility for setting the regulations and standards for the airworthiness of aircraft, air operations and flight crew licensing. As part of the SES II initiative the Commission has proposed an amending Regulation to extend EASA’s remit to the safety of aerodromes, air navigation services and air traYc management. The Department is seeking views by 20 October on the proposed extension of EASA’s remit to the safety of aerodromes, air traYc management and air navigation services. The responses to the consultation will be taken into account in formulating the UK’s negotiating position during the legislative process in the Council and the European Parliament. 13. Under the Transport Act 2000, the CAA has an obligation to facilitate the integration of civilian and military air traYc management. The Civil Aviation Authority (Air Navigation) Directions 2001 require the CAA to oversee the arrangements between a licence holder and the MOD to ensure that air traYc services continue to be provided on a joint and integrated basis. The Joint Air Navigation Services Council (JANSC) is the principal means of achieving this aim. Currently, NATS is the only holder of an en-route licence and the JANSC acts as the forum for discussing and resolving diVerences of opinion between it and the MOD. The JANSC is chaired by the Director of Airspace Policy. This mechanism is highly eVective in continuing to improve the UK’s joint and integrated civil and military air traYc services to the extent that the arrangements are viewed as the model of civil/military co-operation for Europe. The UK’s civil/military interface is further enhanced by the co-location of civil and military units at the NATS London Area Control Centre in Swanwick and the Scottish and Oceanic Area Control Centre in Prestwick.

Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently?

14. The Government does recognise that airspace is a finite resource. Forecast traYc growth in both UK and European airspace as well as the development of airport masterplans will place increasing capacity demands on airspace, particularly in the South-East. That is why the Progress Report noted that the Department with the CAA and NATS would consider the impact of forecast growth on the South East airspace in the period up to 2030. 15. Termed the “Future Airspace Strategy” (FAS), work has begun to set out a strategic plan for managing the UK’s increasingly busy airspace to deliver safety, eYciency, capacity and environmental benefits. This work will necessarily take account of European developments, in particular the developing SES II initiative, its SESAR (Single European Sky Air TraYc Management Research) programme and any resulting changes in our European neighbours’ airspace management arrangements impacting UK airspace structure and procedures. 16. FAS aims to ensure that airspace developments are taken forward in a measured and co-ordinated manner rather than on a piecemeal basis. However, the airspace policy framework is set by the International Civil Aviation Organisation (ICAO) and increasingly the European Community; the UK must respond, as appropriate, to such international and regional developments. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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How are the eVects [of] aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? 17. Responsibility for airspace changes procedures falls primarily to the CAA’s DAP in light of proposals put to them by airspace change sponsors, mainly airports and air navigation services providers. This responsibility extends to ensuring that a thorough assessment of the environmental impact of any proposed airspace change is undertaken during its development. 18. The process for making changes to airspace is governed by the CAA’s Airspace Change Process. CAP 724, the Airspace Charter, enables any organisation to initiate a change to airspace arrangements and CAP 725 provides further Guidance on the Airspace Change Process. These are explained in more detail in paragraph 37. 19. Following review and consultation, the CAA issued a revised version of the guidance in March 2007. Amongst other matters, the revision provided greater clarity on the roles and responsibilities of an airspace change sponsor and the decision-maker, greater detail, including a step-by-step guide, on the activities of a consultation exercise, and substantial detail on the environmental assessment of any proposed change including what impacts should be taken into account, how they should be measured and who should be consulted. 20. The CAA’s airspace change process reflects the Secretary of State for Transport’s Directions and Guidance to the CAA on the exercise of its statutory duties and environmental objectives. The balance in decision-making rightly sits with the CAA’s Director of Airspace Policy given his statutory duties (see paras 33—37).

What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined? 21. The economic value of commercial air transport and its associated public benefit has long been acknowledged, but the CAA’s recent Strategic Review of General Aviation in the UK has now also highlighted the significant economic and social benefits of the wider General Aviation sector which includes both business and recreational flying. 22. DAP is responsible for ensuring that the needs of all airspace users are reasonably met, taking into account environmental issues. To that end, DAP’s process of consultation on airspace change proposals is perhaps unique in Europe in that all airspace stakeholders have the opportunity to express their views on proposals through the National Air TraYc Management Advisory Committee (NATMAC). This forum has, to date, worked well. Given the economic and social benefits of General Aviation identified in the CAA’s Strategic Review, it is important that all stakeholders continue to strive to ensure that the outcome of any airspace management change proposals seek to allow all users the maximum use of the airspace that is consistent with safe operations.

How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? 23. EU Member States hold sole responsibility for the design and management of their airspace (both sovereign and that entrusted to them under the ICAO 1944 Chicago Convention—ie the FIRs (Flight Information Regions)). However, although each State bears this responsibility, it is coordinated for 25 of the EU States under a co-operative agreement within Eurocontrol, the European Organisation for the Safety of Air Navigation. Proposed national amendments to the design of airspace are loosely co-ordinated under Eurocontrol’s Route Network Design group to ensure compatibility of changes. 24. Air TraYc Flow Management (ATFM) for the 38 contracting States of Eurocontrol is performed in entirety by the Agency’s Central Flow Management Unit (CFMU). Although slots at individual airports are agreed between aircraft and airport operators directly (a commercial arrangement), and Flight Plans (a notice of intention to fly a prescribed route, at a given time and over a given profile) are filed by individual aircraft operators, the capacity of ‘the European ATM system’ to control each flight is determined by the CFMU (a flight safety arrangement). UK operators are therefore treated in flow management regard on the same terms as all other Member States. 25. Airspace management is a purely national responsibility. Each Member State is empowered to ensure safe and equitable access to airspace for all groups of users. This responsibility is exercised in diVerent ways but the overarching principle of the “Flexible Use of Airspace (FUA)” is now mandated by the EU under the Single European Sky programme. FUA endeavours to make the best use of a limited resource by ensuring blocks of airspace are not unnecessarily ring-fenced for specific groups of users for prolonged periods of time; the UK is considered to be a leader in the application of FUA principles. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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26. SES II, currently under negotiation in Council Working Group, proposes the establishment of a “Network Management Function and/or body” whose ultimate responsibility is yet to be determined but in essence will formalise the existing arrangements for the design, allocation and use of airspace. This function/body is seen as the next natural step in coordinating design and use aspects of the airspace of all Member States. Eurocontrol is likely to perform this role but it is not anticipated that it will be granted any authority over Member States that impinges on sovereign right or ICAO driven responsibility. 27. Under SES, Members States are required to establish Functional Airspace Blocks (FABs) as one means of maximising the capacity and eYciency of the wider European ATM network. The UK/Ireland FAB, the first FAB in Europe, was implemented in July 2008 and is designed to deliver real operational eYciencies regardless of existing national boundaries. Given the UK’s strategic position in managing air traYc flows between North America and Europe, we are also a co-operative partner in the development of the proposed FAB Europe Central (FABEC) involving the airspace of France, Germany, the Netherlands, Belgium, Luxemburg and Switzerland.

What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? 28. The UK is continuing to push for improvements in aircraft technology and operating procedures to continually increase the eYciency and environmental performance of the industry. In terms of airspace management, the White Paper stated that the Government looks to NATS to operate and develop air traYc control eYciently, consistent with their overall objectives and, in particular, to seek to minimise stack holding as far as possible, to reduce fuel burn and emissions. 29. Current airspace change proposals under development seek to promulgate techniques such as Continuous Descent Approach (CDA), a quieter and more fuel-eYcient approach for landings, and Precision Area Navigation (P-RNAV), a means of improving aircraft routings and profiles with resulting reductions in fuel consumption and emissions. 30. Although the removal of stacks would require careful examination to ensure that safety and runway capacity were not compromised, increased airport capacity may also reduce the need for stacking. For example, depending on the Government’s decision on a third runway at Heathrow, NATS have stated that their aim is to explore the possibilities for reducing or even eliminating the need for routine stacking as advanced air traYc management techniques are gradually introduced. The extra capacity of a third runway would help in this. 31. Furthermore, NATS is the first air navigation service provider in the world to declare an environmental target, aiming to cut emissions from aircraft under its control by, on average, 10 per cent per flight by 2020 against a 2006 baseline. 32. The UK is also an active supporter and participant in SESAR. Although the project is in its development phase (2008–14) with implementation planned from 2014 onwards, we strongly support its emphasis on the environment with a 10% target reduction in emissions per flight based on shorter routes with improved flight profiles resulting in reduced fuel burn, reduced emissions and reduced stacking.

In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play?

Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? 33. The CAA’s statutory duties are set out in Section 70(1) of the Transport Act 2000. In exercising its air navigation functions, the CAA must give priority to maintaining a high standard of safety in the provision of air traYc services and must carry out its functions in the manner it thinks best to: — secure the most eYcient use of the airspace; — satisfy the requirements of all airspace users; — take account of the interests of any person in relation to the use of any particular airspace or the use of airspace generally; — take account of any guidance on environmental objectives given to the CAA by the Secretary of State; — facilitate the integrate of civil/military air traYc services; — take account of the interests of national security; and — take account of the UK’s international obligations as notified to the CAA by the Secretary of State. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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34. The Civil Aviation Authority (Air Navigation) Directions 2001 and the Civil Aviation Authority (Air Navigation) (Variation) Direction 2004, given under Section 66(1) of the Transport Act 2000, clearly set out the responsibility of the CAA’s DAP to develop, approve, monitor and enforce policy for the safe and eYcient allocation of UK airspace and the sustainable use of that airspace. 35. In addition, the Secretary of State’s Guidance to the CAA on the Environmental Objectives Relating to the Exercise of its Air Navigation Functions (2002), sets out the framework within which DAP will discharge the CAA’s air navigation functions. 36. The Guidance and Directions are designed to ensure that proposals for airspace changes are brought to the attention of aVected parties, are properly assessed, that environmental impacts are mitigated as much as possible and that changes are only made where it is clear, after consultation, that an overall environmental benefit will accrue or where the airspace management considerations and the overriding need for safety allow for no practical alternative—this balance in decision-making rightly sits with the CAA’s Director of Airspace Policy. 37. CAP 724, and CAP 725 clearly identify the roles and responsibilities of airspace change proposer and airspace change decision-maker. A change sponsor is responsible for developing and consulting upon a proposal, ensuring that it satisfies and/or enhances safety, improves capacity and mitigates, as far as is practicable, any environmental impacts in line with the Department’s environmental guidance to the CAA. The CAA, as decision-maker, assesses a formal airspace change proposal against regulatory requirements, including environmental objectives, and then either approves or rejects the proposal. It is only where the CAA considers that a proposal might have a significant detrimental eVect on the environment that the CAA is required to advise the Secretary of State for Transport of the likely impact. They must also advise of plans to keep that impact to a minimum, and to refrain from making the airspace change without first securing the approval of the Secretary of State. 38. Clearly, airspace change sponsors need to ensure that they are adequately resourced to develop, consult upon and, subject to regulatory decision, implement a proposed change. Similarly, the CAA must ensure that it is adequately resourced with the necessary expertise to evaluate and decide upon a proposal. To date, appropriate resourcing in the respective bodies has not been a limiting factor in the development or decision-making processes for airspace change proposals. 39. Following the independent strategic review of the CAA by Sir Joseph Pilling, the Secretary of State has agreed his recommendation that the CAA’s governance be strengthened with the addition of a Chief Executive OYcer. 40. The review’s other recommendations remain subject to detailed consideration with a view to the Secretary of State providing an update in the autumn. In airspace terms, recommendations of particular note include that the CAA be given a general statutory duty in relation to the environment, that the duty be set within a policy framework from Government oVering guidance to the CAA on how to strike the balance between environment and other considerations, that the framework make clear the boundary between the roles of the CAA, the Government and other stakeholders, and that the Secretary of State’s environmental guidance to the CAA be updated. 41. The Government welcomes these recommendations and the review’s acknowledgement of the challenge which would be involved in producing an environmental framework for aviation given the range of factors to be taken into account—setting out the inter-relationships between safety, the needs of airspace users, the economy as a whole, the aviation sector in particular and the environment. Clearly, any such framework would need to be suYciently flexible to allow airspace change proposals to be considered on their individual merits, recognising that a balance would need to be struck between diVering environmental objectives as well as wider considerations.

Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? 42. There is no evidence to suggest that airspace management considerations delay the planning processes in relation to airport development proposals. To date, all airspace change proposals have been implemented by their target date, where regulatory approval to proceed has been granted. 43. The Department’s aim is to establish a suite of national policy statements that will comprise a statement for aviation incorporating the White Paper in a way which meets the Government’s proposed policy and statutory requirements for National Policy Statements set out in the Planning Bill. We are committed to producing a further progress report between 2009 and 2011, which would provide a good opportunity to designate the White Paper in conjunction with that report. 44. The Infrastructure Planning Commission (IPC) will deal with decisions on the construction of infrastructure and capacity development on the ground; it will not make decisions solely relating to airspace management which remain the responsibility of the CAA under the Airspace Change Process. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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45. In submitting applications for airport development, a preliminary view will need to be taken of the various options for airspace configuration and capacity requirements. Those preliminary views will form part of the application and be subject to the necessary impact assessments. However, the detailed airspace design and subsequent consultation will depend on the nature of the airport development for which IPC consent is granted. Given the timescales for infrastructure development, the airspace change consideration is not a limiting factor in planning timescales—the decision-making phase for the airspace change process is 17 weeks.

Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? 46. Airspace change proposals can be initiated by any body.However, sponsors for change are most likely to be an aerodrome operator, an air navigation services provider or a combination of these two given that the driver for change is generally safety or capacity stemming from increased demand, albeit that environmental considerations must be taken into account. Consequently, in line with the “user pays principle”, it is airspace users who fund airspace change proposals through aerodrome landing fees and/or air navigation route charges. There is no evidence to suggest that such funding is likely to be a constraint to developing future airspace change proposals. October 2008

Supplementary memorandum from the Department for Transport (AIR 21a) Further to my appearance before the Transport Select Committee’s inquiry into the use of airspace on Wednesday 22 April, I agreed to write to the Committee detailing any initiatives within the Government’s Budget announcement of the same day which would impact upon the Civil Aviation Authority (CAA)’s resources, particularly in relation to safety and the environment. I am now in a position to confirm that the Budget contained no proposals which would impact directly upon CAA resources in relation to safety, the environment or other areas of the regulator’s work. However, I would like to take this opportunity to reiterate my statement to the Committee that safety is the top priority for Government and all the other key players in managing airspace and that the CAA, as independent regulator, is regarded as one of the leaders in its field. On environment, whilst the Budget did not impact CAA resources directly, it did recognise the UK’s instrumental eVorts in negotiating a strengthened framework for the EU’s Emissions Trading Scheme (EU ETS) which, from 2012, will include aviation, capping emissions from this sector while enabling cuts to be made in the most cost-eVective way. The revised EU ETS will ensure an annual reduction in emissions up to 2020 and will support the broadening and deepening of carbon markets as part of co-ordinated action towards a global deal. In conjunction with the UK’s new target to reduce total UK aviation CO2 emissions to below 2005 levels by 2050, the UK has the toughest climate change regime in the world. Furthermore, as I reported to the Committee, following Sir Joseph Pilling’s Strategic Review of the CAA, the Government accepts his recommendation that the CAA should be given a general statutory duty in respect of the environment. The Government plans to bring forward suitable legislation when the legislative programme allows. I hope that this is helpful. May 2009

Memorandum from the Chilterns Conservation Board (AIR 22) Following the recent call for written evidence the Chilterns Conservation Board is pleased to detail its comments below, which are submitted as evidence in connection with the above inquiry. The Board has tried to answer as many of the questions as possible, but has focussed on those issues that are considered to have implications for the Board or the management of the nationally designated Chilterns Area of Outstanding Natural Beauty (AONB). The Chilterns Conservation Board is a body, set up under an Act of Parliament, that represents the interests of all those people that live in, work in, visit and enjoy the Chilterns AONB. It is made up of representatives nominated or elected (parish council) by the following organisations: — Bedfordshire, Buckinghamshire, Hertfordshire and Oxfordshire County Councils; — Aylesbury Vale, Chiltern, Mid Bedfordshire, North Hertfordshire, South Bedfordshire, South Buckinghamshire, South Oxfordshire, Three Rivers and Wycombe District Councils; Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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— Dacorum and Luton Borough Councils: — The Bedfordshire, Buckinghamshire, Hertfordshire and Oxfordshire Parish Councils (six elected in total), and — DEFRA (eight in total).

Summary — The Chilterns Conservation Board is extremely concerned about the implications of the proposed growth in the number and frequency of flights over the Chilterns AONB. It is considered that there would be significant detrimental impacts on the tranquillity of the AONB and the quiet enjoyment of the countryside. — Much greater account should be taken of the current and ongoing economic conditions which have resulted in demand being level or in decline in the short to medium term and demonstrate a pattern of demand that is diVerent to that in 2003. This may well have implications for some time to come. — The Government should take much greater account of the environmental implications of growth in the number and frequency of flights. Such implications include loss of tranquillity (particularly in connection with protected landscapes such as National Parks and AONBs) arising from increased noise, the eVects of traYc congestion in the vicinity of airports and the eVects of other emissions. — All proposed changes to airspace should be based on thorough and up to date assessments of current demand, should consider all relevant matters even if they are diYcult to address and should rely on robust studies of tranquillity and all other environmental implications. The Board considers that the Government should not simply respond to the airlines’ demands for increased capacity irrespective of the environmental consequences. — Advice from Government to the aviation industry (CAP 725) is at present confusing and misleading and ought to be redrafted in connection with the implications for the overflying of protected landscapes. — Greater account should be taken of the implications for flying out of smaller airfields. — All changes to airspace should be independently examined and verified by a publicly accountable body.

Evidence

Are the White Paper’s projections for increased passenger demand still accurate? 1. The Board considers that the projections for increased passenger demand are no longer accurate and further work should clearly be done now to ensure that forecasts are brought up to date to reflect the current economic conditions. These conditions may apply for some time into the future (not just the short term) and should not be dismissed as a short term issue. 2. The price of oil and the “credit crunch” have led to some major airlines significantly reducing the number of flights over the coming months. There is therefore no need to rush into significant changes as demand has levelled oV and in some cases is in decline. This is particularly important when taken in the context of the need for a full examination and reporting of the environmental implications of air travel. This has been called for by a number of bodies but has yet to take place. 3. Greater consideration therefore needs to be given to diVerent scenarios rather than just a single one that focuses on unconstrained increases in demand and the Board considers that, rather than catering for relatively unconstrained growth, the Government should be considering only planning for managed limited growth. This is because expansion will lead to greater numbers of lower overflying aircraft which will damage the enjoyment of the special qualities of the Chilterns AONB for those people who live in and visit this protected landscape. Airspace management does not currently give any weight to those aVected. 4. The Board considers that the inquiry also needs to take account of the implications of the carbon emissions of air travel. This is not done at present and is a serious omission that, when properly considered with cost implications, will almost certainly lead to a reduction in the number of passengers.

Are all the measures to provide for increased passenger demand likely to be implemented? 5. The Board considers that with falling passenger numbers and a decreasing number of flights it is most unlikely that measures to provide for increased passenger demand will be implemented. In fact, the opposite is probably true with contraction, rather than expansion, in the industry being the case. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Can safety be maintained as airspace is increasingly utilised? 6. The Board does not consider that there are currently unacceptable threats to air safety in terms of airspace use and is not aware of any significant increase in risk due to congestion that would warrant significant changes. In addition, with contracting services rather than increasing utilisation it is considered to be most unlikely that it will become an issue in the future. The Board therefore considers that safety can be maintained with current levels of airspace use, as well as if airspace is increasingly utilised, though this is not being advocated (please see the summary detailed at the start of this document which highlights the Board’s key concerns).

Is the current approach to planning and regulating the use of UK airspace adequate? 7. The Board does not consider that the current approach is adequate because it seems that changes are promoted by and for the aviation industry and approved by organisations that are at arms length from any accountable body. Consultation on changes are inadequate (for example we only need to look at the recent NATS consultation on the TCN proposed changes to airspace to see how inadequate the consultation has been) and do not reflect the procedures that are undertaken for comparative exercises in the planning sphere for example. 8. Changes should be instigated that ensure that any future consultation is thorough, transparent and accessible to all, with proper reporting procedures leading to independent conclusions and recommendations.

Would an Airspace Master Plan covering the period of the White Paper be beneficial? 9. The Board considers that this would be useful, but any Plan should be drafted after a thorough examination of the conditions that are applying at the time, and any consultation should be full and proper based on adequate and accessible information. Any conclusions should be arrived at independently of the aviation industry.

Could a piecemeal approach to individual developments necessitate additional redesigns subsequently? 10. Yes, because all matters that apply should be considered from the outset even if they are diYcult to include. If a problem exists then it should be addressed and not ignored because it is too diYcult (the exclusion by NATS of changes to the Bovingdon Hold as part of the recent TCN proposed changes is a very good example). 11. The evidence base that is used for redesigns should also be up to date and should address all matters that are relevant (this includes impacts on things such as tranquillity and the need to have robust assessments incorporated).

How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? 12. The Board does not consider that adequate account is taken of the eVects of aircraft noise and emissions when changes are made. Noise is particularly intrusive in those places where background or ambient noise levels are low. This applies in the more tranquil areas of the country and particularly protected and nationally designated landscapes such as the Chilterns AONB which are by their very nature less congested and less densely populated. 13. Before any changes are proposed the Board considers that thorough and robust studies should be undertaken to assess tranquillity. In the Board’s experience no consideration has been given, as part of proposed changes to airspace, to the impacts on people on the ground or their enjoyment of quiet and peaceful countryside for example. 14. The Board also considers that much greater account should be taken of the implications of significant increases in car use and congestion on roads local to airports. With the proximity of airports such as Luton and Heathrow to the Chilterns AONB the eVects of increased congestion are felt in the AONB. 15. The Board also considers that the Department for Transport’s guidance to the CAA (CAP725 paragraphs 45 and 46) requires redrafting in connection with the issue of the eVects of overflying of protected landscapes because it is being misinterpreted at present, thus resulting in proposals that would increase overflying of the Chilterns AONB. 16. The importance of avoiding the overflying of AONBs cannot be stressed enough and the Board also considers that there should be much more consideration of the eVects of expansion in combination with the use of other airports (both large and small). There should also be cooperation and collaboration between all airports so that the full eVects of proposed changes are considered holistically. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Who should be consulted about such changes? 17. Any consultations should be wide ranging and should include all those bodies that are likely to be aVected, including bodies that represent the countryside and protected landscapes for example. Consulting is one thing, listening to the results and doing something about it are another matter and the Board is concerned that such consultation exercises will be seen as a “tick box” exercise on the part of the CAA and NATS for example. 18. Those populations likely to be aVected by any proposed changes should also be consulted and listened to.

How should the balance between conflicting interests be struck? 19. The Board considers that interests of national importance (protected landscapes such as National Parks and AONBs for example) should take precedence over the interests of the aviation industry because once changes are implemented there are likely to be very few opportunities to revisit proposals and the damage will already have been done. 20. The environmental eVects of aviation, including the impacts of noise and emissions, should feature much more prominently in any consideration than is the case at present.

What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? 21. Opportunities will exist to make flying, take oV and landing procedures more eYcient, though these should not be introduced at the expense of the wider environment and particularly the quiet enjoyment of protected landscapes such as AONBs. A number of airports are in close proximity to AONBs and National Parks and direct routes may lead to more overflying of such landscapes, therefore in some cases there will be environmental benefits in taking an indirect route and not overflying such areas.

Could environmental benefits be gained as a result of such improvements? 22. In some instances this may arise, though, as detailed above, there may also be environmental costs that the Board thinks would outweigh the introduction of such measures.

In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? 23. Based on the Board’s recent experience with the NATS’ TCN proposals it is quite clear that the allocation of roles and responsibilities of the interested parties are neither appropriate nor clearly understood. It is understood that any redesign is proposed and approved by those within the air industry without any clear involvement of any directly elected or fully accountable body. This is confusing and needs to be addressed so that stakeholders have confidence in the system such that any comments that are made are going to be taken account of fully and properly. 24. Any decisions should be independently made by a fully accountable body. In addition, the Board considers that robust and up to date statistics should be used, thorough and robust studies of tranquillity should be undertaken and the current guidance that has been issued by DfT to the CAA should also be revisited and clarified.

Are the structures of the parties appropriate for undertaking the roles that they should play? 25. The Board does not consider that bodies that are owned and operated primarily by airlines should be taking decisions that have such a direct impact on their own industry. The consideration of proposals should be undertaken on an independent basis, but with expert input where required. The public interest is clearly not being given full and proper weight.

Do airspace management considerations delay the planning processes in relation to airport development proposals? 26. The Board does not consider that airspace management considerations delay planning processes in relation to airport development proposals. In fact it has been quite clearly told that airspace management is quite separate from development proposals and that the expansion of airports is not taken account of in airspace change proposals. The Board considers that any future expansion plans should quite clearly be inextricably linked to any airspace change proposals and vice versa. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? 27. The Board is not sure how airspace management considerations will be taken into account by the IPC or National Policy Statements, but it is clear that any proposals should be subject to full and proper consultation with all those that have an interest in the proposals, including relevant stakeholder groups and aVected local populations.

What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? 28. The Board considers that, rather than catering for relatively unconstrained growth, the Government should be considering only planning for managed limited growth. The question ought to be considered in the light of the current and ongoing economic climate, which is likely to have significant implications in the medium to long term. 29. The Board also considers that the use of smaller airfields, recreational flying and use of helicopters have wider implications arising from intrusive noise caused by lower flying aircraft that ought to be brought under more control than is the case at present. Many smaller airfields are within or in close proximity to protected landscapes such as the Chilterns AONB and their use often has detrimental impacts on the tranquillity of the protected landscape.

How should an appropriate balance between conflicting priorities be determined? 30. The Board considers that based on a thorough assessment of the implications of any proposals that national priorities should have an overriding importance (and includes nationally protected landscapes such as AONBs and National Parks in this) over the interests of a single industry, which is working for profit and the benefit of shareholders rather than for the benefit of the public.

Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? 31. The Board does not consider that this issue needs to be examined in any great detail unless it is quite clear that there is robust and up to date evidence that shows that additional airport capacity is required. Should extra staV be required the Board considers that if the right incentives are in place then adequate numbers of staV could be recruited. 32. However, based on the location of many airports in the south east of England, there are likely to be housing aVordability issues for new staV that may be recruited. This may then result in greater commuting distances and increased congestion in the vicinity of airports. This would aVect a number of AONBs and particularly the Chilterns AONB which is close to both Heathrow and Luton airports.

Who should fund airspace changes? 33. The Board considers that any airspace changes should be administered and funded by Government in order to ensure that any proposed changes are independently verified.

Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? 34. Once again the Board considers that this question is wrongly based on the premise that additional airspace capacity is needed. Up to date studies should be undertaken to assess what the likely level of demand will be based on the current economic climate rather than proposals being based on information that is now at least four years out of date. If there is no longer a need for additional airspace capacity then the funding will not be required for redesign work. October 2008 Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Memorandum from the International Air Transport Association (AIR 23)

Executive Summary IATA recognises the importance of the UK Government’s statement in the White Paper for “a structured programme for the redesign of UK airspace that would help protect safety standards, relieve current constraints, take account of environmental impacts and accommodate the forecast increase in air transport movements where additional capacity was supported”. IATA recognises the importance of these objectives which could be realised as follows: — planning for airspace capacity is essential if delays and congestion is to be avoided; and — a more strategic and top down approach is required to airspace planning and design. This could be realised by each actor having clearer accountabilities: — DfT responsible for a National Policy Statement on aviation including the provision of airspace resources to meet demand, — CAA to own a high level airspace strategy together with a Master Plan to meet future capacity needs, — NATS responsible for detailed airspace design within the framework defined above, and — Operators to meet performance standards in order to access airspace. — assuring the independence of an airspace regulator in order to meet the needs of all users: commercial, military and general aviation. Coordination with other agencies responsible for the provision of strategic aviation infrastructure is recommended; — taking account of the obligations of the Member States in the Single European Sky, ensure a network based approach for the design, planning and management of Europe’s airspace including the development and implementation of new concepts of operation, the associated technological systems and the relevant operational procedures; and — adequate specialist resources are required to plan airspace in a timely and cost eVective manner. Adequate financing, funded from public sources, will be required to plan airspace in parallel with airport developments.

1. What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented? 1.1 In general IATA believes that the figures for passenger demand remain accurate although there may be some small reductions as a result of falling demand associated with the high cost of fuel and the downturn in many national economies. With respect to the planning for air traYc management movements as distinct from passenger demand, IATA accepts that the current scenario is for a 75% rise in traYc in 2020 compared with the 2004 baseline.

2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for air traYc control? 2.1 Yes, provided a Safety Management System (SMS) is always applied to the design and management of airspace changes. The SMS process is designed to provide the evidence to an independent regulator—the CAA’s Safety Regulation Group—that safety levels are maintained if not increased. 2.2 The UK is a good example of a joint and integrated approach between civil and military entities to airspace design, planning and management.

3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently? 3.1 The current process for planning and regulating UK airspace is based on the Airspace Change Process published in CAP 725, “CAA Guidance on the Application of the Airspace Change Process”. These guidelines were revised in 2007. Whilst these processes have proved suYcient in the past, IATA has some doubts as to whether the current guidance or procedures are the most eYcient or eVective in terms of satisfying the future and timely need for a strategic resource—airspace. This is particularly important in the context of a national infrastructure requirement for additional airport and runways capacity as outlined in the 2003 White Paper. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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3.2 IATA believes that a National Airspace Master Plan would be highly beneficial providing such a document is recognized as part of a National Policy Framework. Such an approach would require political endorsement by the relevant authorities and as a consequence influence subsequent decisions by the CAA regarding more detailed implementation decisions. The benefits of such an approach would be: (a) A more strategic and top down approach to airspace planning. (b) Timely decision-making regarding the provision of suYcient airspace resources to meet the predicted demand. (c) Increased certainty for the industry and will facilitate the necessary financial and investment planning.

4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? 4.1 The eVects of noise and emissions can be analysed, modeled and predicted using the processes outlined in the CAA’s Airspace Change Process 4.2 IATA is of the opinion that: — around all major airports there should be full public consultation on proposed airspace changes but these should be timely and eYcient and should not be allowed to unduly extend the planning process. The Government needs to establish a clear environmental policy which recognizes the trade-oV between noise and emissions and at diVerent levels and parts of the operation; — outside of controlled airspace there should be consultation with defense and general aviation users in order to assure a balanced and fair approach between all airspace users; and — above 7,000 feet, there should be a general presumption that all airspace users suitably equipped to a certain standard and under the guidance of an ATC authority,can operate safely without being subject to the full rigors of the Airspace Change Process provided that a National Policy Statement has been endorsed at the political level and the airspace change has been incorporated within the National Airspace Master Plan.

5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? 5.1 Airspace can only be eYciently managed from a network perspective that takes account of all movements particularly in the congested parts of SE England and the interface with both the oceanic and continental flow. The very dense airspace between the four major hubs of London, Amsterdam, Frankfurt and Paris is particularly challenging and requires a coherent approach to airspace design between the six air navigation services providers involved. Further the continuously growing demand from both civil and military users is such that new organizational arrangements are required to manage this airspace. 5.2 IATA strongly believes it is no longer possible to design national airspace in isolation without taking full account of adjacent international airspace particularly from an operational, safety and environmental perspective. The European Commission has promoted the importance of rationalizing Europe’s Air TraYc Management System in the Single European Sky project and has proposed two important measures to improve the eYciency of air navigation service: (a) Functional Airspace Blocks (FAB) to improve traYc flows. The FAB Europe Central project of the 6 States UFrance, Germany, Switzerland, Netherlands, Belgium and Luxembourg and with the UK as an associate partnerT if of major strategic importance for reducing delays and flight ineYciencies in Europe’s most complex airspace. (b) A centralized Network Manager Function to ensure consistency in airspace design and airspace management across national boundaries together with various airspace programmes promoted by the Eurocontrol Organisation. 5.3 IATA recognizes the importance of the SES project to overcome the following issues which exist at the European or Network level and require national authorities such as the CAA to coordinate its planning across national boundaries: — Flight ineYciencies accounted for detours of 468Mkm in 2007 resulting in between 1.6 and 2.5Beuro unnecessary fuel costs for the airlines. If related costs such as aircraft utilization, maintenance and staV costs are included then the total cost related to flight ineYciency is estimated at between 4 to 7Beuros per year. — The environmental impact of such ATM detours together with ineYciencies on the ground result in avoidable emissions of 16 million tons of CO2 per year. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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— Air TraYc Flow Management delays were 21.7 million minutes in 2007 resulting in an additional 1.3Beuros costs for airlines. — The cost of fragmentation amounts to an additional and unnecessary cost of one billion euros per year. (Source: Eurocontrol’s Performance Review Commission PRR 2007 May 2008.)

6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive ‘stacking’ while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? 6.1 The SESAR (Single European Sky ATM Research) project has identified the need for a new paradigm in Air TraYc Management in order to meet future capacity requirements. The major elements in the SESAR Master Plan have been identified as follows: — developing advanced concepts of operation (eg trajectory based operations) which increase safety, capacity and flight eYciency; — moving away from fixed airspace and route structures to dynamic and real time management of airspace using integrated civil/military arrangements promoted by the FAB concept; — managing Europe’s network more eVectively by a centralized Network Manager; — more automation in conflict detection and resolution supporting both pilots and controllers; and — queue management tools for both the departure and arrival sequence of flights. 6.2 SESAR has quantified the environmental improvements from new concepts of operation, new procedures and technologies. These amount to 17 million tons of fuel savings and 50 millions tons of CO2 up to 2020. Fuel savings for airlines amount to 8 billion euros at fuel price of 0.54 US dollars per kg. (Source: SESAR Consortium, D5 SESAR Master Plan 2008.)

7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties-Department for Transport, the CAA, airport operators, NATS, etc-appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play? 7.1 Whilst the current arrangements have served the needs of all aviation users, there will be additional benefits if a top down approach complements the current arrangements and is fully aligned or integrated, as required, into European developments such as the Single European Sky and the SESAR project. 7.2 IATA is of the view that the current arrangements could be streamlined so that each actor has clear accountabilities as follows: — The DfT should be responsible for a National Policy Statement on aviation transport whose scope includes the airspace resources deemed necessary to satisfy the medium to long-term predicted demand. — The UK CAA should own a high level national airspace strategy together with a Master Plan to meet capacity requirements and the needs of all airspace users. — NATS should continue to be responsible for detailed airspace design but within the framework outlined above. Fast tracking of airspace changes in the national interest should be permitted and without excessive consultation processes. — All aircraft operating in controlled airspace and in defined route structures- where needed in very congested airspace, need to have appropriate levels of system equipage and aircraft performance capability in order access airspace and maintain safety levels.

8. Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning?

8.1 IATA does not support the proposed new Infrastructure Planning Commission having any executive function in approving airspace changes. These powers should remain with the CAA and should not be incorporated into planning law. However the provision of a National Policy Statement for airport infrastructure should recognize the need for airspace as a strategic resource and there may be merits with the CAA assisting any authority with a clear understanding of the airspace implications for enhancing airport capacity. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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9. What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined? 9.1 In general, IATA believes that all airspace users need to be accommodated in the network and that an independent regulator should provide assurance of fair allocation, non-discrimination and clear rules to access and operate in the network. This may entail rigorous performance standards for: (a) the equipment to be fitted on board aircraft; (b) compliance to validated procedures of operation by all operators; and (c) the service level provided by the Air Navigation Service Provider. These requirements are necessary to assure the highest safety levels at major airports and may imply that certain categories of users are excluded from certain airspace because of non-compliance with the relevant rules. Furthermore safety rules must be respected at all times and take precedence over all other rules such as environmental policies or constraints such as noise or emissions

10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? 10.1 IATA believes that adequate specialist resources should be secured to plan airspace in a timely and cost eVective manner. NATS has responsibility under its License to provide suYcient capacity in the ATM system and is already engaged in the detailed design of the UK’s National airspace to meet this requirement. However a more proactive and strategic approach may entail additional resources particularly if all the airport master plans were to be delivered in full. Airport capacity together with an examination of the eVects on the environment need to be considered as part of the policy decisions on airport expansion.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? 11.1 The development of airports takes place in a national economic framework that provides opportunities for economic growth, jobs, tourism and regional development. Similarly the need for airspace is linked to airport developments and airspace, as a national asset, must be used eYciently in the interests of all airspace users. Consequently IATA believes that there is a compelling case to ensure that adequate public resources are allocated by the DfT to fund the provision of airspace needed to satisfy the national need as defined in the National Policy Statement. October 2008

Memorandum from the Society of British Aerospace Companies (AIR 24)

Introduction 1.1 SBAC is the UK’s national trade association representing companies supplying civil air transport, aerospace defence, homeland security and space markets. SBAC encompasses the British Airports Group and UKspace. Together with its regional partners, SBAC represents over 2,600 companies across the UK supply chain, assisting them in developing new business globally,facilitating innovation and competitiveness and providing regulatory services in technical standards and accreditation. 1.2 Aerospace is one of the few successful and globally competitive manufacturing sectors of the UK economy. Aerospace primes and their supply chain companies compete on an international basis. The competitiveness of the UK supply chain aVects the competitiveness of the whole industry. 1.3 The UK aerospace industry recognises its environmental responsibilities and is investing considerable financial resources in an ongoing programme of performance improvements. It is firmly committed to minimising its environmental impact and the sector is making significant contributions through research, technological progress and operational measures. As such we are a leading member of the UK Sustainable Aviation initiative, which includes airlines, airports, manufacturers and the UK’s leading air navigation services provider (ANSP). 1.4 We are pleased to have the opportunity to comment on the changes proposed to UK airspace through this consultation. Where appropriate, we have commented on specific questions that relate to SBAC’s activities and/or the interests of our members. 1.5 How are the eVects of aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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1.6 Aircraft engines produce a range of diVerent emissions. Some of these aVect local air quality whilst others have global impacts, contributing to climate change. There is significant scientific uncertainty regarding the eVects of many aviation emissions, however, the main contributors to climate change are widely accepted to be carbon dioxide (CO2), oxides of nitrogen (NOx) and water vapour (H2O), which in certain conditions can combine with the H2O already in the atmosphere to form condensation trails and cirrus clouds. 1.7 In 2001, the Advisory Council for Aeronautical Research in Europe (ACARE) proposed challenging environmental targets for the aviation industry including a 50% reduction in CO2 emissions and an 80% reduction in NOx emissions for aircraft entering into service from 2020, relative to their year-2000 counterparts. As the amount of CO2 produced depends directly on the amount of fuel burned, to reduce CO2 emissions the amount of fuel that must be burned to carry a given payload over a given range needs to be reduced. Hence, improvements in airframes, engines and air traYc management all have a role to play in reducing CO2 emissions. 1.8 Changes to UK airspace are made through the process set out in the CAA Directorate of Airspace Policy (DAP) Airspace Charter. This can require ANSPs to conduct consultation exercises with both airspace users and environmental stakeholders beneath proposed changes. The environmental consultation is normally only carried out with respect to airspace changes below 7,000 feet but there are exceptions for airspace changes over Areas of Outstanding Natural Beauty (AONBs) and National Parks. 1.9 We believe that the current system of consultation on proposed changes to airspace is already comprehensive and allows for extensive stakeholder engagement, including government (central/regional and local), local communities, businesses, environmental groups and the aviation industry.

1.10 NATS has committed to reducing CO2 emissions by 10% per flight by 2020 relative to a 2006 baseline. ANSPs such as NATS continually evaluate their route networks to assess where there is potential need for redesign in order to maintain capacity and how certain routes could change to improve their eYciency and possibly reduce their lengths. However, there are trade-oVs between emissions and noise exposure. For example, within the proposed changes to airspace being considered under the Terminal Control North consultation, routes below 4000 feet have generally been positioned to avoid flying over sizeable population centres. Between 4000ft and 7000ft, an attempt has been made to balance the demands of mitigating noise and reducing fuel burn and emissions. Above 7,000 feet increasing fuel eYciency and reducing emissions has taken priority. 1.11 Changes to existing airspace inevitably mean making diYcult and complex decisions which recognise the need to take into account the aims of reducing delay and mitigating the environmental eVects, whilst ensuring safety. Any changes made to existing airspace will attempt to achieve a balance between these often competing demands. 1.12 How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? 1.13 It is predicted that by 2020 there will be 17 million flights in the European airspace per year. To accommodate this volume of traYc, a three-fold increase in capacity from 2000 levels is required. Therefore despite current initiatives underway and already producing good results, significant further work is required in ATM and operations to avoid ineYciencies and delays. In the long term, the Single European Sky Research Programme (SESAR) is expected to deliver substantial improvements for the European airspace. However, eVective measures that can be delivered in the short term are required. Work is currently ongoing at the European level through the DMEAN and TMA2010! projects in this regard. 1.14 DMEAN is a five-year European Framework Programme led by EUROCONTROL that aims to deliver an additional 10% capacity to the 10-15% believed to be delivered through current initiatives. One of the priorities of the DMEAN Programme is to establish an improved interface between airports and the European ATM system. This will be undertaken through the ‘Airport Operations within the Network’ component of the programme. Collaborative Decision Making (CDM) is the principle vehicle for improving the interface. The idea is to extend CDM, which is already utilised by some airports and ANSPs, to many more airports throughout Europe to provide more accurate data for inbound flights, new information on capacity issues at other airports or in other airspace, and improved knowledge of weather-related disruptions. This new and improved knowledge will assist decision making and allow airports to have a more direct role in strategic planning. 1.15 As Terminal Manoeuvring Area airspace becomes increasingly busy and progressively more complex, and although some initiatives such as P-RNAV and Continuous Descent Approaches (CDAs) are bringing benefits today, more is needed, especially for high-density operations. TMA 2010! is a collaborative programme whose partners include EUROCONTROL, QinetiQ and NATS. Although engaged in a wide range of activities in relation to TMA operational improvements, the main focus for the TMA2010! Project is the development of the requirements and specifications of new arrival management system support tools. Phase 1 of the project aims to deliver quick win benefits to airspace users by 2010. Phase 2 aims to deliver a package of tools and procedures for implementation by 2015. Phase 3 is looking at enhanced procedures and tools beyond 2015 that align with the SESAR programme. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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1.16 The SESAR programme is a ƒ2.1 billion European Union ATM modernisation programme designed to integrate and extend the eVorts of past and current ATM initiatives so that their benefits can be fully realised. The programme will bring together the technological, economic and regulatory aspects of the ATM issue and use the Single European Sky legislation (introduced by the European Commission in 2004 to unlock viable growth in the European air traYc system) to synchronise the actions of diVerent stakeholders and concentrate resources. SESAR has many ambitious objectives to achieve by 2020 relative to a 2005 baseline including: — reduce environmental impact (CO2 emissions) by 10% per flight; — increase the capacity of the European sky by 73%; — reduce ATM costs by 50%; and — increase safety by a factor of three. 1.17 However, ultimately the ATM target concept developed through SESAR will go beyond these targets, enabling a three-fold increase in capacity and a 10-fold increase in safety within Europe. 1.18 What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive ‘stacking’ while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? 1.19 The high engine power settings required for take-oV and climb means that a significant proportion of fuel is burned in this phase of flight, particularly for short haul flights. Current practice sees aircraft climbing to cruise altitude in a series of steps separated by periods of level flight. This keeps departing traYc separated from those aircraft arriving and transiting to other airports but is not the most eYcient way for an aircraft to reach cruise. Climbing continuously from the ground up to cruise altitude eliminates the need for additional thrust in the segments of level flight and also means aircraft spend longer at flight levels closer to their optimal altitude which leads to a reduction in fuel burn and emissions. 1.20 Current airspace design means that this concept, known as “Continuous Climb Departure” (CCD), is not currently in use in the UK. However, programmes such as the US/EU Atlantic Interoperability Initiative to Reduce Emissions (AIRE) are working to evaluate its feasibility and impacts. Before this departure technique can be implemented the eVects of such a change need to be carefully considered as CCDs may lead to other unwelcome impacts such as more ineYcient overall routings and increased levels of noise. 1.21 Operating altitude, speed and route can all significantly aVect fuel eYciency, emissions and noise during cruise. When an aircraft is not flying at its optimal altitude, fuel consumption and emissions are increased. However, determining the best altitude at which to fly is not straightforward, as optimal altitude varies with aircraft type and throughout the flight. As fuel is burned, aircraft weight is reduced and the aircraft needs to climb higher in order to maintain its optimum cruise eYciency. In addition, environmental conditions such as favourable wind speeds and directions may mean that it is better to fly at higher or lower altitudes at certain points throughout the flight. 1.22 Every aircraft is designed to operate at a set of specified conditions, known as its “design point”. This includes a particular cruise speed (Mach number). Although aircraft can safely operate at conditions within an envelope around their design point (known as the operating envelope), their performance at these oV-design conditions is not optimal and will incur penalties such as increased fuel consumption. As there is a direct relationship between aircraft speed and fuel burn, reducing cruise speed whilst staying within the aircraft’s operating envelope, can be an eVective way to reduce fuel burn and emissions. 1.23 Designing and utilising shorter, more direct routes can lead to significant reductions in fuel burn and emissions. This includes using route profiles with optimal ascent and descent approaches and increasing the height at which aircraft are held before landing, as this keeps the aircraft higher, where the air is less dense, thereby resulting in less drag and hence fuel burn. 1.24 EVorts underway to optimise height, speed and route profiles include those made as part of the CRISTAL In-trail Procedure (ITP), which allows an aircraft to perform altitude changes more easily during cruise (thereby reducing fuel burn and emissions). These have recently been trialed by Airbus and Scandinavian Airlines (SAS). The demonstration took place in Iceland in March 2008 using Airbus’ own A340 test aircraft and an SAS A330. During the flight test, the A340 aircraft performed a number of altitude changes using a new navigation system fitted in the aircraft. The system, which is based on ADS-B (Automatic Dependant Surveillance—Broadcast) and uses new air-to-ground and air-to-air surveillance technology to transmit information, enabled the pilot to receive all the flight identification and positioning information about the surrounding aircraft on his navigational flight display. This technology is currently being certified for use by Airbus. 1.25 This successful trial represents a significant step forward in the flexibility of oceanic operations. Currently, the lack of radar systems limits the changes in cruise altitude an aircraft can make within the oceanic airspace. However, with this new technology, the flight crew will be able to provide the air traYc controller with precise information about the aircraft’s position relative to other aircraft. Air TraYc Controllers can then use this information to instruct air crew to change altitudes while maintaining reduced separations. This creates more climbing opportunities for the aircraft. 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1.26 With regard to arrivals, an eYcient approach to landing is one that does not require any additional energy input (eg no level sections of flight or holding periods requiring engine thrust). This can be achieved by managing the aircraft’s momentum from Top of Descent (TOD), en-route or stack altitude such that its vertical and lateral speed onto the glide slope are optimised for its type to ensure a safe and fuel eYcient landing. 1.27 As a result of inherent airspace restrictions, aircraft have traditionally descended towards their destination in a series of steps. However, from both a fuel burn and emissions and a noise perspective, this approach is not ideal. With a Continuous Descent Approach (CDA), an aircraft descends towards an airport in a gradual, continuous approach with the engine power cut back. By flying higher for longer and eliminating the need for the extra thrust required for the periods of level flight between steps of descent, CDAs result in average reduced fuel burn and emissions of 100 kg of fuel and 315 kg of CO2 per flight, compared to a conventional approach. Deferring the start of descent also means less noise exposure for communities under the early descent phase of the flight path. 1.28 Currently, CDAs are agreed by the air traYc controllers and pilots on a flight-by-flight basis, according to weather and traYc conditions. Their use in the UK is well-established; they have been used extensively in the UK for certain airports such as London Heathrow for several years with no impact on the airport’s capacity. However, CDA utilisation is often limited by ATM resource, airspace capability or pilot uptake. These approaches need dedicated control assistance throughout the approach which is very time consuming and not always possible during busy periods. Advanced, automated CDAs are however now being tested. With this new procedure the aircraft’s flight management system automatically receives instructions from the on-ground ATC system on how to descend such that the most eYcient descent approach is used. 1.29 Steeper approaches, which aim to keep the aircraft as high as possible for as long as possible, are primarily flown for noise abatement reasons, however they also oVer emissions savings. A notable user of such approaches is London City where a glide path angle of 5.5 degrees (compared to three degrees for a standard CDA) is routinely flown. Low power low drag (LPLD) approaches are another example of environmentally friendly approaches. They use low engine power low drag profiles to reduce fuel burn and noise. With these approaches, the aircraft keep the most aerodynamically “clean” configuration for as long as possible subject to given operating conditions (weather, air traYc conditions, etc), thereby minimising drag and hence thrust requirements and fuel burn. This means that the deployment of equipment like the aircraft’s flaps and landing gear is delayed as much as possible. These approaches are in use at some UK and EU airports. However, it is becoming increasingly recognised that the optimum approach procedure is a combination of LPLD and CDA, as this allows for eVective speed and energy management while also reducing noise impact. 1.30 EUROCONTROL estimates that if CDAs became standard throughout Europe around 945,000 tonnes of CO2 emissions would be saved each year. However, unfortunately CDAs cannot be used at all European airports at all times. At busy airports, descending aircraft are not allowed to fly freely down their optimum descent paths. This is because the controller needs to have the flexibility to intervene as required to appropriately space the descending aircraft to accommodate for changes in conditions (traYc, weather etc.) and fulfil safety requirements for aircraft in terms of separation for aircraft wake vortices. 1.31 A number of projects that attempt to preserve flexibility, whilst ensuring that optimal approaches are used wherever feasible, are underway throughout Europe. These make use of a number of advanced pilot and controller tools including P-RNAV,which, with an additional vertical navigation capability,VNAV,can be used to very accurately define an arrival route; and a suite of tactical control tools which can help to provide more certainty in the Required Time of Arrival (RTA) of aircraft on approach, relative to each other. October 2008

Memorandum from the Aviation Environment Federation (AIR 25)

Who we are The Aviation Environment Federation (AEF) is the principal UK non-profit making environmental association concerned with the environmental eVects of aviation. It promotes a sustainable future for aviation which fully recognises, and takes account of, all its environmental and amenity eVects. These range from aircraft noise issues associated with small airstrips or helipads, to the contribution of airline emissions to climate change. The AEF was established in 1975 because of growing concerns about noise from private aircraft. This remains an important part of AEF’s work, but in recent years increasing attention has been focussed on the impacts of commercial aviation. AEF is a membership organisation which provides an advice and information to its members. We have over 120 aYliated members comprising community and environmental groups, local authorities, parish councils, businesses and consultancies and individuals. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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The document below sets out our key responses to the call for evidence, and then more detailed responses to the questions contained in the call for evidence. Appendix A contains a numbered list of the questions AEF has responded to.

Key Recommendations — Independent research is required to revise growth forecasts to the point where a suYciently robust Airspace Master Plan would be feasible. — An Airspace Master Plan should contain comprehensive mapping of airspace blocks and projected traYc flows, assessment and projection of current and future emissions and strategies for reducing these, more clarity on the issue of rural/urban routing, strategic guidance on the preservation of Areas of Outstanding Natural Beauty and National Parks, and projections for the maximum eYciencies that can be achieved in case of increased capacity/usage. — Airspace change proposals should be closely tied to land use planning, managing any planning restrictions or environmental impacts through thorough local consideration and the eVective communication of alternative measures. Airspace management it must be brought forward in the planning process, if necessary, with outline permission being gained before further planning consideration is undertaken. — The eVects of aircraft noise and emissions on local populations are not given equal consideration with capacity. There should be accepted thresholds for environmental impacts which, if exceeded, would invalidate Airspace Change Proposals (ACPs).

Detailed Responses 1. AEF does not have the expertise to comment on all the details of airspace management, however, we are concerned with its environmental implications. As an overall remark we believe this consultation is premature, as growth levels and the structure of the industry are in flux. Revised forecasts are required to ensure no non-essential capacity is built, thus reducing pressure on airspace operators to increase capacity to unsustainable levels. We have asked the DfT to provide revised forecasts before any capacity decisions are made. 2. The extent to which safety may be compromised depends partially on the congestion of routes. Care should be taken to ensure that safety standards do not lapse to increase capacity, and that penalties against level-busts etc are severe. While our members understand the focus on safety, decisions on the location of new capacity will influence the size and shape of Public Safety Zones, and thus planning decisions. More detailed strategic guidance, formulated with comprehensive consultation and independent research is needed over the viability and impacts of rural routing being used in preference over urban areas. 3. The planning and regulation of UK airspace requires long-term strategic support. Providing comprehensive, independent evidence is used for its construction, an Airspace Master Plan covering the period of the White Paper would be beneficial. Piecemeal approaches to individual developments and any subsequent redesigns should be considered under the strategic framework of the Airspace Master Plan, which should be non-site-specific, and used alongside the Air Transport White Paper 2003. Without this, it will be diYcult to determine if the White Paper projections can be safely met. AEF envisages any airspace Master Plan would contain comprehensive mapping of airspace blocks and projected traYc flows, assessment and projection of current and future emissions and strategies for reducing these, more clarity on the issue of rural/urban routing, strategic guidance on the preservation of Areas of Outstanding Natural Beauty and National Parks, and projections for the maximum eYciencies that can be achieved in case of increased capacity/usage. Airspace changes should have closer links to land-use planning. Where increased airport capacity is proposed, airspace should be considered in parallel, with mapping available to consultees, but no formal planning status. 4. The eVects of aircraft noise and emissions on local populations are not given equal consideration with capacity. The Environment Agency should be a key consultee. There should be accepted thresholds for environmental impacts which, if exceeded, would invalidate Airspace Change Proposals (ACPs). The degree of environmental information provided by National Air TraYc Services (NATS) has improved, yet still remains inadequate overall. ACPs consistently undervalue the importance of reductions in noise and emissions. Research into degrees of intrusiveness of air routing is not yet robust enough for the formulation of proper policy guidance, resulting in a shifting of environmental impacts, rather than solving them. More sophisticated guidance is required from the DfT, and a revision of current guidelines for airspace planning. At present, the focus on concentration and minimising the number of people aVected by aircraft noise, fails to recognise emerging environmental policy, not least the protection of tranquil areas. 5. Better integration with EU airspace is necessary if coastal stacking is to be an option. A single integrated EU airspace block would increase eYciency, for example by allowing direct routing between states, and we urge the UK Government to continue to push for an agreement on the Single European Sky. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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6. If the Terminal Control North consultation is a good indicator of technology being used to achieve environmental benefits, then it is clear that such benefits are minimal when compared with the environmental impacts of the capacity growth envisaged, for the South East in particular. Greater emphasis should be placed on maintaining environmental standards, which should not be considered as subsidiary to capacity constraints. It is disappointing that the increasing use of CDA and PR-Nav technological advances have not led to parallel environmental gains. Many of the initiatives presented served to move the environmental impacts rather than resolve them, with the resultant capacity increases leading to an overall increase in emissions- a highly unsustainable position if the aviation industry is to counter its climate change costs. 7. NATS, as a source of expert advice and data need to enhance their role in the planning process. NATS concerns about capacity limitations should take precedence over externally set growth targets. In order for the CAA to strengthen its reviewing process of actual operations, it must demonstrate its possession of the resources to enforce Airspace Change Sponsors to follow CAP725. Areas of responsibility should be clearly delineated. Better definition of these roles would lead to increased transparency and democratic accountability. The DfT should provide strategic objectives for Air Space Managers. 8. Under current arrangements, airspace management is given no consideration in airport development proposals; it must be brought forward in the planning process, if necessary, with outline permission being gained before further planning consideration is undertaken. This is why new National Policy Statements on airport planning should contain a fully comprehensive Airspace Master Plan. CAA/NATS role in the planning process should be strengthened as suggested above. Where consultations are carried out on expansion, basic Airspace Change mapping should be included, to increase public awareness of areas aVected. This is a fundamental flaw with the present approach. For example, the Government consulted widely on the airport expansion proposals presented in the 2003 ATWP, but airspace considerations were confined to a few paragraphs stating simply that: “The Government will now look to the CAA to make early progress in bringing forward a structured programme for the redesign of UK airspace, with a view to the phased implementation of changes to eliminate constraints and permit the integration of the forecast increases in aircraft movements, including traYc using the additional runways proposed in this White Paper” Those being consulted now by NATS, were not necessarily those impacted or consulted by the airport expansion options in the ATWP.This has confined the NATS consultation to questions of “where” rather than allowing communities to voice concerns about the general volume of traYc. 9. With increased commercial capacity, viable Class G airspace for recreational and private flying could decrease. The erosion of uncontrolled airspace could bring recreational aircraft lower, and/or create more intensive corridors as aircraft navigate around controlled areas. This would create problems with increased noise and emissions in these areas. General Aviation has its own environmental considerations, which will not be mitigated by constraining its operations. 10. Personnel issues should be resolved by greater collaboration and training initiatives between the CAA and NATS. For greater integration with land use planning issues, collaboration with Local Authority planners will be necessary. 11. Those benefiting from additional airspace capacity should fund changes. If carriers want greater capacity, they should meet the costs associated with the investment in safe routes- the same applies to airports looking to attract more carriers. Central government backing should be made available to ensure safety standards are maintained, conditional upon consideration of environmental mitigation measures, and maximizing environmental benefits.

APPENDIX A 1. What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented? 2. Can safety be maintained as airspace is increasingly utilised? 3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently? 4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? 5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? 6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive ‘stacking’ while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play? 8. Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? 9. What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined? 10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? 11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? October 2008

Supplementary memorandum from the Aviation Environment Federation (AEF) (AIR 25A) In relation to the Oral Evidence session on 26 February 2009, The AEF would like to make the following clarifying remarks and provide additional information:

1. In Q134, the AEF was asked by the Chair who should produce the accepted thresholds for environmental impacts which, if exceeded, would invalidate airspace change proposals, and how would these thresholds would work? In addition to the oral evidence given to the Committee, we would like to indicate that the environmental targets for assessing Airspace Change Proposals (ACPs) should be determined by Government. In providing its guidance to the CAA, the Government should take appropriate advice from DECC, DEFRA, the Committee for Climate Change Committee, the Environment Agency, and have reference to other expert opinion such as the World Health Organisation. The targets should be consulted on, and originate, from the DfT, who would have responsibility for drawing together the most relevant evidence from the sources mentioned above, and from other government departments. Accountability for the delivery of these targets would rest with the CAA. Substantive targets on environmental thresholds/limits would increase transparency with regard to ASC procedure. For example, on local air quality- ACPs only require information to be collected where there is a potential breach of legal limits on air quality that could be caused as a result of any change. This cannot be conclusively known unless some form of monitoring and assessment is undertaken as standard. The CAA’s functions need to be clarified, with regard to their ability to examine and enforce the environmental aspects of ACPs, and their forthcoming environmental responsibilities as a result of the Pilling review. Clarity is needed on the extent of the CAA’s environmental remit—will they be able to tackle the consequences of intensified airspace use- for example, increased congestion, and surface access? This is important, as paragraph 124 of CAP 725 only currently states that ACPs may wish to make an economic appraisal of the environmental impact of a proposal- and then, only of the benefits generated. There is no requirement to make an economic appraisal of the costs of any environmental disbenefits. As it stands CAP725 cannot provide a robust or balanced assessment of the overall economic or environmental impacts of an ACP.

2. In question 165, Mr Wilshire asked about the integration of the planning process with airspace changes The overall structure of the UK’s airspace, and the framework for how changes to this structure are implemented, has relevance beyond the needs of aircraft operators and the passengers who use their services. Though airspace is not currently part of the town planning process, it does have implications for planning issues including: — land use planning; — the interactions between national and regional strategy; — ability of regional authorities to deliver Regional Spatial Strategies (RSSs); — on the operations of Regional Development Agencies; — the ability of local authorities to meet national indicators on environmental performance; — on the siting and completion of housing developments; and — on projected population totals. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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For example, the impact of location specific changes to routes requires the collection of population data, including projected populations. The statistics for these are not always reliable, but where they can, reference should be made to local housing strategies, regional spatial strategies (RSSs), and the delivery plans for the aVordable housing targets which the Department for Communities and Local Government has levied on the regions. The inclusion of municipal buildings should be a non-voluntary requirement. The impact of changes in noise climate on hospital facilities and schools has been widely identified- therefore in order to reduce the potential damage to service provision that may be instigated by a flight path being routed over a hospital/ school etc, these should be catalogued. Local Authorities of every tier should be statutory consultees on any ACP. This should not extend to having to deliver elements of the consultation themselves, which should be the remit of the proposer. Local authorities currently have minimal statutory authority on aviation emissions or noise. Regulating these impacts is the province of the CAA. This means that the extent of community representation on these key issues can be limited. For example, as the 2M group pointed out, during the Heathrow inquiry, no maps of changes to Public Safety Zones were available to the public, as flight paths for the proposed development had not yet been agreed. Expansion proposals will not be subject to full consultation whilst the public, and the local government oYcers who serve them, are denied detailed knowledge of these proposals. Little can be done by local communities can be done to reverse impacts once change is enacted. This is why the design of airspace changes should run in parallel with any associated airport development or expansion proposal.

3. In questions 166–167, Mr Wilshire went on to critique the concept of airspace changes running in parallel to decisions on expansion, in particular those based on central government policy which were not yet planning applications. AEF had some core evidence on this point, which we were unfortunately unable to give to time constraints. On the basis that central government policy will become the basis for many airport expansion decisions under the framework proposed by the Planning Act 2008, we submit the following supplementary evidence to the Committee. A national Airspace master plan is essential if the Air Transport White Paper (ATWP) is to be updated to a National Policy Statement (NPS). We understand that NATS, CAA and the DfT have already begun working in partnership on a project to this eVect. We oVer our conditional support for the project, on the basis of certain environmental criteria being met. The government has consulted on a long-term airports plan. This cannot be divorced from airspace, which in turn will impact on emerging regulation on environmental limits. It will be diYcult to assess the UK’s ability to meet expansion plans without a national plan. Not only will such a plan help assess the environmental eYciency of the current air space structure, it will also assist in identifying whether it best serves the economic interests of the UK. The Air Transport White Paper (ATWP 2003, revised 2006), whilst not a planning application as such, is the framework upon which planning decisions are likely to be based when it is converted into a National Policy Statement (NPS) as part of the Planning Act 2008. It is also a statement of intent. To assure stakeholders of every stripe of its credibility and deliverability, all of its implications should be fully assessed. Any assessment should contain comprehensive mapping of the airspace blocks and predicted traYc flows required to meet the capacity increases sparked by airport expansion. As the Transport Select Committee (TSC) will have been made aware, the Civil Aviation Authority (CAA) and National Air TraYc Services (NATS) are of the view that, were all of the South East airport development plans9 to come to fruition, there would not be suYcient airspace capacity to accommodate the scale of predicted traYc growth on the basis of current and predicted technology. (Para 28, Competition Commission’s Market Investigation of BAA Submission by the Civil Aviation Authority May 2007) CAP 725 contains an Environmental Assessment framework, but this is not strategically aligned with the ATWP. Firstly, the traYc forecasts required for Airspace Change Proposals (ACPs) are limited to five years, whereas the ATWP provides projections up to 2030. Environmental guidance for ACPs lacks clarity and requires a more prescriptive approach, with targets and goals, set by governmental bodies and delivered by the CAA. It is clear that a strategic assessment of the UK’s airspace is necessary; to ensure that industrial requirements can be met safely, without compromising the delivery of other national and regional policies. Without this, the sustainability of the ATWP cannot be properly assessed. As the system currently stands, NATS is a service provider, tasked with meeting demand. They have duties to consider if various ACPs would provide an environmental improvement, but with a substantial “get out clause” indicating that air traYc management procedures or safety considerations can override this requirement. ACPs are frequently instigated by service users to increase capacity. NATS have no authority to consider whether capacity increases are sustainable, especially whilst operating on a piecemeal basis. CAA and NATS are constrained in their ability to meet sustainability criteria by their duty to satisfy demand requirements. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Airspace is a finite resource. Safety is, by necessity, paramount. The two bodies tasked with delivering Airspace Change have a remit to provide for growth, but, as yet, not an established environmental remit. This means environmental considerations are sidelined in favour of capacity requirements. Safety cannot be compromised; therefore capacity/environmental conflicts should necessarily trigger further sustainability analysis, at a long-term, strategic, forward looking level.

4. Q140–150 involved a discussion of noise nuisance assessment. AEF was not called to respond to these questions, but feels the Committee may find the additional input below useful The AEF was represented on the Steering Group of the ANASE study. We would highlight that the peer review critique was confined to elements of the study, and most comments related to the “stated preference” aspects which attempted to establish a monetary value. The peer review comments from the CAA and Bureau Veritas did raise some concern regarding the methodology for the work assessing annoyance. Nevertheless, in publishing the report, the DfT’s Chief Economist stated “The evidence in ANASE indicates, in my view, that it is highly probable that concern (or annoyance) with a particular level of aircraft noise is higher than found in the ANIS study in the early 1980s.This finding is in line with the emerging findings from the European Commission’s HYENA Study”23. Aviation Minister, Jim Fitzpatrick added: “The Government accepts that noise from aircraft is a growing concern and will take into account those people aVected by aircraft noise when considering the costs and benefits of future projects”24. Given that the report found that annoyance is experienced at far lower levels than the government’s current threshold of 57 dBA Leq, and that annoyance is very dependent on the number of noise events, the AEF believes that it is important to (a) set lower noise thresholds as an indication of “acceptability” and (b) produce alternative metrics that show the changes in the number of noise events. The AEF is pleased to note that the NATS consultation does provide some additional information in respect of the latter. This is very important as no change in the area of a contour does not necessarily mean no change in the number of events (albeit performed by less noisy aircraft) and therefore public reaction. While the Government claims it cannot identify a point that marks the upturn in annoyance below 57 Leq, acknowledging that people are more annoyed while continuing to rely on data from the 1980s cannot be justified. Government should provide update noise thresholds as part of the revised guidance to the CAA outlined above. The Committee may also be interested in an objective measurement for the variable impact of aircraft noise in more tranquil areas. The Noise Gap Index comes from an Australian study, published in 2004, by the University of New South Wales, on Aircraft Noise and Community Impacts.25 It examined whether health related quality of life was worse in communities chronically exposed to aircraft noise than in communities not exposed. The new noise index analyses aircraft noise measurements against background environmental noise levels. It was found that communities with relatively low levels of background noise had significantly diVerent reactions to the introduction of air craft noise than those with chronically high noise levels.

5. General Aviation issues The AEF was given a pre-evidence brief that General Aviation would be a line of questioning. We are aware that the time for questions was reduced as a result of a previous session over-running, so have prepared the following to cover some of the questions the Committee may have had on this topic: The increasing use and expansion of commercial, regulated airspace will have consequential impacts on the general aviation community.General aviation (GA) using Class G airspace is being forced into corridors and concentrated at lower levels. Results from the DAP Stakeholder survey 2004, on the balance of interest between industry stakeholders, showed that whilst Commercial aviation users gave an approval rating of nearly 80%, only 33% of GA respondents felt DAP was Good or Excellent in balancing interests across the sectors, with 50% believing it to be Average. Airspace is not equitably shared between the sectors. There is still a noise issue surrounding smaller airfields. Circuit training and low-flying prop planes and small jets all have a noise impact. Concentrating aircraft at lower levels in restricted areas will mean that people living near to GA airfields will be exposed to greater noise intensity and increased incidences of disturbance. Where GA aircraft are routed around large tracts of regulated airspace, there is a parallel impact on emissions and fuel usage. There is also a potential safety issue with decreasing the volume of unregulated airspace. The CAA’s guidance on safety for unregulated airspace conflicts with some of the NATS TCNorth proposals. The minimum recommended height to avoid bird strike (as given to GA pilots by the CAA) is 2,500ft. NATS TC North proposals included wide-bodied aircraft being given flight paths of between 2,300–3,000 foot over the Chilterns.

23 http://www.dft.gov.uk/pgr/aviation/environmentalissues/Anase/anasechiefeconomist 24 http://nds.coi.gov.uk/environment/fullDetail.asp?ReleaseID%327707&NewsAreaID%2& NavigatedFromDepartment%False 25 http://www.bbsu.unsw.edu.au/documents/AAS 2004 Conf Paper 3 formatted%5B1%5D.doc Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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There are currently few established guidelines regulating flying patterns for uncontrolled airspace, although some good practice guides have recently been developed. There is little statutory enforcement. Regulatory guidelines should be published. This is of particular concern, not only to our membership, but to address the 70% of airproxes that occur in uncontrolled airspace. March 2009

Memorandum from Stop Stansted Expansion (AIR 26)

Introduction Stop Stansted Expansion (“SSE”) was established in 2002 in response to Department for Transport (“DfT”) proposals for major expansion of UK airport capacity, particularly in the south east. We represent over 7,000 members and supporters including 140 parish and town councils, residents’ groups, national and local environmental groups and other organisations. We have no political aYliations. SSE responded to the NATS’ Terminal Control North (“TCN”) Airspace Change Proposal Consultation and a copy is attached as Annex 1.

Summary of Our Evidence — Airspace capacity is only one of the issues arising from the DfT proposals for airport expansion. — The additional airport capacity outlined in the 2003 Air Transport White Paper (“ATWP”) is now based on unreliable data. This is due, inter alia, to subsequent changes in demand, oil prices, aircraft load factors and runway utilization at existing UK airports. — The 2003 ATWP had scant regard for the need for aviation to contribute to the UK’s targets for reducing carbon emissions. — The current approach for planning and regulating the use of UK airspace does not adequately take account of the environmental harms caused by aircraft noise, emissions or visual intrusion. — The establishment of an Airspace Master Plan would have planning benefits. — The management of UK airspace should be more integrated with the rest of Europe including the development of UK airspace changes. — Greater emphasis should be placed on developing new techniques and technologies, in collaboration with European air navigation service providers, to improve the capacity of UK airspace. — There should be a smaller number of competing air navigation service providers in Europe. — The roles of the UK interested parties in airspace design are currently unsatisfactory in that environmental considerations are subordinated to commercial interests. — Airspace implications should be considered as part of any major airport expansion proposal.

Responses to Specific Questions

1. What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented? 1.1 The ATWP is a policy document whose time has passed. In 2003, the DfT was projecting an increase in UK air passenger demand from 180mppa in 2000 to about 500mppa in 2030 and, despite strenuous denials of a “predict and provide” approach, supported airport expansion proposals to cater for 484mppa in 2030.26 Seemingly, therefore, it was a policy of “predict and provide minus 3%” but it has transpired to be “predict and fully provide” because the DfT significantly underestimated the share of UK demand that would be handled by regional airports (and overestimated the demand upon airports serving London). The DfT projected that regional airports would be handling 40% of UK air passengers by 2030 compared to 35% in 2000. However, regional airports achieved a 41% share in 2007,27 just four years after the ATWP was published and the strong regional growth trend continues.

26 Passenger Forecasts: Additional Analysis, DfT, Dec 2003, Annex B4. 27 CAA airport statistics for 2000 and 2007, Table 1 in each case. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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1.2 The DfT has always viewed the rapid growth in air travel as evidence of a looming capacity problem rather than a problem of unsustainable demand growth. In addition, the DfT has never contemplated the possibility that supply can create demand for air travel even though there is considerable evidence to support a supply-led view of the market, particularly in the low-cost sector.28 1.3 The DfT’s projection of passenger demand of 500mppa by 2030 was based on assumptions which were always extremely sensitive to the economic, social and political context and the context has now significantly changed. For example, the demand projection was predicated on an oil price of $25 per barrel and there was scant regard in the ATWP for the need for aviation to contribute to the UK’s targets for reducing carbon emissions. With an 80% carbon reduction target by 2050 now in prospect, it is no longer credible to claim that a “predict and provide” approach to air travel can be reconciled with the Government’s policy for tackling climate change. 1.4 There is also the question of whether there is suYcient airspace in the south east to cater for the level of expansion envisaged by the ATWP and in this context we would draw your attention to the view expressed by the CAA and NATS in a recent submission to the Competition Commission: “To date, all airspace change requests have been managed and implemented. However, the CAA and NATS are of the view that, were all of the SE airport development plans to come to fruition, there would not be suYcient airspace capacity to accommodate the scale of predicted traYc growth on the basis of current and predicted technology.As a consequence, airspace constraints may aVect the future nature and degree of competition in this market.” 1.5 The DfT has also consistently underestimated the ability of UK airports to increase capacity on the existing runway infrastructure. Progressive improvements in technology and improved operating procedures have over the years enabled a steady increase in the number of aircraft movements that can be handled per hour and this is likely to continue to be the case. 1.6 In addition, aircraft have become larger over the years and again this trend will continue. Indeed, a shortage of runway capacity would encourage this. Tokyo International Airport (Haneda) has averaged over 200 passengers per air transport movement (“ATM”) since 2000 whereas Heathrow averages just 143 passengers per ATM.29 Put another way, Haneda handles almost the same number of passengers as Heathrow but with a third fewer ATMs.30 This is largely because the two main Japanese airlines31 operate Boeing 747s with up to 563 seats on short haul routes. Such an approach obviously enables more eYcient use of airspace. 1.7 Airspace is not the only finite resource. Britain is a small, overcrowded island and the South East is its most overcrowded part containing one third of its population in just 12% of its land area (and generating 40% of UK GDP). Land use considerations therefore deserve high priority. Globally also there are finite environmental limits which need to be respected and, as stated above, a “predict and provide” approach to aviation simply cannot be reconciled with the Government’s claim to leadership on the issue of tackling climate change. 1.8 The Government’s own advisors, the Sustainable Development Commission (“SDC”), appear to have recognized the mismatch in aviation policy by calling for an independent commission to review the economic, environmental and technological evidence before any decisions on major airport expansion are taken.32 Unsurprisingly the DfT has dismissed the SDC report, perhaps preferring not to have its evidence base subjected to independent scrutiny. 1.9 In short, lack of airspace capacity is just one of many diYculties associated with the DfT’s proposals for airport expansion in the south east and in our view it would be far more fruitful to initiate a root and branch review of the DfT’s “predict and provide” aviation policy rather than seeking to address, one by one, the many problems arising from that policy.

2. Can safety be maintained as airspace is increasingly utilized? Is there a suitable interface between military and civilian arrangements for air traYc control? 2.1 As indicated above, it is not necessarily the case that UK airspace should be increasingly utilized. Safety is of course of paramount importance and any intensification in the use of airspace over the south east of England—a densely populated area and already the busiest airspace in the world—is bound to give rise to safety concerns. 2.2 SSE has no comments to make on the interface between military and civil arrangements for air traYc control.

28 For example, oral evidence by Mr David O’Brien on behalf of Ryanair to Uttlesford District Council (“UDC”) in connection with BAA’s G1 planning application, UDC webcast, 4 July 2006. 29 “Transport Statistics: Great Britain, 2007”, Tables 1 and 6 30 Haneda handled 66.8m passengers in 2007 compared to 67.9m at Heathrow. 31 JAL and ANA. 32 “Breaking the Holding Pattern”, SDC, May 2008. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently? 3.1 The current approach to planning and regulating the use of UK airspace does not adequately take account of the environmental harms caused by aircraft noise and emissions or visual intrusion. It does not seek to establish a trade-oV between benefits to the user (ie the airlines) and environmental harms to the community and certainly does not provide environmental benefits to the community. This issue is further described in our attached letter to the CAA (Annex 2). 3.2 It is considered that an Airspace Master Plan covering the period of the ATWP would be beneficial. It is untenable that the 2003 ATWP extends to 2030 and yet the 2008 major TCN Airspace Change Proposal only has a horizon of 2014. This means that the full implications of airport expansion proposals cannot be understood by local communities and others. The information is simply not available at the planning inquiry stage. It is also desirable to maintain stability of air routes over as long a period as possible in order to bring greater certainty to land-use planning, the housing market and noise-sensitive development in general. 3.3 It would be more eVective if individual airspace developments were reviewed against the backcloth of an Airspace Master Plan. There should be a computer model of the whole of UK airspace such that likely future scenarios can be tested and redesigns validated within the whole system.

4. How are the eVects of aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? 4.1 The eVects of aircraft noise and emissions are not adequately taken into account when changes are made to airspace. A current example of this inadequacy is the NATS’ TCN Airspace Change Proposal. The methodology used by NATS to calculate the population aVected by noise is flawed and underestimates the adverse impact. Its methodology for estimating the fuel burn/emissions per flight shows a neutral result in total across a region of over 12 million people. That means there will be no overall environmental benefit for these changes throughout the whole system. The proposed new routes for aircraft using Stansted Airport, for example, would increase the total track mileage in this region by an average of 2,500 per day. This clearly has environmental disadvantages both to local communities and the world at large. Further information concerning this issue is given in our attached letters to NATS and the CAA. 4.2 In the case of the TCN Consultation, the NATS’ Initial Feedback Report dated July 2008 showed that over 15,000 responses were received and that 86% of the members of the public and 77% of the representative groups were opposed to the changes. NATS identified 27 key themes in the responses. For the representative groups, the three main themes for objection were tranquillity, aircraft noise in general and noise over rural areas. The fourth main theme was climate change and CO2 emissions and significantly the fifth main theme was the development/consultation process itself. The public’s main themes for objection followed a similar pattern with tranquillity and noise over rural areas ranking significantly above the other issues. 4.3 If a conflict is found to exist between user eYciency gains and environmental gains, priority should be given to delivering environmental gains. 4.4 In SSE’s opinion the NATS’ TCN Airspace Change Proposal Consultation was flawed. One of the deficiencies was the inadequate involvement of the public and their elected representative bodies. This is further discussed in our attached letter to the CAA (Annex 2). There needs to be a fundamental improvement in this process which should also be carried out against the backcloth of an Airspace Master Plan.

5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? 5.1 The management of airspace in the rest of Europe aVects flights into the UK and ideally this total continuum of airspace should be seamless. Upper airspace can be managed in what are termed large functional blocks and this principle should be extended as widely as possible. It is operationally and technically possible to safely and eYciently control air traYc throughout Europe both for en-route traYc and traYc in the terminal marshalling area without the current plethora of Air TraYc Control Centres in every country. A smaller number of pan-European centres should undertake the task and this would also bring cost savings such that airlines would pay lower user charges. 5.2 An example of good European integration is the Eurocontrol Central Flow Management Unit in Brussels which, through co-ordinated management of the air traYc throughout Europe, seeks to minimise congestion in the air and make the most eYcient and eVective use of available capacity. 5.3 A smaller number of centres each having control over a larger volume of airspace throughout Europe would necessitate an integrated approach to air traYc management, including the development of UK plans for airspace changes. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realized? Could environmental benefits be gained as a result of such improvements? 6.1 A considerable amount of research and development eVort is currently underway in Europe on new techniques and technologies to improve the eYciency of air traYc management through improved controller tools, for example, reduced separation minima, flight trajectory prediction, tailored arrival procedures and air traYc flow and capacity management (optimizing network capacity through collaborative decision making processes). In addition there have been considerable advances in aircraft flight deck avionics using satellite technology for improved communication, navigation and surveillance. 6.2 Better dynamic flight planning is the key to avoiding wasteful flying on indirect routes and excessive stacking. This requires the early introduction of improved controller tools and an integrated “end-system” approach between the ground and airborne systems. Such tools would provide a much more eVective “gate to gate” operation and reduce wasteful flying. 6.3 When considering the stacking problem, it is often asked why aircraft are allowed to leave the departure airport only to be subsequently stacked whilst waiting to land at the arrival airport. The aircraft should not have been allowed to depart in the first place. The introduction of new controller tools would enable the flow and capacity of the total system to be more eVectively managed. 6.4 The realization of these potential improvements will require a more collaborative approach throughout Europe and a greater willingness to standardize on system architecture and solutions. Additionally the timescales from initial design to introduction into service of ground based ATM equipment are too long and need to be speeded up. 6.5 Reduced stacking would clearly bring environmental benefits and provide an opportunity to deliver environmental benefits through more sensitive routing and sequencing.

7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play? 7.1 The change process for the redesign of airspace is set out in CAP 72533 and NATS is the sponsor for the current TCN Airspace Change Proposal. In our letter to the CAA (Annex 2), we draw attention to an apparent conflict of interest whereby NATS is a limited company controlled by BAA and seven major UK airlines. Furthermore, the shareholder objectives focus on eYciency considerations and do not include any environmental objectives. We regard this as an unsatisfactory state of aVairs whereby environmental considerations are subordinate to the commercial interests of the aviation industry shareholders. This subordination is manifest in the TCN proposals where there are clearly potential cost savings for airlines but significant adverse environmental consequences for the community in terms of aircraft noise, emissions and visual intrusion, aVecting over 12 million people. 7.2 The change process has to undergo regulatory assessment by the CAA before any approval can be given and the changes then require to be approved by DfT. However, the CAA has no environmental remit and we have little confidence in the DfT to act as a guardian of environmental interests when its main focus is upon promoting the interests of the UK aviation industry. Consideration should be given to involving DEFRA, DCLG or the new department for Energy and Climate Change in the process.

8. Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? 8.1 Airspace management considerations are currently outside the scope of the planning process and so should not give rise to any delays in the planning process, except insofar as their exclusion gives rise to misunderstandings and arguments. As we have argued above, we believe it is quite wrong that airspace implications cannot be considered as part of any proposed major airport expansion project. An Airspace Master Plan would be a useful tool in informing planning decisions—whether dealt with by the present planning system or by the proposed new Infrastructure Planning Commission.

9. What could be the implications for smaller airfields, recreational flying and helicopters if changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined? 9.1 No comment.

33 CAA Guidance on the Application of the Airspace Change Process, 30 March 2007. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? 10.1 No comment.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? 11.1 The air navigation service provider should fund airspace changes and recover the costs through user charges. 11.2 A smaller number of European air navigation service providers competing for fixed term contracts for the provision of air traYc control over larger blocks of airspace would be a more cost eVective way of operating European airspace. October 2008

Memorandum from the Strategic Aviation Special Interest Group (AIR 27)

Introduction SASIG is the Strategic Aviation Special Interest Group of the Local Government Association (LGA) with a membership of 54 Local Authorities representing 14 million people, or approximately a quarter of the UK population. SASIG seeks to ensure that any national aviation strategy for the UK is implemented through regional planning guidance and other planning processes so as to reconcile economic, social and environmental issues in a sustainable way.

SASIG’s Key Recommendations — Early assessment of airspace requirements Aviation proposals resulting in increased capacity must be supported by assessment of the airspace requirements. — Production of an Airspace Master Plan for the UK An Airspace Master Plan for the UK should be drawn up using robust, independent evidence, and integrated fully into a review of the 2003 Aviation White Paper. This Airspace Master Plan should also inform the production of a National Policy Statement for aviation. — Greater understanding and consideration of community impacts of aviation Increasingly congested airspace should, where necessary, lead to capacity constraints for reasons of safety and environmental protection.

Responses 1. The additional airport capacity outlined in the 2003 Air Transport White Paper (ATWP) necessitates consideration of airspace for the associated increase in air transport movements. These considerations were not made in preparation for the White Paper, and to date the airspace requirements for the ATWP proposals have still not been assessed. Earlier this year, NATS consulted on proposals for airspace changes associated with Stansted, Luton and London City airports—the Terminal Control North (TCN) airspace block. Despite this being one of the largest airspace change proposals undertaken for the UK, it did not address the ATWP proposals for the airports within TCN. The shortcomings of the TCN airspace change proposal, in terms of longevity, consideration of future development on the ground, consultation support and public engagement, and overall environmental gains, must be addressed in subsequent airspace consultations. Further research and consideration of the viability and impacts of rural routing being used in preference to flying over urban areas is required. This may require revisions to current strategic guidance. The growth projections outlined in the 2003 ATWP may or may not be met. Revised forecasts are required to future-proof the ATWP proposals—a Progress Report is not suYcient; a full review of the proposals is required to provide for long-term, robust, strategic planning, in place of the piecemeal, incremental proposals in the ATWP. Reassessment of oil prices and the increasingly unpredictable marketplace are required to ensure that the capacity that is provided is actually used. This would reduce pressure on airspace operators to provide capacity beyond safe and environmentally sustainable levels. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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EU-wide airspace blocks could provide for an increase in capacity, as could estuary airport solutions, and over-seas stacking. These elements should all be assessed in terms of airspace management considerations. 2. Safe operations must be maintained at all times. As routes become increasingly congested, safety requirements must not be compromised and penalties for level-busts must be severe. This should be taken into consideration when deciding on the location of new capacity. Amongst other issues, capacity increases may aVect the size and location of local Public Safety Zones, and thus land-use planning decisions. The operational interface between military and civilian arrangements for air traYc control must provide for the most eYcient use of airspace, taking account of safety, environmental, social and economic considerations. 3. The planning and regulation of UK airspace requires long-term strategic support. This means that an Airspace Master Plan, based on comprehensive and independent evidence, covering at least the period of the Aviation White Paper but ideally to 2050 and possibly beyond, is needed. Without this, it remains diYcult to determine whether or not the White Paper projections can be safely met. The Airspace Master Plan should be used to inform the production of a National Policy Statement for aviation, and should address, for instance, the following elements: maps of airspace blocks across the UK in association with airfields; the current air quality and noise emission conditions in each block; the relevant limits to not be breached for air quality and noise conditions in each block; the measures needing to be implemented to manage and reduce noise and air quality in each block; and following consideration of the aforementioned prerequisite elements, the current and potential capacity per block in terms of air transport movements by type. To date, airspace has been considered on a piecemeal, incremental basis, and a national overview is very overdue. A UK Airspace Master Plan should be used to inform the airspace considerations that should be provided in support of development proposals. 4. The eVects of aircraft noise and emissions on local populations are not given equal footing with capacity considerations. There should be accepted thresholds for environmental impacts which, if exceeded, would invalidate Airspace Change Proposals. More hard evidence should be gathered to ensure that environmental impacts are considered on a par with economic and safety statistics. Local Authorities should provide input to the collection of that evidence, and be key consultees for Airspace Change Proposals. 5. Better integration with EU airspace is necessary if coastal stacking is to be an option. A single integrated EU airspace block would increase eYciency by allowing controllers to better regulate the speed of traYc arriving in UK airspace. 6. The environmental gains to be achieved from the Terminal Control North airspace change are minimal, and in contrast to the environmental impacts of the growth envisaged, particularly in already congested airspace. Greater emphasis should be placed on maintaining environmental standards, which should not be considered as subsidiary to capacity constraint considerations. It is disappointing that the increasing use of Controlled Descent Approaches (CDA), Precision Area Navigation systems (PR-Nav), and other technological advances, have not led to more significant environmental gains. Further assessment of these technologies is required to fully understand the extent and impacts of their use, particularly in terms of the community impact of aircraft noise. 7. Provision of expert advice and data needs to be made earlier in the consideration of development proposals. Currently, NATS is the main airspace control provider, and as such should be required to provide data to inform airspace considerations in relation to development proposals. NATS’ advice regarding capacity limitation should take precedence over externally set growth targets. In order for the CAA to strengthen its reviewing process of actual operations, it must be appropriately resourced, to enforce adherence to their CAP 725 Airspace Change Process Guidance. 8. Under current arrangements, airspace management is given no consideration in airport development proposals. In order to make informed, robust decisions on such proposals, it is necessary for airspace management considerations to be provided prior to decisions regarding consent or refusal being made. The issue is not one of delay, more a matter of having the necessary information available at the correct point in the process. The Aviation National Policy Statement should contain a fully comprehensive UK Airspace Master Plan. The proposed new Infrastructure Planning Commission (IPC) is intended to consider only those projects defined as Nationally Significant Infrastructure Projects (NSIPs). There will be a need for coordination between the IPC, airspace control provider(s), the CAA, Local Authorities, the Department for Environment, Food and Rural AVairs (Defra), the Department for Communities and Local Government (DCLG), and the Department for Transport (DfT). 9. Allocation of a greater proportion of airspace to commercial operations will reduce to some extent the airspace available for smaller airfields, recreational flying and helicopters. This could in turn lead to a lack of training opportunities and a subsequent skills and employment shortfall. It is essential that public consultation adequately captures the community impact of overflying—area that still requires further research and consideration. Assessment and monitoring of the impact of new routes and altitudes is essential in order to inform an appropriate balance between such conflicting priorities. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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10. It should be possible to resolve personnel issues such that airspace changes can be implemented in parallel with additional airport capacity. 11. Those who benefit from additional airspace capacity should fund changes. If carriers want greater capacity, they should invest in safe routes—the same applies to airports looking to attract more carriers. Central Government backing should be made available to ensure safety standards are maintained. October 2008

Memorandum from The Boeing Company (AIR 28) Boeing is pleased to submit evidence to The House of Commons Transport Committee’s inquiry into the use of airspace. This response includes a discussion of airspace utilization issues and is based upon existing features on current Boeing and other commercial aircraft as well as extensive research and technology programmes.

General Information 1. Boeing is the world’s leading aerospace company and the largest manufacturer of commercial jetliners and military aircraft, with capabilities in rotorcraft, electronic and defence systems, missiles, satellites, launch vehicles and advanced information and communication systems. Our reach extends to customers in 145 countries around the world, and we are the number one US exporter in terms of sales. Headquartered in Chicago, Illinois, USA, Boeing employs more than 160,000 people in more than 70 countries. 2. Boeing has a long standing relationship with the UK dating back over 70 years and today the UK remains a critically important market for the company, as a supplier base and a source for technology partners. Boeing’s annual spend in the aerospace industry supports thousands of jobs around the UK, in the process generating intellectual property and facilitating exports. 3. Boeing sources more from the UK than from any other country in the world, except the USA. Typically in the UK, the company sources up to $3 billion of services and materials from around 300 UK suppliers. There are currently more than 650 Boeing UK employees, in locations from Almondbank to Gosport.

Boeing Commercial Airplanes 4. Boeing Commercial Airplanes (BCA) is the world leader in commercial aviation because of its complete focus on airplane operators and the passengers they serve. Boeing products and services deliver superior design, eYciency and support to airline customers and allow passengers to fly where they want to go, when they want to go. By working together with supplier partners from around the world, Boeing has delivered more than 15,000 airplanes to customers worldwide including airlines, leasing companies, governments and private firms. 5. Boeing Commercial Airplanes is headquartered in Renton, Washington, under the leadership of President and Chief Executive OYcer, Scott Carson. It is organized into three primary business units—787 Program, Airplane Programs and Commercial Aviation Services—as well as providing Airplane Trading services.

Airspace Optimization 1. Air safety can and must be maintained as airspace is increasingly utilized. This is the aviation industry record and Boeing expects this emphasis to continue. There are new ATM technologies that will not only support increased utilization but will yield new opportunities for environmental improvements by promoting the most eYcient possible use of the airspace system in terms of fuel savings and noise reduction. 2. The eVects of aircraft noise and emissions are taken into account when changes are made to the use of airspace. These changes are generally preceded by consultations with aviation stakeholders. This process results in the presentation of relevant facts, data, and opinions which the UK government takes into account before choosing a course of action. This UK process has the additional advantage that it helps ensure adherence to the ICAO Balanced Approach, which requires airports and governments to consider alternatives before imposing operational restrictions and/or noise and emissions reductions at the source. 3. When changes to airspace are proposed, interested aviation stakeholders should be consulted for facts, data, and opinions. It is especially important to consider, in some detail, the impact of airspace changes to noise and emissions and the resulting eVect on residents and national environmental goals or targets. 4. Boeing recommends that a balance of conflicting interests can be struck by the Government on airspace utilization issues, however it must promote the most eYcient transfer of goods and services possible within the global air transport system without compromising safety. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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5. There are opportunities to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive holding. There is significant opportunity to integrate new ATM capabilities into an operational model for London TMA. These capabilities, such as RNP and RNAV, coupled with ATM re- design will support the reduction of delay (holding stacks), improve environmental performance (CDA’s and Tailored Arrivals), and allow more direct flight routing. 6. These opportunities will best be realized through the integration of airspace design and airplane capability. These actions in conjunction with regulation harmonization will allow timely implementation of these capabilities. 7. Boeing believes that there are airspace operational and environmental benefits to be gained as a result of such improvements. The evidence is clear that any reduction in indirect routes or excessive delay will provide environmental benefits. Continuing the status quo will result in greater fuel burn than theoretically necessary, with a direct increase in emissions. What may be less apparent is that reducing indirect routes will tend to result in less fuel capacity needed at takeoV, reducing takeoV weight and departure noise exposure. Reducing excessive holding, particularly if combined with Continuous Descent Approach starting from top of descent, coupled with other airspace optimization will tend to result in less noise exposure under the flight path on approach.

Conclusion 8. Overall Boeing believes that there is scope for improving the operational performance of Britain’s airspace, as there is for many countries around the world. Much of the technology that can deliver improvements is in existence today and Boeing is actively working with air traYc service and airline partners in particular. Further information is available from Boeings’ corporate oYce at 16 St James’s Street, London, SW1A 1ER. October 2008

Memorandum from the National Air TraYc Service (NATS) (AIR 29)

1. Introduction 1.1 NATS is the UK’s leading provider of air traYc management services. We are regarded as a world leader in our industry, voted in 2007 the best Air Navigation Services Provider (ANSP) in the world in an independent survey of the industry including other ANSPs, systems manufacturers and airlines. 1.2 NATS was established as a PPP in 2001 and is now owned 49% by the UK Government, which also maintains a Special Share; 42% by The Airline Group, a consortium of UK airlines; 5% by its employees, and 4% by BAA. 1.3 NATS comprises two businesses. NATS En Route plc (NERL) is the monopoly provider of en-route air traYc services in the UK and the north east quadrant of the North Atlantic, provided under licence from, and regulated by, the Civil Aviation Authority (CAA); NATS Services Ltd (NSL) is NATS’ non-regulated business providing air traYc services at many UK airports and is NATS’ interface with the wider UK and global ATM markets. 1.4 The terms of NERL’s licence from the CAA require the company to be capable of meeting on a continuous basis any reasonable level of overall demand. NERL is charged under its licence with permitting access to airspace on the part of all users whilst making the most eYcient overall use of airspace. 1.5 In other words, NATS’ job is to meet the air traYc service requirements of airlines and others using UK airspace, including the Military, and to control traYc safely and eYciently. NATS does not establish airspace policy, which is the responsibility of the Directorate of Airspace Policy (DAP) at the CAA. 1.6 NATS welcomes the Committee’s interest in the use of airspace, and this opportunity to contribute answers to your questions as part of your inquiry. We would also like to renew our invitation to the Committee to visit the Swanwick Centre to help inform your debates.

2. Summary 2.1 NATS’ submission to the Committee responds to the questions posed and we would be happy to provide further explanation should the Committee find that helpful. In summary, our responses make the following points: — Airspace design is complex and must accommodate many interactions; it requires significant planning. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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— Airspace in south-east England, in particular, is the most complex in the world and if all the airport master plans accounted for in the White Paper come to fruition at the maximum capacity, there will not be suYcient airspace capacity to accommodate the scale of forecast traYc growth on the basis of current and predicted technology, without the imposition of delays and a reduction in overall eYciency. — Airspace requirements—and constraints—must be recognised in the earliest stage of aviation policy making. — Airspace is as important a part of the airport infrastructure as runways and ground access and must be factored in to consideration of airport expansion. — Detailed airspace design requires specialist expertise; this is a costly resource which must be used eVectively and is only applied once policy has been clarified. — Greater clarity is required in some areas of Government policy, notably environmental policy on matters such as concentration/dispersal of noise and relative importance of noise/emissions; this in turn will enable clearer guidelines provided by the CAA for airspace design and future airspace rule-making. — Priority should be given to maximizing the capacity of existing infrastructure, rather than building new infrastructure; new capacity provided through new runways can be used to build resilience into airport operations, particularly at busy airports such as Heathrow.

3. Responses to the Committee’s Questions

3.1 What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? 3.1.1 Any changes to airspace would be dependent on the nature and extent of any specific planned airport expansion. A sizeable expansion may well require new procedures which would trigger an Airspace Change Proposal, the formal process under CAA guidelines which airspace change sponsors, such as NATS, follow for all airspace development. 3.1.2 A major limiting factor to increasing airspace capacity in the South East is the complex interactions between routes serving a large number of airports within a relatively small geographical area. To date, all airspace change requests have been managed and implemented, but ultimately NATS agrees with the CAA that if additional runways are built at Heathrow and Stansted, and if, in the unlikely event, all of the other SE airport master plans accounted for in the White Paper come to fruition at the maximum capacity, there will not be suYcient airspace capacity to accommodate the scale of forecast traYc growth on the basis of current and predicted technology, without the imposition of delays and a reduction in overall eYciency. 3.1.3 NATS has not carried out detailed work to assess individually the airspace implications of any of the airport expansion proposals currently being considered (eg a third runway at Heathrow or a second runway at Stansted). Until a decision is made on these significant developments, there is no basis for carrying out this extremely labour-intensive and costly work. 3.1.4 Airspace changes are undertaken only when necessary and take account of traYc growth since the previous change, as well as acknowledging the general forecast increase in traYc volumes. For instance, the recent proposals for the Terminal Control North area (the most complex area of airspace in the world) were not designed to support runway expansion at any individual airport, but to reflect the growth in air services over the past 15 years, as well as accommodating the forecast air traYc arising from general airport growth under the provisions of the White Paper. 3.1.5 Changes that may be required could include revised route structures, airborne holds (or stacks) and flight paths to give greater consistency of aircraft tracks, to segregate and separate flight paths, improve operational eYciency, increase capacity/reduce pre-departure delay, enhance safety and reduce environmental impact. 3.1.6 In terms of airspace management, NATS would apply new techniques and tools to support the most eYcient use of any new routes and airspace. This includes: — Greater use of support tools to accurately manage the integration of arrival and departure flows. — Greater co-operation and data sharing between all elements of the network (ATC, airport operations and aircraft operators—otherwise known as Collaborative Decision Making (CDM). — Greater data sharing, interoperability and co-operation between adjacent ANSPs for better delivery of aircraft into the south-east. — Better integration of aircraft from smaller airports into the network to reduce the impact of aircraft using busy airports. — Application of performance based navigation requirements on aircraft to reduce distances between flights and improve the accuracy of the tracks flown. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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3.2 Are the White Paper’s projections for increased passenger demand still accurate? 3.2.1 This is not a matter for NATS.

3.3 Are all the measures to provide for increased passenger demand likely to be implemented? 3.3.1 This is not a matter for NATS. However, it is important that NATS makes it clear to policy makers that the projections and aspirations of airport operators will ultimately aVect strategy and airspace design requirements and capabilities, and that therefore policy decisions must reflect clear priorities.

3.4 Can safety be maintained as airspace is increasingly utilised? 3.4.1 NATS’ first priority is safety and this will not be compromised; as airspace becomes increasingly constrained, so safety is assured by reducing the number of aircraft in the system, which leads to the introduction of flight delays. However, whilst airspace capacity is a finite resource, it will increase safely over the next 30 years or so through improved procedures and new technology and ATC tools.

3.5 Is there a suitable interface between military and civilian arrangements for air traYc control? 3.5.1 The civil/military interface in the UK is extremely good, and significantly better than anywhere else in Europe. Military controllers share NATS’ centres and the level of interaction is high with the introduction of initiatives such as flexible use airspace. However, it is certainly true that the level of demand outlined in the White Paper will require even greater flexibility to accommodate civil flights during peak periods. NATS’ ability to feed traYc into Europe can be inhibited by other countries’ military activities, so better co- operation between adjacent States would be helpful. Whilst the ATC arrangements are eVective, Government must recognise that policy on military matters, eg the location of bases, may also aVect airspace eYciency.

3.6 Is the current approach to planning and regulating the use of UK airspace adequate? 3.6.1 There is a need for a review of regulatory process with a fast track process for changes that support national transport policy statements. NATS accepts the importance of public scrutiny of proposals that can aVect flight paths over communities; however the current system is very susceptible to repeated and extended challenge which can seriously compromise the need for change within reasonable time limits and severely constrain the development of airspace in support of wider policy objectives.

3.7 Would an Airspace Master Plan covering the period of the White Paper be beneficial? 3.7.1 It is essential to have an Airspace Strategy, or master plan, owned by the CAA and which describes how it will address the objectives of the White Paper, albeit that the White Paper is aspirational. In order for such a strategy to form an eVective basis for planning assumptions, it needs clear policy direction on priorities between operations at diVerent airports. NATS’ airspace development programme should deliver this airspace strategy.

3.8 Could a piecemeal approach to individual developments necessitate additional redesigns subsequently? 3.8.1 This would be a risk to longterm stability in airspace development, particularly in airspace as complex as in southeast England where there are many inter-leaving routes and competing airports. This makes it diYcult to provide a complete picture of change and to plan eVectively.

3.9 How are the eVects of aircraft noise and emissions taken into account when changes are made to the use of airspace? 3.9.1 NATS is establishing a set of environmental best practices for airspace design. Whilst we have in- house expertise we also sub-contract external agencies to ensure we fully meet CAP 725 requirements in terms of noise, emissions and Local Air Quality assessments.

3.10 Who should be consulted about such changes? 3.10.1 The current regulatory process requires change sponsors to liaise with CAA DAP on consultation requirements which may vary depending upon the scale of the proposed change. NATS believes that airspace change in support of nationally agreed transport policy decisions should be conducted with appropriate representative bodies, local authorities and aviation stakeholders. Feedback from the recent TCN consultation shows that representative local authority bodies whom NATS consulted are representing the views of their electorate and raised the same issues as members of the general public. This does not restrict the right of individual members of the public to make their own representations on information provided. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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3.11 How should the balance between conflicting interests be struck?

3.11.1 The White Paper represents the best opportunity to date to ensure that new airport capacity can be used to build resilience into the system and to reduce the amount of airborne holding. NATS as airspace design experts believes it is ideally placed to ensure safety, and strike the right balance between providing capacity and minimising environmental impact. More rigorous environmental guidance, particularly on the balance between emissions and noise, will support this approach, whilst air transport policy should state clear priorities.

3.12 How does the management of airspace in the rest of Europe aVect flights into the UK?

3.12.1 The UK contributes a significant percentage of aircraft into the core of Europe, not only through local European traYc, but also because of its unique position as Europe’s primary North Atlantic gateway. The eYcient transfer of aircraft from one ANSP to another can fundamentally aVect the capacity of the ATM system. Single European Sky developments will further reinforce close working together by adjacent states to develop the most eYcient procedures to ensure seamless transfer of aircraft across boundaries.

3.13 Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries?

3.13.1 NATS is fully committed to working with European partners to enhance the ATM system and is a leading participant in SESAR and FAB development. The proposed network management role in the new Single European Sky proposals will help embed best practice.

3.14 What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land?

3.14.1 Stacking is caused by more traYc arriving at an airport than the runway(s) can support; it enables controllers to ensure there is a pool of aircraft available to maintain the optimum use of runway space at busy airports. For instance at Heathrow, the runway is scheduled at a rate of 99% of available capacity based upon an average holding period of 10 minutes. 3.14.2 NATS is developing new tools and working with other ANSPs and airlines to enhance arrival management to reduce the need for airborne holding, as well as mitigations to reduce the impact of holding such as Required Navigation Performance (RNP) procedures to minimise environmental impact of noise, Continuous Descent Approaches (CDA), new tools to meter and manage departures to reduce ground holding and provide eYcient flows through points to provide better climb and descent profiles and improve capacity, and new closely spaced routes to manage flows.

3.15 How can the potential of any such opportunities best be realised?

3.15.1 Building resilience into airport operations is vital—ie not scheduling to maximum capacity; or by increasing capacity. New arrival and departure procedures using new technology which is under development will also contribute, as will greater collaboration between ANSPs to develop systems and provide economies of scale in development and deployment (such as through SESAR in pursuit of the single European sky). 3.15.2 It is also vital to work with the Regulator to be proactive in developing and approving such procedures well ahead of actually needing them and, where necessary, mandating equipment to ensure consistency of application.

3.16 Could environmental benefits be gained as a result of such improvements?

3.16.1 Yes, however we need to be clear about the nature of any benefits notably the diVerent focus on noise, fuel burn, air quality that is achieved in certain phases of flight (to assist understanding of the design) as not all can be achieved in busy and complex airspace. A clear policy direction from Government is also essential to set environmental priorities as a framework. 3.16.2 NATS is the first air navigation services provider in the world to set an environmental target, to reduce ATM CO2 for aircraft under our control by 10% by 2020 against a 2006 benchmark. Benchmarking work will be complete by the end of this year. Processed: 06-07-2009 18:46:59 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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3.17 In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? 3.17.1 It takes significant time and resource to develop and implement airspace change (following the airspace change process guidelines contained in CAP725) in order to support any national policy decisions on airport growth. NATS believes these considerations can be underestimated by the Department for Transport and by the DAP. 3.17.2 The DAP’s consultation guideline document, CAP725, is intended to be a living document to be updated in the light of experience. In NATS’ view these guidelines should now be reviewed, particularly in light of the recent consultation on proposed changes to airspace in the Terminal Control North region of south-east England where environmental direction and guidance, in particular, was unclear. 3.17.3 A more pro-active approach to translating Government policy into practical guidance will help ensure that potential future airspace requirements to accommodate growth are known and acted upon in a timely manner.

3.18 Are the structures of the parties appropriate for undertaking the roles that they should play? 3.18.1 DiYcult decisions lie ahead and NATS requires ongoing reassurance that the DfT and DAP are suYciently organised and resourced to provide the necessary guidance and policy direction, and properly equipped to make the necessary decisions within realistic timescales.

3.19 Do airspace management considerations delay the planning processes in relation to airport development proposals? 3.19.1 The current process builds in the potential for three separate sets of consultation on the same policy decision—first the Government policy decision itself, second the airport operator’s planning application (with possibly a public inquiry) and third, following approval, the airspace implications of the development. 3.19.2 NATS will provide feasibility studies to help policy and planning decisions; for instance NATS provided the DFT with feasibility studies for its consultation in autumn 2007 on the future of Heathrow. However, airspace design is extremely costly and NATS cannot undertake detailed work until after a policy decision is made on the development itself; whilst this does not delay the planning process, it must be factored into the timescale for any development proposal. 3.19.3 It is important that decisions on airport development are taken with the understanding of potential airspace development timescales, ie design development, consultation requirements, possibility of Judicial Review.

3.20 How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? 3.20.1 So far as NATS is aware, it has been decided not to bring airspace management within the remit of the Commission. However, NATS will play a full role in ensuring that the Commission is fully informed on the airspace implications of any development provided we know well in advance of any decision and that we are an integral consideration in the decision making process.

3.21 What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? 3.21.1 Any increase in capacity by commercial airports puts additional pressure on airspace and can lead to a requirement to establish additional Controlled Airspace (CAS). This inevitably aVects military operations, smaller airfields and recreational flying and so any decision on airport expansion must be taken with a full understanding of national transport policy/ priority and the airspace implications assessed by NATS. 3.21.2 Whilst NATS is responsible for traYc operating in CAS, our operating licence requires us to provide access to airspace for all users. Our airspace design proposals aim to make minimum demand for additional CAS.

3.22 How should an appropriate balance between conflicting priorities be determined? 3.22.1 NATS is responsible for the safe and eYcient management of controlled airspace, not for policy. In developing airspace, we ensure safety, and apply a balance between delay/capacity and the environment whilst ensuring the key objectives for the design are met. That balance will need to be assessed by the DAP when an ACP is delivered (assuming current process is followed), satisfying its statutory obligations. However, clearer guidance to support the national policy decision will assist this balance to be struck. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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3.23 Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? 3.23.1 Airspace design expertise is in very short supply to deliver significant change, especially given the new ATM techniques being developed which will deliver more technical rather than procedural solutions to providing capacity. Creating that expertise is costly and it is a delicate balance to ensure that suYcient designers are available to meet expected demand; advance planning and a sensible sequential approach to airport development are therefore essential. 3.23.2 In terms of controller availability, NATS’ standard processes ensure that suYcient controllers are appropriately trained for delivery to the operation in a timely manner.

3.24 Who should fund airspace changes? 3.24.1 Airspace change is generally required because of expansion by airports or airlines. Airport owners generally fund changes required by their expansion, within their own control zone; funding for en-route changes required to accommodate that expansion and to increase eYciency in the face of growing volumes, required under NATS’ licence, is recoverable through route charges to airlines, which are set for five-year periods through NATS’ regulatory review by the CAA. This seems to be an equitable way of funding required change; it also ensures that only necessary change is undertaken.

3.25 Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? 3.25.1 This depends on the scale and timescale of redesign required and whether the process can be accommodated through the five-year funding mechanism in NATS’ licence. The scarcity of skilled airspace designers means that in the unlikely event of all airports wishing concurrently to expand in line with their masterplans, this will place pressure on NATS’ resources, and therefore on funding.

4. Additional Information:New Airport in the Thames Estuary 4.1 NATS also anticipates that the Committee may wish to explore the Mayor of London’s proposal to build a Thames estuary airport and to close Heathrow. 4.2 NATS has always been clear that we believe the UK should maximise its existing airport infrastructure rather than building new airports. Airspace is too often the forgotten factor in consideration of aviation expansion, particularly airport development. Airspace is often as constrained as ground infrastructure, particularly in the congested airspace of south-east England, and its consideration is vitally important. 4.3 Establishing a new airport in the Thames estuary would require complete redesign of the entire London terminal airspace; it is not feasible simply to drop the airspace requirements to support a new airport into the existing infrastructure. This would potentially constrain other airports in the area. There are additional considerations in terms of the proximity of neighbouring states and interaction with adjoining airspace with The Netherlands and Belgium, and the potential eVects on other operations, eg the Shoeburyness firing ranges oV the coast near Southend. October 2008

Supplementary memorandum from Nation Air TraYc Services (NATS) (AIR 29A) Thank you for the opportunity to present oral evidence to the Transport Select Committee’s inquiry into the use of airspace on 18 March. Following that session, we have been asked to provide supplementary evidence to the Committee regarding whether NATS will make an undertaking to “inform the Committee if it became concerned about the possibility of developments at the European level leading to a dilution in safety standards”. The highest priority for NATS is safety. Our safety objective is to maintain and improve standards to achieve the highest levels of safety performance. To this end the whole structure and culture of NATS is focused on safety. NATS is subject to rigorous safety regulation from the Civil Aviation Authority (CAA). The UK model of independent safety regulation is increasingly being adopted world-wide in the Air TraYc Management (ATM) industry. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Internally, we apply a systematic safety management system (SMS) to all operational activities and were amongst the world’s first Air traYc providers to do so. This formal approach is founded on documented safety policies, safety principles and safety procedures. The system forms the basis for risk assessment, safety assurance, safety control and safety monitoring. The SMS maintains explicit safety standards which comply with national and international obligations. The CAA has oversight of the SMS. NATS also has a Safety Review Committee (SRC), a Board-level group—supported by independent experts from safety-related fields—that assists NATS in setting “best in class” safety standards. The role of the SRC is to monitor and review the eVectiveness of our safety arrangements and provide advice, independent of the NATS Executive, on improvement where necessary.This Committee is authorised to seek any information it requires from any employee of the company in order to perform its duties. NATS is also committed to maintaining a “just” culture to encourage the free and honest reporting of safety incidents and concerns. The law mandates reporting on certain types and severity of incident. These “Mandatory Occurrence Reports” go straight to the CAA which will, if appropriate, perform an incident investigation independent of the NATS investigation. External to NATS, the CAA, the UK Airprox Board and the Air Accident Investigation Branch (all independent of each other) provide a view to Government on the level and standards of safety in NATS. Given these numerous, formal procedures currently in place and operating with full transparency, we do not believe that introducing a further layer of reporting to the Committee is necessary, nor would it enhance safety. I would also like to reiterate my comments during the oral evidence session that we do not have any concerns regarding safety standards under the existing Single European Sky proposals. April 2009

Memorandum from the Campaign to Protect Rural England (AIR 30)

Summary The Campaign to Protect Rural England (CPRE) believes that the present laissez-faire approach to the use of airspace is unsustainable. Action is required urgently to deal with the flaws in the present arrangements, which have developed in an uncoordinated manner and are based on outdated evidence. In particular: — there is an urgent need for an independent review of the Future of Air Transport White Paper; — a National Airspace Master Plan is crucial to the eVective use of this national resource; — ownership of airspace needs to be placed in the hands of a body that is completely independent of the National Air TraYc Service (NATS) and the aviation industry; — current arrangements for planning and regulating the use of UK airspace are reactive and ineVective; — the eVects of aircraft emissions and noise, in particular the costs to communities, are either inadequately taken into account or ignored altogether; and — airport development proposals should be made in the light of their possible consequences on a National Airspace Master Plan and changes to routes by individual airports should be made subject to the same Master Plan.

Introduction 1. CPRE welcomes the opportunity to submit evidence to the Transport Select Committee inquiry into the use of airspace. As a leading environmental NGO with over 62,000 members and supporters, CPRE has worked to promote and protect the beauty, tranquillity and diversity of rural England by encouraging the sustainable use of land and other natural resources since our formation in 1926. 2. CPRE’s campaigning on the importance of tranquillity in the countryside, and our new tranquillity maps, has attracted considerable public support. Indeed a significant and increasing proportion of enquiries from members and the general public about our work in this area relate to concern about aviation expansion and change to flight paths. 3. There are important economic and social benefits arising from the promotion and protection of tranquillity as an important aspect of environmental quality. Aviation is increasingly having a detrimental impact on tranquil areas popular with visitors, while it contributes to a significant tourism deficit for the country as a whole34.

34 CPRE, Aviation—Policy Position Statement, 2008 Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Future of Air Transport White Paper

4. The Future of Air Transport White Paper (“the Air White Paper”) forecasts of aviation growth were based on assumptions which are now grossly incorrect on both the supply and demand sides of the case. The following factors are of particular relevance: — the Climate Change Commission’s call for the CO2 reduction target to be increased from 60 to at least 80%, and in particular the caveat that this target will need to be increased further still if the aviation industry is unable to reduce its emissions by this amount; — the increase in the price of aviation fuel, the price of which is likely to increase further over the long term as demand increases in Less Developed Countries; — the precariousness of many airlines and predictions that more will become bankrupt, which makes price increases likely rather than continued price cuts; — the credit crunch and likely impact on future economic growth; and — a greater understanding of the eVects on health of noise35. 5. Last month, the Sustainable Development Commission (SDC) produced a report entitled Contested Evidence: the case for an independent review of aviation policy. CPRE gives its unqualified support to the SDC’s call for independent review of aviation policy. Such a review should consider the costs and benefits to diVerent sections of society36, now and in the future, of diVerent aviation growth and contraction scenarios. We are particularly concerned that a National Policy Statement on Aviation, likely to be produced in 2009 if the Planning Bill is passed, may be based on the Air White Paper. Given the degree of change in context since it was produced, we believe that this would be perverse and is likely to present serious challenges to the work of the proposed Infrastructure Planning Commission and the decision-making process surrounding individual airport proposals. 6. In any event, a re-run of the Department for Transport (DfT) NAPALM/SPASM air traYc forecasting model using up-to-date data is imperative before any decisions based on the Air White Paper are taken.

ANational Airspace Master Plan

7. In its oral evidence to Sir Joseph Pilling’s independent strategic review into the present and future remit of the Civil Aviation Authority (“the Pilling Review”), CPRE made the point that airspace is an increasingly scarce national resource but one whose consumption is disordered and unsustainable. We suggested then that it is essential both to create a National Airspace Master Plan as well as an independent owner of UK airspace. We suggest that consideration be given to extending the role of the Environment Agency to cover this. It already has such a role for that other “free” good, rainfall, and strongly promotes demand management for that scarce resource. Extending its role would facilitate bringing the larger airports within the remit of the Integrated Pollution Prevention and Control regulations. 8. Both CAA and NATS have already informed DfT that if all the airports in the South-East were to expand according to the terms of their Master Plans there would not be suYcient airspace to accommodate the growth, using current or any predicted future airspace management tools and techniques. This is because each airport is currently largely free to grow, in size and in activity level, as it wishes with no regard to adjacent airports or airspace capacity for example. The whole notion of airports, some of which are less than 30 miles apart, competing for airline operators and passengers, has led to this chaotic—and unsustainable—state. 9. Allowing consumption of airspace on the basis of a mixture of predict-and-provide and sauve qui peut is folly when it is in such short supply. Airspace Master Plans should also encompass active management of any capacity changes at each airport, to ensure that the scarce resource is used equitably and to the greatest benefit of the country as a whole, rather than in support of individual commercial interests. 10. Airspace management considerations should figure prominently in the early stages of any airport development proposals. It may be that they would be seen by the developer as a delaying factor, but it is a necessary factor to address the present lack of forward planning. 11. Since airspace capacity is a national resource, its consumption should aVord some measure of return to the exchequer: “slot pricing” as currently implemented appears to be limited to runway slots and returns money to the airport operator. Some form of airspace slot pricing should be considered: this could have the benefit, for example through making a slot as expensive to consume by a small biz-jet as by a 300-seat aircraft, of encouraging eYcient use of the airspace: a form of “airspace pricing” which discourages one slot being consumed by flying one small aircraft instead of one large aircraft.

35 Although much more research needs to be done on the impact of aviation noise in tranquil areas: Transport Research Laboratory, Aviation, Noise and the Countryside—The Future Development of Air Transport in the United Kingdom, CPRE, 2003 36 See for example: CPRE/SERA, Runaway Costs—Social Justice, Environmental Sustainability and the Aviation Industry, 2003 Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Effects of Aircraft Noise and Emissions 12. The Pilling Review recommended an urgent updating of the DfT’s Guidance to the CAA on Environmental Objectives Relating to the Exercise of its Air Navigation Functions, 2002. The sections of that Guidance dealing with aircraft noise are based on research, public attitudes and public values dating from the 1960s and 1970s. We would therefore strongly support the need for such an update. 13. A proper replacement for DfT’s Attitudes to Noise from Aviation Sources in England (ANASE) study of 2007 is also urgently required. ANASE produced evidence that was unpalatable for the DfT, showing that people were disturbed at lower noise levels than assumed, and that the current “equivalent noise level” was not the most relevant way of measuring and depicting noise exposure. Furthermore, the health impacts of aviation noise are becoming increasingly apparent although they seem to be ignored in practice. This has resulted in a significant environmental policy gap which, though it may be advantageous to those keen to expand aviation, is neither equitable nor appropriate. The DfT’s obvious reluctance to re-work or re-do the study is highly regrettable. 14. The claimed “balance” between competing interests, in the case of aircraft noise, is at present far from being a defensible one in CPRE’s view. This begins, for example, with noise from civil aviation being excluded from the oVence of statutory nuisance in the Environmental Protection Act 1990. The DfT’s repudiation of the evidence from its own ANASE study continues to tilt the balance. A further component of ANASE was an attempt to ascribe a value (or a cost, depending on one’s viewpoint) to aircraft noise disturbance. This was also regarded as a failure: so “the balance” in financial terms consists of often-inflated claims of economic benefit from the aviation industry as compared with nothing. Balance is not helped, either, by the reluctance by agencies such as DfT to factor-in the down-side of aviation growth in terms of the tourism spending deficit—which the OYce for Government Statistics (OGS) states as being over £19 billion a year. 15. The aviation industry is a major contributor to climate change. The Greenhouse Gas Emissions generated by aviation are consistently understated, because emissions at higher levels in the atmosphere create much greater amount of damage than the same quantity emitted at ground level. Currently the only emissions which will be “charged” in any way are CO2, and then only as though the emission occurred at ground level. Nor is any account taken of the damaging eVects of nitrogen oxides and water vapour injected at high levels. The whole basis of emissions trading results in aviation being, in eVect, able to buy its way out of jail and it pays no duty or VAT on the hydrocarbon fuel it burns.

European Airspace Considerations 16. Pan-European management of airspace through the proposal for a Single European Sky or “Eurocontrol” could benefit aircraft and airport operators, passengers and the environment. Clearly a significant measure of control over national airspace would need to be ceded by the states involved. There would also be a need for much more eVective coordination of slot allocations at all European airports. Progress in all of these areas is urgently required but not at the cost of environmental standards being reduced to the lowest common denominator. If Eurocontrol is to become a reality it needs to be based on best practice environmental standards.

Roles and Responsibilities 17. There is a perception outside the aviation industry that a revolving door exists between DfT, CAA and NATS and that the relationships between them are damaging to public confidence in policy making. Decisions over the use of airspace need to be made with a stronger degree of independence. CPRE believes that a large measure of control over use—as opposed to the technical aspects of route design—needs to be removed altogether from both CAA and DfT.

Airspace Management Considerations and Planning of Airport Developments 18. Airspace management considerations should always be taken into account in the formulation of airport development proposals. Whether those considerations cause delay to the proposals is largely in the hands of the proposers: if proposals are made at the appropriate time and with suYcient precision there is no prima facie reason why delay should occur. 19. Unlike any other industry, the eVects of changes in aviation operations, in particular with respect to noise pollution and visual intrusion, can suddenly be spread over tens or hundreds of thousands of people. Transparency, early consultation and consultation that is really meaningful in the sense that its results, however unpalatable, are acted on, are urgently required. The examples of the airspace changes for West End in 2006 and Terminal Control South West in 2008 demonstrate how reasonable objections from CPRE and others were eVectively ignored in the decision-making process. The latter changes are now subject to judicial review. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Other Users of Airspace

20. Airspace, particularly in the South East, is at a premium. It has to be the case therefore that the subject of priorities for consumption of airspace must be examined, ideally on the basis of “greatest good to greatest number”, which might be taken as “greatest overall proven economic benefit”. If an “eYcient use of resources” approach were to be taken in respect of airspace there would, and should, undoubtedly be adverse consequences on recreational flying: and any other form of “general aviation” such as “bizjets” which consume airspace capacity in a demonstrably sub-optimal way. This will be a diYcult issue to address: there are recreational flying facilities which have existed for a long time and which, under present rules, are treated equally with all other consumers of airspace and are able to take the line “what we have, we hold”. Though the consequences for fly-for-fun airfields, for example, would be painful such an approach appears to be inconsistent with eYcient use of airspace.

Resourcing of Airspace Changes

21. Currently NATS, majority-owned by airlines, airports and its staV, carries out this work using its own staV, and derives comfortable levels of income and profit through raising navigation charges from “consumers” of airspace. NATS’ charging and profit levels are, one understands, regulated by CAA under the terms of NATS’ licence. This seems a relatively equitable way of proceeding and in line with the terms if its licence which requires it to “meet any reasonable level of overall demand”. If the level of demand is deemed to be unreasonable, whether through environmental constraints, lack of airspace capacity or trained personnel, it should be for the CAA to so declare, provided it has been given clear environmental guidance by Government. 22. NATS navigation charges are set to generate a commercial rate of return from its operations, and these fall on the consumers of airspace (airlines) which in turn recover these and other costs from the end user (the passenger). This appears to be an eVective mechanism: save for the lack of any return to the population as whole, which should be regarded as the owner of the airspace. 23. It could be claimed by NATS that some consumers of airspace, particularly those engaging in recreational flying, are in eVect getting a “free ride” since they derive benefit from the existence of the uncontrolled airspace in which they are free to fly but which can only exist because NATS has defined, and manages, areas of controlled airspace. The relative proportion is small, however, compared with commercial aviation and could therefore be ignored though that proportion may need to be assessed periodically to ensure that it remains negligible.

Recommendations

24. There is much that is wrong with the way in which airspace is currently allocated, used and managed. CPRE hopes that the Transport Select Committee will carefully consider the views expressed above in forming its conclusions as to appropriate ways forward. In particular, we ask that the Committee recommend that: 1) There should be an independent review of the Air White Paper; 2) A National Airspace Master Plan is promoted by Government; 3) Ownership of airspace is given to an independent body; 4) A pricing mechanism is introduced to allocate airspace eYciently; 5) The Pilling Review recommendations on providing the CAA with a stronger environmental remit are implemented as soon as possible; 6) There is much faster implementation of Eurocontrol, with environmental standards raised to “best practice” levels; and 7) The securing airspace is made a pre-requisite for any airport development proposal. October 2008

Supplementary memorandum from Campaign to Protect Rural England (AIR 30A) I would like to thank you on behalf of my colleague Michael Nidd and my own behalf for your invitation to CPRE to give evidence to the Transport Committee last month. Whilst giving our evidence, we oVered to supply the Committee with further information, which I do in this letter. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Night Noise from Airports I attach a note on the production of eight-hour night noise contours for UK airports. CPRE believes that all UK airports should produce annual night contours or should have their night movements regulated according to the principles adopted for the three principal London airports (Heathrow, Gatwick and Stansted). We hope that the Committee will feel able to make a recommendation on the subject.

Tranquillity It was not possible in the time available to give the Committee a proper insight into the work done by CPRE to map tranquillity in England. However, we would wish to clarify and further explain some of the points made in oral evidence. We attach a brief note about the methodology used to generate the national tranquillity maps. We would like to stress that this methodology combines objective data from national data sets such as from the Ordnance Survey with subjective weighing of 44 potential factors, based on statistically significant public consultation. The subjective element was necessary to weigh the importance of diVerent incommensurable factors, such as frequency of air traYc movements, decibel levels and electricity pylons, which cannot be compared using objective factors. It is important to emphasise that any analysis of human sensory responses to environmental factors is by definition subjective, as people are by their nature sentient individuals. The cumulative weight of a large survey (more than 3,000 objectively recorded responses) gives statistical importance to the data. My colleagues also stand ready to provide whatever further information would be of assistance, and to meet all or any members of the Committee to give additional information or explanations. I hope that the Committee will find that the tranquillity mapping is a helpful tool in establishing the likely consequences of policy decisions.

Integrated Planning The Committee asked us whether we were in favour of integrated planning for airspace and land use. We favour this without reservation. We also favour integrated airspace planning, such as by including a national airspace masterplan within a National Policy Statement on Aviation, and believe that it should be the responsibility of a single body. We believe that both the CAA and NATS would support such an approach. When they gave joint evidence to the Competition Commission in May 2007, they said: “CAA and NATS are of the view that, were all of the south-east’s airport development plans to come to fruition, there would not be suYcient airspace capacity to accommodate the scale of the predicted traYc growth on the basis of current and predicted technology.” The further strengthens our view that no planning application to increase the throughput of a particular airport should be undertaken until it has been objectively demonstrated that the requisite airspace is genuinely available, and that safety is not compromised. It also underpins the need for a single body to be responsible for planning both airport growth and airspace utilisation. It seems to us that neither the CAA nor NATS regard themselves, severally or jointly, as the bodies to do it. We would be pleased to give any further explanations or information that might be helpful to the Committee.

Noise Contours Noise contours around airports provide a systematic basis for monitoring and, where necessary, tactical control of the noise disturbance created by airport operations. For many years the CAA has required airports to produce 16-hour day A-weighted noise contours (in acoustics shorthand, LAeq,16h), based on the busiest 92-day period in the year. The CAA defines “day” as extending from 07.00 until 23.00.

No Requirement for Night No similar contours (LAeq,8h) have been universally required to cover the complementary night period (from 23.01 until 06.59). Thus there is no generally-applicable method for monitoring and control of night noise, though a small number of airports do have schemes of one form or another.

Airports Producing Night Noise Contours Occasionally BAA’s London Area Airports (Heathrow, Stansted and Gatwick) do not routinely produce night noise contours, but have, from time to time, produced such contours as part of planning applications, as have Bristol, Liverpool and Birmingham. Nevertheless, night noise disturbance caused by those airports is managed through a DfT scheme based on numbers of aircraft movements and the total “quota units”. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Airports Producing Night Noise Contours Regularly East Midlands, Luton and Manchester Airports produce LAeq,8h night noise contours annually as a result of conditions attached to planning permissions. The Environmental Noise (England) Regulations 2006, which stemmed from the EU Directive on Environmental Noise (EC 2002/49), have required Airports which support more than 50,000 air transport movements a year to produce night contours. These are broadly similar to LAeq,8h contours, although the contour intervals are spaced diVerently from those adopted by the CAA. These were produced for most busy Airports for 2006, and that process should be repeated in five years’ time. We attach a list of the airports involved in the 2006 exercise. Thus these night noise contours, though instructive from a strategic, land-use planning viewpoint, are not suitable for the tactical control of night noise because the five-year update cycle is too infrequent.

Airports Producing Noise Maps in 2006 1. Birmingham International Airport (EGBB) 2. Blackpool Squire’s Gate Airport (EGNH) 3. Bournemouth Airport (EGHH) 4. Bristol Lulsgate Airport (EGGD) 5. Coventry Airport (EGBE) 6. Leeds Bradford Airport (EGNM) 7. Liverpool John Lennon Airport (EGGP) 8. London City Airport (EGLC) 9. London Gatwick Airport (EGKK) 10. London Heathrow Airport (EGLL) 11. London Luton Airport (EGGW) 12. (EGSS) 13. Manchester International Airport (EGCC) 14. Newcastle International Airport (EGNT) 15. Nottingham East Midlands Airport (EGNX) 16. Shoreham Airport (EGKA) (daytime only) 17. Southampton Eastleigh Airport (EGHI) 18. Southend Airport (EGMC) March 2009

Supplementary memorandum from Campaign to Protect Rural England (AIR 30B)

NOTE ON TRANQUILLITY METHODOLOGY The concept of mapping all undisturbed countryside as a resource in itself—tranquillity mapping— derives from groundbreaking work by Simon Rendel of ASH Consulting in a study for the Department of Transport in 1991. ASH Consulting produced a set of highly influential national and regional Tranquil Area maps for CPRE and the Countryside Commission published in 1995. In these maps, “Tranquil Areas” were defined as “‘places which are suYciently far away from the visual or noise intrusion of development or traYc to be considered unspoilt by urban influences”. In 2004 CPRE, supported by the Countryside Agency (now Natural England), commissioned Northumbria University and the University of Newcastle-upon-Tyne to carry out a pilot study to develop a methodology to map tranquillity in two pilot areas. This study developed the tranquil areas work through: — extensive public and stakeholder consultation with over 430 people using participatory appraisal (PA) to define what factors contribute to and detract from tranquillity (positive and negative factors); — accounting for the presence of positive features or factors which can foster tranquillity; — reflecting the cumulative impact of positive and negative factors in a given area; — more advanced modelling techniques with GIS (Geographic Information Systems) to reflect diVusion of factors over distance; and — production of detailed continuous surface maps of tranquillity on a relative scale from lowest to highest. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Further PA work carried out in the Chilterns AONB in 2004 with over 580 participants confirmed the general transferability of the consultation approach with further methodological developments. This provided a firm basis for the use of these findings to map tranquillity at a national scale. In 2006 CPRE commissioned a project to map tranquillity on a national scale which drew extensively on the earlier work in 2004. The approach adopted combines two main streams of data collection and integration: 1. Public consultation Over 1,300 people were surveyed in 20 separate locations across England to rank and quantify the positive or negative factors on a national basis; participants were asked to select three positive and three negative characteristics that most contributed to or detracted from an experience of tranquillity. The number of responses for each of the 44 option choices (21 positive, 23 negative) was converted into a percentage which provided a way of weighting each option choice in order of relevance. 2. A GIS (Geographic Information System) model to map tranquillity GIS was used to provide a spatial footprint of the 44 option choices. In the national model these were divided into two key themes—“what you can see” and “what you hear”—to make the link between digital datasets and the ability to model “visibility” and “noise” clearer. Data was compiled separately for both positive and negative option choices and was derived from existing national datasets compiled by relevant competent authorities. Raw data for each factor were reclassified on a scale from zero to ten to establish parity between widely varying types of data. Ten represents the strongest and zero the least contribution to or detraction from tranquillity. Reclassified data were then weighted according to the consultation results and combined into negative and positive totals. Scores for negative tranquillity were taken away from scores for positive factors to give an overall score for how “tranquil” a given 500m by 500m cell will be on the relative national scale. March 2009

Memorandum from London City Airport (AIR 31)

1. Introduction This response to the House of Commons Transport Committee’s invitation to submit evidence on its Inquiry into the use of airspace is submitted by London City Airport (LCY). London City Airport is owned by Global Infrastructure Partners (GIP).

2. Summary See bullet points in attached LCY paper.

3. Responses

“What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide increased passenger demand likely to be implemented?” 3.1 LCY continues to believe that the forecast overall increases in passenger demand over the period to 2030 as presented in the 2003 White Paper are broadly valid despite current economic circumstances which are likely to have a short term negative impact. We believe that these forecasts are reflected in the development of airport capacity to meet that demand. 3.2 The 2003 White Paper notes that the additional airport capacity required to meet forecast demand “must be matched by a corresponding increase in airspace capacity”. However, despite the White Paper’s aims for a structured programme for the redesign of UK airspace being brought forward by the CAA there has so far been little obvious movement towards this objective. The development of airspace appears to be progressed on a somewhat piecemeal basis. The committee’s inquiry is therefore timely.

“Can safety be maintained as airspace is increasingly utilised? Is there suitable interface between military and civilian arrangements for air traYc control?” 3.3 Safety within aviation has to be maintained at the highest possible levels and LCY is confident that the exceptional record of all of the stakeholders in the UK aviation industry ensures that these high standards are maintained and enhanced as time progresses and traYc increases. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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3.4 At the operational level there is an eVective interface between military and civilian air traYc control. However, we do not consider that this interface is necessarily maintained at the strategic level, particularly in relation to “ownership” of airspace and any strategic initiatives to facilitate the release of military airspace for civilian use. If such airspace could be released on a permanent basis, it would enable civilian flights to make use of that additional capacity and potentially facilitate more direct routings, which would have environmental and economic benefits through reduced fuel burn. 3.5 The Committee will be aware that the military does allow short term release of some of its airspace eg at weekends. However, these short term fixes, whilst useful, do not provide the long term airspace capacity gains that would be greatly welcomed by commercial aviation. Weekends tend to have the lowest proportion of business travellers. 3.6 An issue which is very important to UK airports and air navigation service providers (ANSP) is the future supply of qualified air traYc control oYcers. This could have serious repercussions for the future development of UK aviation as a whole if it is not addressed. One useful constituent to an overall approach to this issue would be a review of the current lengthy and expensive conversion arrangements required for military controllers to become controllers in the civil sector.

“Is the current approach to planning and regulating the use of airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently?” 3.7 The responsibility for planning and regulating airspace lies with the Civil Aviation Authority and more specifically its Directorate of Airspace Policy (DAP). While we believe that DAP is an eVective regulator we also believe that there is relatively little evidence of it developing the inclusive “structured programme for the redesign of UK airspace” as envisaged by the 2003 White Paper. 3.8 LCY fully supports the development of a UK Airspace Master Plan covering the period of the White Paper and beyond. Such a Master Plan could complement the work being undertaken in Europe on the SESAR initiative (covered in more detail in paragraphs 3.16 to 3.24 inclusive). A Master Plan would provide a structured framework within which airspace development could be progressed and implemented and (following wide consultation) with a presumption in favour of such developments.

“How are the eVects of aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck?” 3.9 Airspace change proposals are supported by a CAA document, CAP 725 Airspace Change Process Guidance. This document was initially published in 2002 but has been updated as since that time “public interest in aviation-related environmental matters has greatly increased, in part prompted by the Government’s Air Transport White Paper published in December 2003. At local level, noise and emissions have emerged as significant issues . . .”.37 Accordingly, environmental considerations play a key part in any proposal to change airspace. 3.10 Appendix B to CAP 725, Airspace Change Proposals—Environmental Requirements states: “The Civil Aviation Authority (Air Navigation) Directions 2001 (incorporating Variation Direction 2004) (HMG, 2001) requires the CAA to take into account “the need to reduce, control and mitigate as far as possible the environmental impacts of civil aircraft operations, an in particular the annoyance and disturbance caused to the general public arising from aircraft noise and vibration, and emissions from aircraft engines”. And “It is the function of this document to assist those preparing airspace change proposals in providing suYcient environmental information for public consultation and to inform the decision making process”. 3.11 CAP 725 requires airspace change proposals to be supported by: — A description of the airspace change; —TraYc forecasts; — An assessment of the eVect on noise; — An assessment of the change in fuel burn / CO2; — An assessment of the eVect on local air quality; — An economic valuation of environmental impact. 3.12 In terms of public consultation, CAP 725 requires the proposer of the airspace change to identify “all of the diVerent parties aVected by the design options”38 and to have undertaken a stakeholder analysis to ensure that it can be demonstrated that a complete consultation on the proposal has taken palace.

37 CAP 725 CAA Guidance on the Application of the Airspace Change Process—Foreword. 38 CAP 725 CAA Guidance on the Application of the Airspace Change Process, Page7, Paragraph 14. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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3.13 Regarding the balancing of conflicting interests, CAP 725 states: Consensus is not necessary nor should it be expected. However, a Change Sponsor will be accountable for their decisions to either accommodate or disregard consultees’ responses and for providing timely feedback to the consultees. These decisions will be scrutinised and form part of the Directorate’s (DAP’s) assessment criteria at the Regulatory Decision stage. 3.14 LCY considers that CAP 725 provides comprehensive and proper provisions in relation to environmental issues arising from proposals to introduce airspace changes and to take account of the views of the general public and other stakeholders in the proposal consultation process. 3.15 However LCY believes that CAP 725 would be more eVective if it was accompanied by a UK wide airspace master plan, championed by the CAA.

“How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European Countries?” 3.16 It is widely acknowledged that airspace over Europe is highly fragmented having developed largely around State borders. This fragmentation does not provide for a high level of air traYc management (ATM) eYciency and until it is fully addressed the system will become more congested as traYc continues to grow. 3.17 As a direct result of the need to completely reconsider how European ATM will deal with the future demands for sustainable growth in air transport, the SESAR (Single European Sky ATM Research) initiative was introduced. For the first time in European ATM history an ATM improvement programme involving all of the aviation stakeholders ( civil and military users, ANSPs, airports, aerospace manufacturing, regulators and legislators) has been launched with the objective of achieving a “paradigm shift” through a pan-European approach to the planning and delivery of European ATM and in support of Single European Sky legislation. LCY supports this initiative. 3.18 The first phase of the SESAR project was completed in March 2008 with the production of a Europe wide ATM Master Plan which will form the basis of the project’s next phase, the Development Phase, to be completed by 2013. The intention is that this ATM Master Plan will be a living document updated as progress is made. 3.19 SESAR is the only pan-European ATM development programme and it will only succeed in delivering its objectives through the commitment of all of the ATM stakeholders. To date the CAA, NATS, DfT, UK airports and some airlines have been directly involved. 3.20 A UK wide Airspace Master Plan would neatly dovetail into the SESAR ATM Master Plan. 3.21 The SESAR objectives are extremely challenging: — A three fold increase in capacity which will reduce delays both on the ground and in the air. — Improve safety performance by a factor of 10. — A 10% reduction in the eVect that flights have on the environment. — A reduction of at least 50% in the cost of providing ATM services to airspace users.

“What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements?” 3.22 Fundamental to the success of SESAR is the development and application of new technologies and techniques and as such a huge eVort is going into the necessary research and development that will enable these factors to be delivered. Associated with many of these applications is the need to deliver quantifiable environmental improvements in all phases of flight. 3.23 The aviation industry is however not sitting back and waiting for SESAR to make things happen. New air traYc control techniques including Continuous Descent Approach (CDA) are being introduced at some airports which deliver benefits including reduced noise, less disturbance to local residents and lower fuel burn. In addition, airports generally are highly pro-active in promoting and delivering environmental mitigation and improvement schemes, many in consultation with their community stakeholders. This is a particular feature at LCY an inner city airport. 3.24 The work undertaken in SESAR is already starting to demonstrate how new ATM techniques and arrangements may provide benefits. Initiatives such as Collaborative Decision Making (CDM) will deliver eYciency gains by improving the processes whereby airport, ANSPs and airspace users interact and thereby deliver environmental benefits through less unnecessary fuel burn both on the ground eg by more eVective taxiing; and in the air through more direct routings and sequenced operations that reduce the need to “stack”. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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3.25 The flexible use of airspace will also enable capacity gains to be achieved as will the use of military airspace. Furthermore, the development of Functional Airspace Blocks (FABs) between neighbouring States will reduce the fragmentation of airspace over Europe and deliver improved ATM eYciency.

“In relation to the redesign of UK airspace of the roles and responsibilities of each of the interested parties— Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play? 3.26 LCY has some concern that the roles and responsibilities for airspace redesign are not particularly well defined or understood. The role of DAP is undeniably that of a regulator but it is not clear that DAP is undertaking the function of a strategic planner of airspace as envisaged by the Government in the 2003 White Paper. 3.27 LCY considers that the overall process for airspace capacity and planning does not work as well as it could. It is largely piecemeal, is protracted in terms of process, and creates diYculties for airports in achieving local authority planning approval for development plans.

“Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning?” 3.28 Airspace management impacts airport capacity development proposals. LCY believes that in future is possible that an airport’s development plans may include and, to some degree, be dependent upon, changes to its airspace, and that this should be scrutinised by local planning authorities when applications to develop capacity are submitted. 3.29 LCY is not aware of how airspace considerations will be taken into account by National Policy Statements on airport planning. What is required is a National Policy Statement on airspace and an Airspace Master Plan, against which airport development plans could be tested by local planning authorities.

“What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined? 3.30 It is undeniable that changes to airspace management to enable capacity gains at major airports could impact upon the stakeholders referred to in this question. However, as stated above (paragraphs 3.9 to 3.15 inclusive) CAP 725 provides a comprehensive framework for consideration of such airspace changes and allows for all stakeholders and parties aVected by the proposed changes to be fully consulted. This CAP also includes appropriate provisions whereby conflicting priorities can be addressed.

“Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity” 3.31 This question has two basic components ie airspace design and air traYc control management. 3.32 In terms of airspace design, there appears to be a shortage of qualified designers in the market with the primary resource coming from individuals who were once employed by DAP when it used to provide an airspace design service. Whilst there is little evidence that this level of approved design supply is causing current problems this situation may worsen over time. 3.33 Once changes have been approved they have to be implemented and this is where the requirement for air traYc control staV to manage the revised airspace comes into play. As previously stated, there is a critical forecast shortage in the supply of qualified air traYc control oYcers and while automation and new technologies may address some of this anticipated shortfall there remains a clear need to find means whereby supply can match demand. This will involve additional training resources and initiatives such as making the transition from military to civilian air traYc control more streamlined.

“Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity?” 3.34 LCY believes that the responsibility and funding for the development of a structured programme for the redesign of UK airspace as proposed in the 2003 White Paper should lie with Government. While execution of this process would lie with CAA the costs should not be included in CAA’s charges to airspace users and airports. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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SUPPLEMENTARY COMMENTS SUBMITTED BY LONDON CITY AIRPORT LTD 1. The comments below should be considered in conjunction with the London City Airport (LCY) responses to the Transport Committee Questions. LCY welcomes the committees focus on airspace issues in light of the Government’s decision to review future airport strategy. 2. LCY is owned by Global Infrastructure Partners (GIP) and handled 3.2 million passengers and 90k aircraft movements in the year to 30th September 2008. 3. LCY has recently been granted approval by the London Borough of Newham (the local planning authority) to increase permitted aircraft movements to 120k p.a. 4. Ultimately LCY may be capable of handing at least 170k p.a aircraft movements on the ground. How this might be achieved is detailed in the LCY Master Plan published in 2006 in response to the 2003 White Paper—The Future of Air Transport. This Master Plan can be accessed via our website (www.londoncityairport.com) and a hard copy is attached. Further copies can be made available to the committee should you wish. 5. LCY growth to 170k or more movements a year is only achievable if there is suYcient airspace to cope with this demand, at a time when other airports will also be seeking increases in airspace capacity. 6. LCY considers that there is currently a shortage of airspace capacity in London and the South East. This shortage manifests itself in delays to aircraft both in the air and on the ground. LCY welcomes the proposed TC North airspace re-design currently being consulted on by NATS. 7. LCY believes this shortage should be addressed by Government, CAA and NATS as a matter of urgency due to the potentially negative impact this has on the regional economy, and London’s role as a major world city. 8. An initial view would suggest that we are always likely to have, or be close to, a shortage of airspace capacity in London and the South East. This suggests that some form of organised priority action of capacity is likely to be required. 9. LCY has commissioned research to test the economic impacts of diVering types of passengers and aircraft. LCY believes some passenger to be significantly more beneficial to UK plc than others. Any prioritisation of airspace capacity should we believe take full account of the economic significance of diVering types of passengers. 10. LCY would be happy to share this research with the committee and discuss the conclusions we have reached. 11. In essence our comments can be distilled into the following bullet points: (a) There is a current shortage of airspace capacity which will inhibit the delivery of the UK airport capacities envisaged in the 2003 White Paper. (b) The UK needs an airspace capacity Master Plan to integrate with the Air Transport White Paper and SESAR. (c) A form of long term capacity rationing is required to deal with current demand levels, as (b) above may take a decade or more to prepare and consult about. (d) Prioritisation of capacity involving discrimination in favour of those airports, aircraft and passengers that are demonstrably of more economic value to UK plc makes the most eYcient use of airspace. (e) Supply of suYcient air traYc controllers and airspace designers is vital in providing future airspace capacity increase. October 2008

Memorandum from British Airways plc (AIR 32)

Introduction British Airways (BA) welcomes the opportunity to submit evidence to the Transport Select Committee’s inquiry into “The Use of Airspace”. The airline’s main base is London Heathrow Airport, the UK’s primary international hub airport and one of the busiest airports in the world. BA also operates from 9 other airports in the UK, and worldwide, to 154 destinations in 75 countries. It employs more than 43,000 people, of whom 38,000 work in the United Kingdom. BA oVers almost 550 flights in total to and from Heathrow each weekday, with a further 190 services a day to and from London Gatwick daily and 44 per day to and from London City. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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BA Response to Specific Questions as set out in the Terms of Reference

1. What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? ii) Are the White Paper’s projections for increased passenger demand still accurate? iii) Are all the measures to provide for increased passenger demand likely to be implemented? BA believes there is a need for planned restructuring of UK airspace to accommodate new runways, general increases in capacity, to accommodate more flights and to reduce delays and unnecessary emissions. There is also a need for clarity about how strategic airspace change is to be taken forward reflecting the decisions taken in 2003 Air Transport White Paper (ATWP). This is urgent for SE England where two new runways are planned to operate within the next 10 years or so, in addition to more immediate changes in airspace management to make better use of existing capacity. It is long overdue to have a master plan in place to deal with development and changes of this complexity and strategic significance. Heathrow is the most important airport in the UK and SE England. This must be recognised by NATS when strategically planning increases to airspace capacity, but also in their day-to-day management of air traYc flow. BA has evidence suggesting LHR is unfairly discriminated against in day-to-day management of airspace, which may be because it is easier to place a restriction on LHR alone to take a proportion of demand from the system, rather than place several smaller restrictions across the SE airport network. This means LHR sees poorest performance, when it is least able to absorb consequences due to lack of capacity for resilience. ii) We agree that 2003 ATWP projections of increased passenger demand remain reasonable assessments for long term planning analysis for additional airport capacity. However, we believe projections of sustained peak-period demand from air traYc movements (ie number of flights) are more important than raw passenger numbers in assessing need for expanding runway and airspace capacity. Airspace capacity needs to match runway capacity, and it is actual numbers of movements that create airspace workload. iii) In due course we expect all ATWP measures providing increased capacity at Heathrow will be needed; indeed they are overdue. They are also capable of being implemented. We fully expect environmental conditions to be met, and our fleet purchases are designed to contribute to that. BA’s concern is that plans are developed and implemented to change the airspace that serves flights to Heathrow in particular, and the UK generally, in a timely way so airspace improvements are not on the critical path inhibiting capacity growth, delay reduction and avoidance of unnecessary emissions due to congestion. We have focused our work on the centrepiece of the ATWP for the national economy, the expansion of Heathrow. We do not oVer specific evidence on other ATWP-endorsed airport developments.

2. Can safety be maintained as airspace is increasingly utilised? ii) Is there a suitable interface between military and civilian arrangements for air traYc control? i) Safety both on the ground and in air is paramount; we would not proceed if we believed safety could not be guaranteed. In fact, improving technology oVers technological and management improvements on the plane and the ground both of which facilitate increasing capacity and improving safety margins. The Pan-European Single European Sky II (SES II) and SESAR (Single European Sky ATM Research) initiatives oVer opportunities for introducing wide reaching changes to technology and organisation of airspace with clear benefits in structural and fuel eYciencies, extra capacity,reduced emissions and improved safety. SES and SESAR initiatives need full UK backing in order to realize their benefits. ii) We recognise the importance of Military use of airspace, however our perception is that more airspace could be freed in terms of geography and time windows of use to ease pressure on the commercial ATC environment. There is interface with the Military in the UK, but could be improved. We are seeing some good interfaces between NATs and Military, in particular at Swanwick where they share a joint cell. This has resulted in some significant improvements to flexibility of some military zones, eg the Portsmouth Danger areas use being modified to assist NATS. However, the key remaining issue is that there is still too much airspace dedicated to military use, and there seems a lack of positive momentum to move this further. We welcome any joint working to reinvigorate resolution of this issue. Apart from UK Military, we observe a clear impact on UK ATC of Foreign Military. In particular UK aviation is highly impacted as a result of foreign military danger areas eg in DOVER sector, CBA1 zone under French Military control. This area causes frequent disruption and rerouting around one of the busiest areas of airspace between UK and Europe. As an example, this area alone is regularly observed to account for 5–8% of UK delays. We also need to recognise LHR has intensely used airspace with restricted capacity and its operations and passengers are all too often disrupted by adhoc users, fly-pasts and helicopter transfers. The US presidential visit to LHR directly aVected the operation of the airport across three days and was felt by the airline community to be unreasonable given number of passengers badly and unnecessarily aVected and the Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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significant cost borne by airlines. Our research has shown that for BA alone, 53 flights were cancelled- impacting 4,887 passengers, 264 flights were delayed more than 30 minutes and in total over 33,000 passengers were delayed 30 minutes or more. We recognise the need for occasional adhoc non-civil activity, but given the economic importance of Heathrow and constraints on the airports ability to absorb delay, we recommend the approvals process for such activity include a full risk and disruption analysis with input from the airline community and airport, including analysis to define suitable alternative Military airfields able to host such activity.

3. Is the current approach to planning and regulating the use of UK airspace adequate? ii) Would an Airspace Master Plan covering the period of the White Paper be beneficial? iii) Could a piecemeal approach to individual developments necessitate additional redesigns subsequently? BA considers the current approach to planning UK airspace is inadequate and lagging behind in terms of what is needed to implement the overdue major airport expansion projects in the ATWP. The ATWP was issued five years ago, and yet there is still to be an Airspace Masterplan published. The ATWP was explicit in terms of the Government’s commissioning the Civil Aviation Authority to produce such a plan39. In the view of BA there is scant evidence to date of progress by the CAA in meeting this explicit remit from Government. The exploration by the committee of this fundamental failure, and how to rectify it is, in BA’s view, important so that essential progress in this area of national infrastructure planning can be kick started. In terms of regulation of UK airspace, the regulation is fragmented and as a result, not eVective across UK airspace as a whole—NSL (NATS Service Ltd) and NERL (NATS Enroute Ltd). There is clearly defined regulation on NERL, and as a result, there is clear and demonstrable progress within their accountabilities in reducing delays, improving investment and performance. However NSL does not fall under this regulatory structure, despite for practical purposes operating a number of noncontestable local airport monopolies, at least at the busy southeast England airports. This means the local airspace delays in landing and departing from airports are not currently included in the regulatory review, and not subject to quality and delay targets set. In addition, there is inadequate inter-agency transparency and uncertainty between NSL and NERL over responsibility for some aspects of poor delay performance. As a minimum this needs addressing in the license conditions of NERL. More importantly, in BA’s view the regulatory process should be extended to include NSL operations at airports where the changing the provider of air traYc services is practically impossible. In BA’s view these weaknesses contribute significantly to the level of performance on airspace delays at airports like Heathrow, where there can be excessive holding on waiting to land. These airspace delays local to Heathrow do form a significant proportion of Heathrow delays as demonstrated by the CAA commissioned LHR/LGW runway resilience study. Economic regulation of NSL at airports in the southeast (or elsewhere in the UK where provision of airport ATC services is eVectively non-contestable) is needed to increase performance and resilience and ensure airspace is managed eYciently as a whole. ii) Yes, airspace Master planning covering the period of the ATWP would be beneficial. BA fully supports implementation of the government approach of having a long-term master plan for airport development. It is imperative in achieving timely airport expansion, where coordination amongst (inter alia) airports, air space providers, airlines, economic and environmental regulators, surface access providers, local and national government is required. Heathrow in particular is the UK’s global hub and it is extremely important that airspace improvements are not on the critical path for capacity growth. At the present time, BA sees a great risk that airspace restructuring will be the item that holds up achievement of necessary airspace and airport capacity expansion. Airspace development needs to be handled in an integrated manner alongside airport expansion. iii) Yes, we see a piece meal approach as a considerable risk to making progress with key developments. That is why we are seeking an integrated master plan that can be implemented sequentially without requiring later redesign. BA has a considerable concern that the current Airspace change process as it stands, has potential for open-ended reiterations. We do not know if the recent consultation on NATS Terminal Control North is a sound start, as we have no overall Masterplan airspace plan within which to assess it. There needs to be a way of drawing it to a timely conclusion. In our view the first issue to be tackled is the need for an airspace master plan. At this time, we understand conversations have been taking place but no clear plan or strategy has been made visible. DAP, DfT and NATS are all involved but no one appears to be taking the lead in producing or coordinating the plan. BA believes that due to the strategic importance of the issue, if there is any ambiguity about the CAA’s mandate and accountability for taking a lead as the DfT tasked them to do in the 2003 ATWP, then that ambiguity should be removed.

39 The Civil Aviation Authority is responsible for the planning and regulation of UK airspace. The Authority has examined proposals for additional airport capacity contained in this White Paper. It believes that the necessary airspace capacity can, in broad terms, be provided safely through the redesign of airspace and the introduction of enhanced air traYc techniques and systems. The Government will now look to the CAA to make early progress in bringing forward a structured programme for redesign of UK airspace, with a view to phased implementation of changes to eliminate constraints and permit the integration of the forecast increases in aircraft movements, including traYc using the additional runways proposed in this White Paper. (The Future of Air Transport White Paper 2003, page 145, para 12.26 Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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4. How are the eVects of aircraft noise and emissions taken into account when changes are made to the use of airspace? ii) Who should be consulted about such changes? iii) How should the balance between conflicting interests be struck?

i) The explanation of the process used for taking the eVects of noise and emissions into account is a question for those who take the decision based on the analysis, rather than an airline. ii) There is a degree of obscurity on the consultation process, depending on who is to make the decision and who has requested the change. We would view it is as a role for DAP acting on the information provided by the proposer of the change. For example with the TC North consultation: Airlines and Local communities should be involved but there must be a cut oV point in consultation to avoid endless reiterations. iii) In the case of strategic changes to airspace the decisions by DAP need to be made within the context of the government having taken strategic decisions on airport capacity, which took into account airspace changes in broad terms. That will ensure that the airspace implications of national policy decisions on airports’ expansion can realistically be implemented having already been through an extensive democratic process over several years that led to the ATWP decisions. Subsequently the step-by-step part of consultation should take into account the detailed local views of stakeholders during each aspect of the implementation. These judgements need to be made taking the views of all stakeholders and the circumstances of each change. It is important that the CAA has a clearly defined remit to make these decisions knowing they have to be consistent with the ATWP. Ultimately decisions could be referred to the Secretary of State for Transport to ensure that the decisions fit with the policy; however so long as the CAA sets out to operate within the policy, then reference to the Secretary of State should be most unlikely.

5. How does the management of airspace in the rest of Europe aVect flights into the UK? ii) Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries?

i) Management of airspace into and out of the UK is heavily influenced by foreign military and cross border ineYciencies. Primarily there is too much regionalism and fragmentation, which has lead to a high level of ineYciencies across the European ATC system. The European ATC structure has grown organically and historically as states have formed and developed with ATC sectors following national borders, limiting their ability to take account of pressure points and key routes for traYc. The system is therefore aVected by a number of historical issues and pressures eg, military control. Where national airspace boundaries exist, analysis has shown routings are 15% less eYcient. As an example, Maastricht area is the only airspace area that is not based on historical boundaries and the higher performance in this area over other European airspace, demonstrates the significant improvements that are possible. ii) The issue of integration of European airspace management needs to be tackled strategically. We view SESII as the ideal vehicle for European integration and in addition we are making moves to speed improvements by working on the UK and Ireland FAB. We support SES initiatives, but the political will needs to exist to make the changes happen. Other governments seem to be determined to maintain control, but this doesn’t mean that we shouldn’t try to make changes within the structures available, and support initiatives for cross border working.

6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? ii) How can the potential of any such opportunities best be realised? iii) Could environmental benefits be gained as a result of such improvements?

i) There are many opportunities available to reduce waste and ineYciency across the ATC system, ranging from altered descent and approach profiles, timed arrivals and optimal level flying. Airlines would already use these techniques if they were not constrained by UK and European ATC practices, which we believe can be made more flexible. The SESAR programme has already identified opportunities to enhance safety and improve eYciency making it vital that SESAR early deliverables are fully supported by NATS and delivered by 2012. As part of the drive to improve Heathrow performance, DfT has taken the initiative, asking the CAA to look at runway resilience to improve the passenger experience and to reduce wasteful emissions. BA has been involved with other stakeholders in developing ideas in this work; however, as the work is ongoing, we leave it to the CAA/DfT if they wish to comment further at this stage. We believe there are significant changes and eYciencies that could be made in usage of runways which could give wide reaching benefits in many key areas; reducing stacking, fuel burn, noise and emissions and direct passenger benefits reducing passenger delays. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Given the scope of benefits of the runway resilience initiative, we consider it would be beneficial to move to implement a range of changes soon. Close cooperation between NATS, CAA (DAP) and BAA would be needed to drive implementation forward. We strongly believe there is no reason for LHR not to have greater resilience and performance well before the 2012 Olympics and that to set a clear goal for all parties involved, this should be a named target by which the improvements must have been progressively implemented. European airspace rationalisation is key to unlocking much Pan-European ineYciency—with savings in the realm of £4 billion across Europe. These savings can only be realised if the whole of EU participates in SESAR. The environmental benefits will follow naturally from this. Ultimately, it is a question of national political will to design and implement cross-border, eYcient airspace integration. In addition aircraft technology is already very advanced with GPS providing ultra accurate tracking and RNAV allowing more flexible inbound routings. There is unrealised potential to use this existing technology on a trial basis to vary routes for fuel eYciency and noise profile purposes, however restrictive and onerous consultation requirements often inhibit the pursuit of these potential eYciency enablers. We suggest that Airports and NSP’s should be able to test certain changes on a strictly trial basis, with defined parameters and timescales but outside of the consultation process, with notification to aVected parties. Permanent changes as a result of the trials can then go to consultation on basis of hard evidence from all those involved and aVected, allowing accurate comparison of costs and benefits. iii) Airlines are naturally driven to reduce fuel burn to cut fuel costs and the cost of emissions—as a rough example, every ton of fuel saved, is 3 tons of Co2. If Governments and airspace providers focus on removing restrictions and improving capacity, making airspace more eYcient and eVective, then environmental benefits will automatically flow without contrived or complex strategies and limits on traYc. The EU will require emissions permits for aviation to be purchased from 2012. If national governments were responsible for purchasing the 12% of emissions permits that are needed due to slow progress in allowing eYciency in design of airspace across national borders, this might spur progress.

7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties-Department for Transport, the CAA, airport operators, NATS, etc appropriate and clearly understood? ii) Are the structures of the parties appropriate for undertaking the roles that they should play? i) This question is fundamentally about lack of clarity, which is causing lack of progress in producing a master plan and implementing change. We believe it is unclear to all those involved where ultimate responsibility for driving the redesign forward and making decisions lies. ii) This is new territory for airspace development; the UK has not built a major new runway in the South East for generations, nor has there been a strategically planned airspace redesign to cope with such expansion. Formerly there was not the level and spread of airspace congestion and future demand for growth that we see today. There are structures and organisations already in place that may be potentially appropriate to meet the new challenges. However clear leadership is needed, with clear roles and responsibilities of DfT and CAA, to use these existing structures, organisations and expertise.

8. Do airspace management considerations delay the planning processes in relation to airport development proposals? ii) How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission, and the relevant National Policy Statements on airport planning? ii) Previously airspace-planning proposals have been concentrated on step-by-step improvements to existing runways’ capacity, not new runway build. Now we are confronting the combined situation of trying to add runways whilst adding to the load on airspace from existing runways. The considerations are complex and if not carefully managed to a timetable that allows for reasonable but not excessive consultation, have the potential to create delay to progress, as mentioned in our previous answers (see Q1 (iiii)). ii) BA understands that airspace management is not in the scope of the IPC. BA has come to the conclusion that the issues of strategic airspace design can best be addressed through more clearly directed use of existing structures and expertise (see answer to Q 7 (ii), and it is not appropriate to refer to the IPC in this specialist area. BA regards it as a matter for the government as to how airspace management considerations are taken into account in relevant National Policy Statements on airport planning. In BA’s view the great majority of what should be in a National Policy Statement on airport planning is already contained in the 2003 ATWP, the 2006 Progress report on the ATWP, various other documents (such as the recently published aviation emissions cost assessment), and (in the case of Heathrow), in the consultation on Heathrow runways earlier this year—on which we await a government decision. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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9. What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? ii) How should an appropriate balance between conflicting priorities be determined? i) There is a growing national need for air transport services expansion, and for those services to be operated with less delay,first and foremost at Heathrow, but also at other commercial airports across the UK serving millions of passengers every year. This long term commercial demand growth needs to be addressed strategically in terms of aVording priority (for airspace development) to the biggest, nationally and regionally important airports, and in terms of a pricing policy for airspace use that reflects the workload created by each flight. Each movement regardless of size of aircraft is a demand on the system, and impacts available capacity. Light and recreational users may not use the full range of ASP services, but nevertheless can be a demand on the system and impact commercial aviation but without paying a towards this. In addition, short haul operators pay significantly lower charges due to the user charge calculations working on weight. In eVect commercial users are subsidising light aircraft and recreational flying, whilst long haul carriers subsidise short haul. Changes in charging mechanisms need to be implemented to make the charging fairer and related to the actual workload per unit, and to generate suYcient revenue for ASP’s to continue to invest in providing the increasing capacity. Whilst the charging framework is governed by European regulation, in SES I rules allows modulation to charges in areas of congested airspace, to incentivise eYcient use. We suggest that significant areas of airspace within the UK and particularly in the SE/London Sectors would benefit from such modulation. ii) To allow all users to maintain access to airspace, and to prevent light users impacting capacity whilst maintaining safety, it is imperative that they should be mandated to carry suYcient levels of equipment. This will facilitate safety improvements by eYciently tracking and enabling distribution of users whilst improving capacity eYciency by reducing the separation distances. We also perceive there may be too much controlled airspace at low levels in London area, and that if these aircraft had suitable levels of equipage, some lower levels could possibly be raised to provide more opportunities for non-commercial users. In converse, we have great concerns that OFCOM Spectrum pricing proposals would have adverse eVects on both safety and capacity if they were to be implemented. Light aircraft and small airfields that currently use radio would potentially be unwilling to pay the Spectrum pricing charge so resulting in large numbers of unknown movements inter weaving with commercial aircraft. This is not only a safety issue, but would also have severe capacity impacts on the airspace as ASPs would be required to introduce greater separation distances between aircraft.

10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? Given lead-time for recruitment, training and testing within the airspace environment, NATs needs to be directed within the framework of a master plan, to start planning ahead to meet projected capacity increases, rather than waiting until demand is needed. There also needs to be separate resource for operational use and development and investment as currently it is a shared resource, which is drawn and withdrawn according to operational needs, and both requirements suVer.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? Ultimately users need to fund development. Charges need to be apportioned in the right way, if you can improve performance, then benefits are self-funding and can be seen as investment. Regulation needs to set targets on a whole range of issues: track miles and fuel burn, delay minutes, flow management, performance, and successfully bringing more capacity on stream and ensure the targets are met. This would enable creation of a performance reward system. As developments are successfully brought on line and performance improvements are made, actual financial benefits are realised and funding and benefits will flow. October 2008 Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Memorandum from the Civil Aviation Authority (AIR 33)

Introduction 1. The Civil Aviation Authority (CAA) welcomes the Transport Committee’s inquiry into the use of airspace as an opportunity to generate discussion around the future airspace requirements for the UK. 2. The CAA was established as a statutory corporation by the Civil Aviation Act 1971, independent of Government, and continued by the Civil Aviation Act 1982. The main statutory functions of the CAA are: safety regulation of civil aviation within the UK; determining policy on how UK airspace is utilised to meet the needs of all stakeholders; economic regulation of the designated airports and of the provision of en route air traYc services (through the National Air TraYc Services (NATS) Licence); licensing of airlines in relation to their finances; and licensing of air travel organisers. 3. The CAA also plays a role in providing independent policy advice on aviation issues to Government, which includes: identifying and developing policy on core aviation issues; collaborating externally with national and international aviation organisations and regulatory bodies; providing a link between industry and the Government; advice on changes to UK airspace arrangements that might have an eVect on the environment; advice to Government on proposed European legislation aVecting aviation; and issues relating to consumer policy and passenger experience. 4. Within the CAA, the Directorate of Airspace Policy (DAP) is responsible for the planning and regulation of all UK airspace, including the navigation and communications infrastructure to support safe and eYcient operations. DAP is staVed by civilian and military experts with experience of commercial, business, recreational and military aviation. The power to make decisions regarding the use of UK airspace is vested in the Director of Airspace Policy. 5. The report of the independent strategic review of the CAA carried out by Sir Joseph Pilling was published in July 2008. As a starting point in his report, Sir Joseph stated, “the CAA is a world-class regulator” and said that his recommendations were “intended to help a good organisation become even better”. He found that under the CAA’s regulation, UK aviation had achieved one of the highest levels of aviation safety in Europe; that the CAA has managed safety and economic regulation without conflict and that there are significant advantages to having both functions in the same organisation; and that the CAA has improved its service delivery performance.

Legal Basis for Airspace Policy 6. The Transport Act 2000 sets out the CAA’s air navigation functions in Part 1, Chapter III. Section 70 sets out the CAA’s general duty for this purpose. The overarching requirement to maintain a high standard of safety in the provision of air traYc services set out in Section 70(1) is a duty that has priority over the other objectives summarised below: a) to secure the most eYcient use of airspace consistent with safety and expedition; b) to satisfy requirements of users of all aircraft (three categories of airspace users: Commercial Aviation, Military and General Aviation); c) to take account of wider airspace interests; d) to take account of environment objectives (set out in the Guidance to the Civil Aviation Authority on Environmental Objectives relating to the exercise of its air navigation functions); e) to facilitate the integrated operation of ATS by the Crown and others; f) to take account of national security; and g) to take account of international obligations. The CAA must exercise its air navigation functions so as to impose minimum restrictions on ATS providers consistent with the above. 7. The CAA’s air navigation functions are set out in the CAA (Air Navigation) Directions 2001 as amended by the CAA (Air Navigation) (Variation) Direction 2004 (the Directions) given to the CAA under Section 66(1) of the Transport Act 2000 by the Secretary of State for Transport and the Secretary of State for Defence and the Guidance to the Civil Aviation Authority on Environmental Objectives relating to the exercise of its air navigation functions (Environmental Guidance). The Directions established the duty of the CAA to develop, promulgate, monitor and enforce a policy for the sustainable use of UK airspace and for the provision of necessary supporting infrastructure for air navigation. In particular, the CAA is to: a) provide advice to Government in the context of both national and international arenas; b) be responsible for the form and content of the UK Aeronautical Information Publication (AIP) and ensuring that an Aeronautical Information Service (AIS) is provided in accordance with international obligations; c) determine and procure the provision of a Lower Airspace Radar Service (LARS) in UK airspace; d) discharge the responsibilities of the UK Meteorological Authority; Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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e) prepare and maintain a co-ordinated strategy and plan for the use of UK airspace for air navigation; f) develop, apply and maintain a national policy for the classification of UK airspace, including design criteria, rules, guidelines and common procedures; g) co-ordinate, determine and promulgate temporary changes in the utilization of UK airspace to meet special air navigation requirements; h) provide support for the analysis and categorisation of reported risk-bearing occurrences; i) develop, monitor and enforce a national policy for the use and assignment of civil aeronautical radio frequencies and Secondary Surveillance Radar codes; j) establish and promulgate consultation arrangements with the Ministry of Defence (MOD), DfT and air traYc service providers; k) ensure the continuation of the body known as the Joint Air Navigation Services Council (JANSC); and l) take account of the environmental guidance. 8. The Environmental Guidance sets out a clear framework within which the Director of Airspace Policy will operate in discharging the CAA’s air navigation functions and centres on: a) the need to reduce, control and mitigate the environmental impacts of civil aircraft operations, and in particular the annoyance and disturbance caused to the general public arising from aircraft noise and vibration, and emissions from aircraft engines; b) the need for environmental impacts to be considered from the earliest possible stages of planning and designing, and revising, airspace procedures and arrangements; c) where such changes might have a significant eVect on the level or distribution of noise and emissions in the vicinity of a civil aerodrome, to ensure that the manager of the aerodrome, users of it, any local authority in the neighbourhood of the aerodrome and any other organisation representing the interests of persons in the locality, have been consulted (which might be undertaken through the consultative committee for the aerodrome where one exists); d) where such changes might have a significantly detrimental eVect on the environment, to advise the Secretary of State for the Environment, Transport and the Regions (now DfT) of the likely impact and of plans to keep that impact to a minimum; e) the need for the Directorate to provide expert technical advice to the Secretary of State on environmental matters; and f) the need for the Directorate to provide a focal point for receiving and responding to aircraft-related environmental complaints from the general public.

Civil/Military Arrangements 9. The CAA (Air Navigation) Directions outline safeguards for the civilian and military Joint and Integrated (J&I) concept of Air TraYc Management mandate for the underpinning agreements to be put in place and for the continuation of the Joint Air Navigation Services Council (JANSC) to sustain and develop J&I arrangements. The J&I concept relates to a collaborative approach by the CAA, NATS En Route plc (NERL) and the MOD to the separate functions of airspace policy and planning and air traYc service provision. Within this concept it is recognised that airspace is a joint resource and that expeditious access to all airspace should be available to all users, with the exception of airspace segregated for safety reasons. The underpinning arrangements are sustained through a Memorandum of Understanding (MoU) between the CAA and the MOD, through the NATS En-Route Licence and through an Operating Protocol between NERL and the MOD, approved by the CAA. The purpose of the JANSC is to enable the CAA to oversee the arrangements between NERL and the MOD and ensure that air traYc services continue to be provided on a joint and integrated basis. It is the arena for discussing and resolving diVerences of opinion and disputes between NERL and the MOD concerning arrangements set out in the Operating Protocol and seeks to keep to a minimum the occasions on which disputes are referred to the CAA.

Airspace Policy 10. The Airspace Change Process, and the Airspace Change Process Guidance document, CAP 725, describe the process and responsibilities established to ensure that proposed changes to UK airspace are initiated, considered, refined, approved and implemented in a safe and controlled manner. The process allows for consultation on proposals with representatives of airspace users, aerodrome operators and providers of air traYc services and other bodies and individuals as appropriate who may be materially aVected by any changes proposed by the CAA in UK air navigation arrangements. The Process and Guidance are made available on the CAA website as well as in formal publications. A review of the Airspace Change Process was instigated in 2005 with a view to strengthening the Process in light of the practical experience gained over recent years and, in particular, to provide greater clarity on the roles and Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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responsibilities of those involved, the consultation activities and the environmental assessment requirements of any change. The review included extensive consultation with all major interest groups and the revised material was published in 2007. 11. When reaching a decision on any proposal, it is DAP’s responsibility to ensure that the 7-step Airspace Change Process has been followed correctly, in accordance with the guidance, and to weigh up competing demands on the basis of the information provided by the Airspace Change Sponsor, using any supplementary material requested and in-house knowledge and experience. As part of the airspace change process the Directorate’s Environmental Research and Consultancy Department (ERCD) prepares an objective report on the proposer’s assessment of the environmental impact of the airspace change. This report comments on the validity of environmental information presented and identifies the limitations of the environmental assessment undertaken by the proposer. This enables the Director of Airspace Policy to balance the environmental impact of the airspace change against the benefits and eYciency gains of the airspace change. The requirements for environmental data to be submitted as part of an airspace change proposal are described in detail in the environmental sections of CAP 725. The decision on whether to accept or reject an airspace change is based on careful scrutiny of the merits, or otherwise, of the proposal. 12. ERCD also advises Government on aircraft noise issues—this, in fact, constitutes the major part of its activities. It also, with the Department for Transport’s encouragement, provides its services to a range of organisations on a consultancy basis.

International and European Dimension 13. The UK’s geographic location brings with it a number of international obligations not only in respect of its sovereign airspace but also in respect of high seas airspace for which the UK has accepted responsibility under the Chicago Convention for the provision of air traYc services. Additionally, there are a considerable number of European influences, which need to be taken into account when considering UK airspace and developing policy for the future, including the impact of European legislation on UK airspace management and operation. Indeed, European initiatives aVecting regulation and other aspects of aviation are now a major focus for the CAA. The CAA has a number of functions that have been defined by UK Government. For example, the CAA acts as a “Competent Authority” undertaking safety regulatory activities as part of the EASA system. The CAA also engages actively on policy formation, both on behalf of DfT and independently, with the European Commission and other European aviation bodies. In addition, the UK CAA has been appointed as the National Supervisory Authority in Single European Sky terms by the DfT.

ICAO 14. The UK is a member of the International Civil Aviation Organisation (ICAO), a United Nations (UN) body with 189 member countries. ICAO has been in place since the birth of international civil aviation at the end of the Second World War, and its role is set out in the 1944 Chicago Convention, the international treaty that governs civil aviation. As a member, the UK agrees to adopt the standards and recommended practices concerning air navigation, prevention of unlawful interference, and facilitation of border-crossing procedures for international civil aviation published in ICAO Annexes. Contracting States to the Chicago Convention recognise that every State has complete and exclusive sovereignty over the airspace above its territory. ICAO provisions that directly impact on airspace arrangements are contained within Annex 2 (Rules of the Air) and Annex 11 (Air TraYc Services) to the Convention on International Civil Aviation.

European Context 15. In certain areas across the European network, air traYc management (ATM) capacity limits were reached in the late 1990s. Operational delays to flights became common and the European Commission decided to take action to address this. The Single European Sky (SES) initiative was conceived to create a more rational organisation of European Airspace and create capacity, whilst maintaining high safety standards. To achieve this, SES aimed to create an ATM system that was designed, managed and regulated in a harmonised way. The first package of SES legislation came into force in April 2004; it has delivered some benefits including a harmonised regulatory framework across Europe for ATM, which provides the institutional arrangements required to enable States and Air Navigation Service Providers to deliver additional capacity. However, many of the SES concepts are still relatively immature, and an ongoing programme of development of Implementing Rules (IRs) to flesh them out is still underway and, consequently, we have yet to see major capacity benefits as a direct result of SES. Nonetheless, these IRs increasingly impact on many aspects of European ATM, including the design and operation of airspace, Air TraYc Services charging arrangements and the regulation of ATM. During 2008, the European Commission has launched a new initiative known as the SES II package to accelerate the implementation of the first package of measures, to introduce further performance-enhancing measures and to ensure ATM plays its part in achieving sustainable aviation. These issues are further explained at paragraph 33. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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EUROCONTROL 16. EUROCONTROL is the European Organisation for the Safety of Air Navigation, created in 1963 by six founding members. This civil and military inter-governmental organisation is now formed of 38 Member States from across Europe. EUROCONTROL’s objective is the development of a uniform pan- European ATM system, embodied in the concept of a Single Sky for Europe, which will contribute to making European aviation safer, more secure and more environmentally friendly. The governance structure of the Organisation is composed of three bodies: two governing bodies, the EUROCONTROL Commission and the Provisional Council, and one executive body, the Agency. In particular, the Agency performs the following functions from a pan-European perspective: a) The Central Flow Management Unit (CFMU) provides Air TraYc Flow and Capacity Management (ATFCM) to airspace users throughout the European States to avoid overloads and to ensure that available capacity is fully exploited. b) The Central Route Charges OYce (CRCO) of EUROCONTROL bills and collects en-route charges on behalf of Member States by virtue of a common policy that builds on the provisions of the Multilateral Agreement relating to Route Charges. Route charges remunerate the costs incurred by the EUROCONTROL Member States for providing en-route services to the users of their airspace. c) EUROCONTROL’s Maastricht Upper Area Control Centre (UAC) ensures the safe, eYcient and expeditious flow of civil aircraft in the upper airspace (above 24,500 feet) of Belgium, the Netherlands, Luxembourg and the North-West of Germany. A Deutsche Flugsicherung (DFS) unit, controlling military air traYc over the North-West of Germany, is co-located with the civil facilities. d) The Agency develops implementing rules which complement the high level Regulations adopted by the European Parliament and Council. 17. The Airspace, Network Planning & Navigation Division (APN) focuses on the design and planning for a cost-eYcient, dynamic pan-European ATM network operation; their activities bring together all the key elements of: Capacity Enhancement Planning ATS Route Network and ATC Sector Design; Airspace Management; and Improved Civil-Military Coordination.

Current Issues

Air Transport White Paper 18. In December 2003, the Government set out a long-term strategy for the sustainable development of air travel for the period up to 2030. This strategy aimed to balance the growing aspirations of the public to travel and the needs of the UK economy together with the requirement to protect the environment. It proposed a comprehensive strategy that: a) committed the Government to ensuring that aviation reflects the full costs of its climate change emissions, which will influence the amount of traYc growth that will occur; b) put in place tough local environmental conditions for the UK’s most environmentally sensitive airport, London Heathrow. Further expansion in flights would not be allowed unless limits on noise and air quality could be met; c) recognised that aviation brings real benefits to the lives of ordinary people and to business. It connects people and places in ways that many people value highly and is also critical for a successful economy; d) did not take forward proposals for new capacity at several airports and at new green field locations, and instead promoted making better use of existing airport capacity. The strategy supported the development of regional airports mostly within existing capacity, as well as the construction of a further runway at Stansted and at Heathrow, and measures to make better use of existing runways at those airports. The White Paper set the context for the environment within which the CAA performs its airspace functions.

Air Transport White Paper Progress Report 19. In December 2006, the Government published a Progress Report on the White Paper, which provided updates in the following key areas: a) Prioritisation of optimisation of the UK’s existing airports through a process of improvement and modernisation. Growth and developments at regional airports, without the need for new runways, would provide improved access across the country to air travel from modern airports. Edinburgh and Birmingham airports, where new runways were supported, do not now expect to build them until some time after 2020. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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b) At Heathrow, where The Future of Air Transport White Paper indicated that a new runway could be delivered in the period 2015 to 2020, expanding the airport is conditional on meeting the noise and air quality limits that the DfT set. Consultation would take place to determine whether the environmental impact of making more use of existing runways, or building a third runway, would be acceptable. c) At Stansted, potential for the second runway would need to follow the due planning process. d) An update of the Government’s forecasts of air passenger demand and changes in the aviation industry was provided. e) The report set out the progress achieved towards meeting the strong demand for air travel, but aYrmed that this needed to be delivered in a way that balanced the need to manage aviation’s environmental obligations. f) The report also set out specific next steps in delivering the Government’s policy. It is against this backdrop, where decisions are still awaited from the consultation and planning process, that the CAA continues to evaluate airspace change proposals.

Providing Advice to Government 20. In the context of this Inquiry and the Directions, the Directorate of Airspace Policy has a remit to provide advice and assistance to the Secretary of State for Transport and the Secretary of State for Defence. In the main, this advice is oVered as technical assistance to the DfT and takes a variety of forms eg it includes direct participation in DfT-run project or programme Boards, such as in the case of Project Sustainable Development Heathrow (PSDH), involvement in international negotiations on matters such as the Single European Sky or responding to formal consultations. In addition, DAP staV have routinely provided technical advice and assistance to Defra, BERR, Ofcom, other non-Government departments and to the Inspector at Planning Inquiries, such as at the Coventry inquiry in 2006 where the Inspector’s report stated that CAA input was highly valued.

Strategic Review of the CAA—Environmental Recommendations 21. In his Report on the Strategic Review of the CAA, Sir Joseph Piling recommended that the CAA be given a general statutory duty in relation to the environment, which would be set within a policy framework that would provide a clear boundary between the roles of the Department, other stakeholders and that of the CAA. The Review recognised the diYculty of producing an environmental policy framework in the context of aviation but stated that there needed to be suYcient context and detail to enable the CAA to reach decisions that were aligned with Government policy. He also recommended that the guidance on the environmental objectives in relation to the CAA’s Air Navigation functions be reviewed. The CAA welcomes the report overall and we are considering the detail of the recommendations; we look forward to working with the DfT in progressing the issues.

Future Airspace Strategy (FAS) 22. Planning for future airspace requirements results from a complex mix of international agreements and domestic aviation and transport policy. Furthermore, separate ownership of the airports situated within the busiest and most complex airspace in the southeast of the UK could further complicate current arrangements and generate potential conflicts that will need to be addressed in the future. The international context is driven from obligations stemming from the Chicago Convention, which are imposed upon the UK as Standards and Recommended Practices, through European legislation emanating from both the European Single European Sky proposals and, increasingly, from the European Aviation Safety Agency (EASA). It is the task of the Directorate of Airspace Policy, working very closely with colleagues in other parts of the CAA, NATS, the MOD and wider industry to turn this complex combination of inputs into sustainable policy for the safe and eYcient use of UK airspace. In this context, the CAA has recently commissioned NATS, as the monopoly en-route service provider, to initiate a study into the future requirements for airspace, air traYc management and navigation policy for the busiest portions of UK airspace. This work has been called the Future Airspace Strategy and NATS is engaged currently in the early stages of scoping the project. The Strategy will look out to the end of the Air Transport White Paper planning timeframe of 2030 and, in the context of emerging drivers for change emanating from Europe, in the form of the SES II proposals and the SESAR project (described in paragraph 32). The Strategy will seek to determine the optimum evolution of UK airspace that will deliver high levels of safety in a sustainable manner, while meeting the anticipated demand in the most eYcient way possible and making the best use of the available technology. The Strategy will also ensure that where changes are required to existing airspace, these new arrangements provide a structured and cohesive approach over a long period that will meet the necessary capacity demand. The initial stages of this work have highlighted a number of key issues that can be grouped into four requirement areas under the headings of: airspace policies, regulatory process, technology mandates and equipage, and environmental policies. These issues are now being progressed in conjunction with DfT, NATS and the MOD. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Competition Commission Investigation into BAA Airports

23. The CAA submitted a number of papers, submissions and oral evidence throughout the Competition Commission’s Investigation into BAA Airports. All of the material is available on the Competition Commission’s website at: http://www.competition-commission.org.uk/inquiries/ref2007/airports/index.htm

Environmental issues

24. The profile of environmental issues in relation to aviation has risen in recent years. Within this wider debate, there has been significant focus on aviation’s impact, both locally (eg noise and air quality) and globally (eg climate change). Further policy developments from the Government (eg continuing delivery of the Future of Air Transport White Paper agenda and recently published White Papers on energy and planning), the publication of high-profile reports with an international dimension (eg the Stern Review and recent reports from the Intergovernmental Panel on Climate Change), published against a background of already high public interest, combined with the steady growth in air traYc and the need to provide extra capacity at UK airports, will ensure that aviation retains a high profile in environmental terms. The current operating environment and economic pressures have resulted in flight eYciency featuring highly on the agenda of airspace users and Air Navigation Service Providers and, in addition, this has positive benefits for the environment. 25. While the CAA exercises its main functions in safety, airspace policy, economic and consumer regulation, it also has a number of environmental roles in the context of its statutory functions. The CAA’s specific environmental responsibilities set by the UK Government include: assessing environmental issues when deciding any changes to UK airspace; undertaking noise studies for Government, airports and local authorities; advice on the economic impact of environmental policies, and specialist advice to Government, including studies on Aviation White Paper proposals. 26. Within an airspace design context there are a number of competing environmental factors that need to be considered and that will aVect the final decision. The CAA (Air Navigation) Directions require the CAA to take account of “the need to reduce, control and mitigate as far as possible the environmental impacts of civil aircraft operations, and in particular the annoyance and disturbance caused to the general public arising from aircraft noise and vibration, and emissions from aircraft engines”. In order to achieve this, DAP requires Airspace Change sponsors to provide an environmental assessment of their proposal which should include: traYc forecasts; an assessment of the eVects of noise; an assessment of the change in fuel burn/ CO2; an assessment on the eVect of local air quality, and an economic valuation of the environmental impact, if appropriate. 27. There are also a number of environmental factors that can be improved or worsened (or remain unchanged) when airspace changes are implemented. These include noise impact on the population, aviation emissions such as CO2, local air quality, the impact upon tranquillity and visual intrusion. In many cases, these factors may act as opposing influences when designing airspace and routes. Two examples of such conflicts are: a) Aircraft noise versus fuel burn and green house gas emissions. In order to minimise the amount of fuel burnt (and thereby minimise emissions), direct routings are preferred because they reduce the track mileage that each aircraft flies. However, a more direct route may take an aircraft directly over a centre of population thereby aVecting a greater number of people in terms of the noise impact. b) Minimising the population overflown versus tranquillity and visual intrusion. In order to minimise the number of people overflown (and thereby reduce the number aVected by aircraft noise) flights sometimes can be routed away from centres of population. However, this could mean that they fly over areas that are less densely populated such as Areas of Outstanding Natural Beauty and/or National Parks. This could have an impact upon the special qualities of such areas by reducing tranquillity and/or causing visual intrusion. Whilst there are physical limits that will set the limit for the visibility of any object, the issue of visual intrusion is subjective, and individuals will have diVering opinions and perceptions. There is no pre-determined formula for assessing these diVering impacts and consequently the CAA is required to exercise its judgement, based on the requirements set out in the Transport Act 2000. 28. It is feasibly an over-simplification to suggest that airlines will always seek to reduce fuel burn as the overriding operational consideration. It is perhaps fairer to say that airlines will always seek to minimise costs, and as the cost of fuel increases, then the amount of fuel used becomes a more significant factor. Whilst the price of fuel is only one element of the cost base for airlines, it is playing a more predominant role and gaining in significance as an influencing factor for operators in deciding the most “eYcient” route and in seeking to use airspace eYciently; as a consequence, this is generating environmental benefits. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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29. One of the techniques that can be employed to minimise the noise eVect is Continuous Descent Approaches (CDAs), an operational procedure that has been developed which results in both a fuel saving and a reduction in the noise impact when aircraft are approaching an airport to land. All airspace change sponsors are asked to consider how CDAs might be implemented as a result of the proposed change but, for a variety of reasons, eg conflicts with other traYc, sometimes it is not possible to implement CDAs. 30. The delivery of the Government’s aspirations in respect of renewable energy has led to a significant growth in wind turbine developments, both on-shore and oV-shore. Inevitably, the construction of these structures has led to potential conflicts with aviation as a result of their possible impact on the performance of technical systems, including radar, and the need for physical aerodrome safeguarding. The CAA has been working with Government departments, aviation stakeholders and the wind turbine industry for some years to help identify the particular issues and to work to develop appropriate mitigations, which would enable aviation and the renewable energy sector to co-exist, as far as is practicable, whilst maintaining safety imperatives. To this end, and recognising the requirement for DAP to consider the needs of all airspace users, the CAA has: assisted in developing a pre-planning consultation process; continues to fully participate in the appropriate Government-sponsored working groups and committees to progress issues; has published guidance to assist aviation stakeholders in how they should deal with the planning issues and the impact of developments; in addition to providing impartial advice and guidance to all stakeholders, including planning authorities. More recently, the CAA has demonstrated its commitment to progress the delivery of work streams within an Aviation Plan to implement measures designed to mitigate the impact of wind turbines on aviation. This was achieved through an MOU signed jointly with BERR, MOD, DfT, NERL and BWEA in June 2008. The potential conflict between aviation and wind turbine development remains a long-term issue but is one which Government departments and the CAA see as appropriate for engagement to best serve the disparate needs of the UK.

European Issues 31. It is key that the CAA continues to engage with DfT, European institutions and other National Supervisory Authorities in an eVective and constructive manner. The principle of harmonisation and the application of common rules across European airspace and air traYc management are fully understood and accepted. However, it is essential that the UK’s requirements are met and it is therefore important that the CAA’s position and that of the UK aviation sector continue to be reflected in major European developments. The CAA will continue to work together with other aviation stakeholders to influence the development of European regulations and policies and institutional structures to ensure that, wherever possible, developments are compatible with UK policy and that they are consistent with Better Regulation principles.

SESAR 32. SES in itself will not result in a new European ATM system and, in parallel, industry has come forward with a proposal for a project to define, develop and deploy a new system—the SES European ATM Research (SESAR) programme. SESAR has now completed its definition phase and the outcome, the ATM Master Plan, will give rise to considerable research and development work over the next few years. This should lead to the progressive deployment, from seven years hence, of a new European ATM system that should sustain European aviation from an ATM viewpoint for the following 30–40 years, whilst also meeting EU-level objectives for safety, environmental impact and eYciency.

SES II, Extension of the EASA System and Airport Capacity 33. Overall, the drivers for a Single Sky have changed with a focus now on areas such as cost, fragmentation of service provision and the environment, rather than just delays. Recognising the challenges that lay ahead, the Commission set up a High Level Group, comprised of senior figures in European ATM, to make recommendations to improve the eVectiveness of the regulatory framework in Europe. Its report, which was published in summer 2007, set out ten recommendations on what needed to be improved in European ATM, calling for a focus on driving higher levels of performance. Addressing the Report’s recommendations, at least in part, the Commission came forward in June 2008 with a package of proposals known as SES II. These proposals aim to amend the existing SES legislation to deal with performance and environmental challenges, create a regulatory environment to allow future technology to be developed and implemented (SESAR), to create a single safety framework for European ATM through the extension of the EASA system and to deliver an “action plan for airport capacity, eYciency and safety”. The CAA continues to work in partnership with EASA as the Agency’s remit is extended. The CAA recognises that although a considerable amount of aviation safety rulemaking will transfer to EASA, there will still be a substantial and vital role for the UK in overseeing the safety performance of its aviation industry, currently one of the largest in Europe. The CAA, working with DfT, will be closely involved in the discussion of these proposals as they proceed through the Council and Parliament. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Answers to Specific Questions set out in the Inquiry

What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented? 34. Whilst it is likely that long-term growth in air travel (as outlined in the Air Transport White Paper) will still occur, the current economic climate may mean that such growth will be achieved later than originally predicted. In the short term, low GDP and consumer expenditure growth, combined with higher oil prices, may lead to air travel becoming more expensive at a time when passengers’ disposable incomes are under pressure. However, the immediate eVect on passenger numbers will depend to some extent on airlines’ responses to these circumstances, whilst in the longer term, economic conditions can be expected to improve. 35. The Directorate of Airspace Policy works to traYc forecasts provided by the DfT and which were used in drawing up the White Paper and the subsequent Progress Report in 2006. DfT forecasts are subject to periodic revision to take into account latest developments in the economy and the industry. 36. The Air Transport White Paper encouraged airports to produce and publish Master Plans but these were largely based on the individual airports’ aspirations and, in most cases, did not take into account the airspace requirements, nor were they detailed assessments of future market developments. It is, therefore, not surprising that the total traYc forecast obtained by combining the forecasts of individual master plans greatly exceeds the DfT’s national traYc forecast. The CAA and NATS are of the view that, were all of the southeast airport development plans to come to fruition, there would not be suYcient airspace capacity to accommodate the scale of predicted traYc growth on the basis of current and anticipated technology developments. However, it is unlikely that every airport will implement its original development plan, since a number of airports (for example Birmingham and Luton) have already indicated that they will not pursue such ambitious expansion. 37. There are, potentially, other factors that will also require airspace capacity such as the growth in business jets (including Very Light Jets (VLJ)) and Unmanned Aircraft Systems (UAS) that have not been accounted for in existing plans.

Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for air traYc control? 38. The CAA works collaboratively with industry to continuously improve aviation safety and address safety issues. The CAA will take any actions necessary to ensure that safety is not compromised and will ensure that the high safety standards within UK airspace, and its supporting infrastructure, are maintained, with potential risks identified and appropriate mitigating actions taken. 39. In all of the CAA’s considerations, safety has primacy—in theory and in practice. DAP works very closely with Safety Regulation Group colleagues and the service providers to ensure that safety is paramount. There are adequate checks and balances in place to ensure arrangements are safe and, should evidence ever indicate that safety could not be maintained, action would be taken to limit the service until safety levels are assured. The CAA is working with European and international colleagues, and aviation stakeholders to assess the impact that the introduction of new aircraft and systems, such as VLJs and UAS, will have on airspace arrangements. The risks associated with the introduction of these new operations will need to be fully understood and mitigated to a level that is acceptable. 40. The International Civil Aviation Organisation (ICAO) has harmonised the approach to Safety Management Systems (SMS) for air traYc and aerodromes with the result that SMS has for some time been a reality for Air Navigation Service Providers and airport operators. Work is now underway to extend this requirement to Air Operator Certificate holders and approved aircraft maintenance organisations. One of the fundamental parts of the ICAO Safety Management System requirements is that each Member State should determine a State Safety Programme. The UK CAA has made progress towards compliance with this requirement by the publication of documents such as the Safety Plan in 2006 and subsequent updates and through the revision of other related guidance material. Further compliance will be demonstrated through the publication of a CAP detailing the State Safety Programme for the United Kingdom, which has been developed by the CAA in conjunction with the MOD, DfT and Air Safety Support International, and is expected to be published this autumn. 41. The CAA takes a proactive stance to safety worldwide and uses UK data to identify safety trends applicable to UK aviation, prioritising this information, using a risk based approach, to focus on the most significant safety issues. The resulting safety improvement initiatives are captured in the CAA Safety Plan, which provides a means of monitoring progress and eVectiveness. 42. The UK’s civil/military interface arrangements are considered by many in Europe to be a model of best practice. There is eVective integration on policy matters, service provision and procedure development between both civil and military service providers and regulators. Indeed, the CAA works closely with the military and civil air traYc service providers across all areas to ensure the proper level of coordination is maintained, from the JANSC through to individual working groups. Furthermore, the interface between Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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civil and military air traYc is greatly enhanced and strengthened by the co-location of military units at NATS’ London and Scottish and Oceanic Area Control Centres, where civil and military controllers use the same data and facilities.

Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently? 43. In the initial part of the time span covered by the Air Transport White Paper, existing airspace change processes have delivered the requisite capacity to meet demand. However, forecast growth and particularly airport master plans have raised expectations and concerns within the industry and amongst the public that suYcient airspace capacity will not be available, in particular in the southeast of the UK. In response to this, and the expectations set out in the White Paper, work has started on a Future Airspace Strategy (FAS). The objective of the FAS is to set out a strategic plan for the reorganisation of the busiest portions of UK airspace out to 2025 so as to ensure safety, secure airspace eYciency and deliver the greatest degree of environmental mitigation, whilst ensuring cohesiveness with European strategies. FAS is designed to avoid the limitations of a piecemeal approach but it is important to recognise that such a strategy cannot be developed in isolation. ICAO, SES and EUROCONTROL all have increasing influence and importance.

How are the eVects [of] aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? 44. The Airspace Change Process, as set out in the DAP Airspace Charter (CAP 724) and its associated guidance in CAP 725, clearly sets out the process to be followed, including the environmental and consultation requirements. CAP 725 details the individual steps to be followed throughout the process and provides extensive advice on the environmental requirements, which reflects the high-level Guidance to the Civil Aviation Authority on Environmental Objectives relating to the exercise of its air navigation function (Environmental Guidance). Clearly, there is always a balance to be struck, and in reaching a decision DAP will consider the individual nature of the proposal in the context of the overarching principles of environmental benefit, airspace management considerations and the overriding need for safety.

How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? 45. The UK situation is pivotal to the North Atlantic air traYc flows, between North America and Europe, as well as the north-south flows to and from the Iberian Peninsula and Balearics. Any delays at Heathrow or in UK airspace have a rapid and significant knock-on eVect to the rest of Europe. The existing route network and design is achieved co-operatively through a process managed centrally through EUROCONTROL, with the appropriate UK representation. The SES II proposal to establish a Network Management Function is designed to enhance the existing arrangements and to ensure the overall network eVect is given greater consideration. This is important for the UK due to its geographic location and, as such, we are maintaining close involvement in the development of the SES II proposals. The introduction of the UK/Irish Functional Airspace Block (FAB) has rationalised existing airspace arrangements between the two countries. Future FAB developments include the proposed Central Europe FAB (FABEC), involving Belgium, France, Germany, Luxembourg, Netherlands and Switzerland, and their Air Navigation Service Providers, including Eurocontrol as the service provider for the Maastricht Upper Area Control Centre. The area covered by FABEC is one of the highest traYc density areas in the world made up of over 1.7 million km of airspace comprised of closely interlaced civil and military traYc routes and areas. Clearly, there are important implications for the UK’s airspace if such a large area of European airspace and its traYc flows were to be reorganised and, as a direct consequence, the UK has been involved in a number of working groups and continues to be an active cooperative partner in the ongoing developments.

What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? 46. The UK is at the forefront of the introduction of new techniques, with airspace changes under development that would require Continuous Descent Approaches (CDA) and Precision Area Navigation (PRNAV) routings and profiles. However, it is clear that new tools are required to deliver the gate-to-gate concept and improved arrival/departure flows. It is hoped that work currently underway in SESAR will deliver some of the technical improvements that will enable optimisation of direct routings and other potential benefits; however, there is insuYcient detail at this time to determine exactly what improvements will be generated. The Future Airspace Strategy is also designed to address some of these issues and this will need to be closely aligned with SESAR. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play?

47. The CAA considers that the roles and responsibilities of the principal parties are appropriate, and are clearly understood by those parties. CAP 724 and CAP 725 clearly delineate the roles and responsibilities for DAP and the airspace change sponsor and reflect the essential clear distinction between the change sponsor and the decision maker. The responsibility for undertaking proper consultation should rest, appropriately, with the change sponsor who after all must own the implementation of the final airspace arrangements and will be responsible for safe service delivery. The Directions provide that, where changes to the design or to the provision of airspace arrangements or to the use made of them which might have a significant eVect on the level or distribution of noise and emissions in the vicinity of a civil aerodrome or under the arrival tracks and departure routes followed by aircraft using a civil aerodrome but not in its immediate vicinity, the CAA shall refrain from promulgating the change without first securing the approval of the Secretary of State. However, although these roles and responsibilities are clear to those principally involved, the wider public does not fully appreciate the individual roles of the CAA, DfT, airport operators and Air TraYc Service Providers and their associated responsibilities with regard to airspace. 48. DAP is properly resourced with the right mix of technical expertise to deliver airspace change in relation to the duties as currently defined in legislation and statutory duties. Clearly, this will need to be kept under review if any changes to the CAA Directions or associated Guidance occur as a result of the Strategic Review Report. It may then be necessary for CAA to recruit individuals with diVerent areas of expertise, such as in the area of emissions, to provide the necessary structure.

Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning?

49. Evidence shows that all Airspace Change proposals have been delivered against their original target dates, where it has been appropriate to approve the change. Where there is a need to build new infrastructure, airport operators have accepted that airspace change elements can be delivered within their required timescale and this is not a limiting factor in their planning considerations. Airspace management considerations will only feature in the Infrastructure Planning Commission (IPC) where the development is large enough to reach the IPC threshold even then, the precise nature of any airspace related decision is yet to be determined. In all other cases the Airspace Change Process will be followed.

What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined?

50. The UK has a finite amount of airspace, although capacity to move air traYc can be increased through re-sectorisation and through advances in technology. Particularly in the southeast of the UK, airspace is in great demand for use by Commercial Air Transport and the General Aviation community. Current airspace arrangements have, to date, enabled the competing requirements to be met, albeit often by reaching a compromise solution that while safe, does not fully meet the needs of all user groups. Historically, where priorities conflict, priority has been given to meeting the demands of major airports and the needs of recreational flying have been accommodated where they can, without impacting on the safe operation of Commercial Air Transport. There is a requirement to take into consideration the needs of all airspace users and the interest of the public as a whole when determining policy for the safe and eYcient use of UK airspace. Helicopter operations can be accommodated safely through normal Air TraYc Control arrangements. Within the London Control Zone the arrangements for helicopter activity have been reviewed recently and enhancements put in place.

Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity?

51. CAA resources are not a limiting factor in the approval of airspace change proposals at the current rate of delivery. It is not anticipated that this will change significantly in the years ahead as the Air TraYc Control system can only cope with a finite amount of change each year. Such changes are only generally made in the spring and autumn to avoid the peaks of traYc conventionally experienced during the summer months and this enables the workload to be managed eVectively. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? 52. Notwithstanding the need to consider the environmental benefit, airspace changes are normally initiated when safety, demand or capacity require it. Whilst anybody can initiate an airspace change, in most cases the requirement for such a change originates from Commercial Air Transport needs and the CAA principally believes that changes will be initiated by an aerodrome operator, an Air Navigation Service Provider, or a combination of the two, to meet this commercial demand. Consequently, it is entirely appropriate that the airspace user community should fund changes as they are initiated to meet their requirements. October 2008

Memorandum from Mrs Alastair Robinson (AIR 34)

Stacking of Aeroplanes Approaching Stansted Airport Richard Spring has informed me that the House of Commons Transport Committee has announced that it will be conducting an inquiry into the use of air space. As you will know there is very passionate objection in this area to the alteration in the plans for stacking the planes waiting to land at Stansted. The new plan would mean the planes would stack in a loop above a large area of tranquil villages and stud land, at the moment remarkable for its tranquility and undisturbed beauty. The scenario we are confronted with is that, under the proposed scheme we might have as many as 33 planes an hour overhead at a height of a mere 4,500 feet at peak hours, which as you will appreciate will transform what until now has been a wonderfully peaceful collection of villages and small towns into the general hubbub from which we have chosen to distance ourselves. People who choose to live in rural areas, and there are many thousands of us, willingly forego the convenience of immediately local schools, shops, doctors, post oYces etc., for the compensating virtues of peace and quiet and the solidarity of a vibrant local community. Must this be threatened so drastically by the advent of deafening noise which would here be life-changing, whereas flights above many busy towns are scarcely noticed? I am informed that other European countries seem to manage a far steeper descent for planes waiting to land which causes less disturbance to the surrounding regions and we would really appreciate it if your committee would press the Air Transport authorities to consider this in depth or look more thoroughly at the stacking of the planes over the Thames Estuary which could be the long term solution. We have of course written to all the relevant authorities about this and hopefully they will at least be considering our objections. Nevertheless we are particularly pleased and relieved to know that you will be conducting an Inquiry into use of air space. This is a matter of great significance to this small country and particularly to its much loved rural areas. September 2008

Supplementary memorandum from the Civil Aviation Authority (AIR 33A) 1. Following the CAA’s appearance before the Committee on 21 January, the CAA is pleased to provide the following additional information, requested by the Committee, which we hope will be helpful to the inquiry.

Airspace and Aerodrome Considerations for Bird Control 2. From the CAA perspective, there is no direct link between airspace capacity and the bird strike risk and, therefore, it is not specifically addressed through the Airspace Change Process. However, any risk associated with potential bird strikes and the operation of a particular airport or runway will be dealt with through the Safety Management System (SMS) of the airport operator. Furthermore, this SMS will be the subject of oversight by the CAA’s Safety Regulation Group. 3. CAA activity in relation to bird strike risk is conducted at two levels. a) At the strategic level, in line with international requirements, the Department for Transport has tasked the CAA with the role of hosting the UK Bird Strike Committee (UKBSC). This committee meets annually, with both national governmental department oYcials and industry stakeholders, to share information and best practice on the subject of bird hazard management. During 2007–08, and as a result of stakeholder engagement via UKBSC members, the CAA conducted a review of its publication CAP 680 Aerodrome Bird Control and republished it completely as CAP 772 Bird Strike Risk Management for Aerodromes. As well as providing comprehensive advice to aerodrome Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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licence holders on the subject of the management of the risk of bird strikes, this document introduced a set of definitions outlining the scope of confirmed, unconfirmed and near-miss bird strike events to enable the CAA to conduct smarter analysis of data. b) At the operational level, responsibilities fall in a number of areas. For example, it is mandatory for aircraft commanders to report to the CAA all bird strikes that occur whilst the aircraft is in flight within UK airspace. In addition, the CAA encourages the voluntary reporting of unconfirmed, or “near-miss” bird strike occurrences. In January 2008, the CAA introduced an online bird strike reporting system to facilitate easier reporting and data handling. The CAA uses the UK bird strike data to inform its safety regulatory oversight of aerodromes (eg aerodrome audits) and to identify any adverse trends. In addition, the bird strike statistics are published on the CAA website. 4. Additionally, CAA-licensed aerodrome operators are required, as part of their Safety Management System, to identify the risk to aircraft operations posed by wildlife at their location and to adopt measures to reduce the likelihood of collisions between wildlife and aircraft. The Airport Operators Association and the General Aviation Awareness Council, supported by the CAA, have also produced a series of Advice Notes, which provide advice on proposed developments located within the safeguarded area of an aerodrome, including those likely to attract birds. Operational Air TraYc Control procedures are also in place to warn pilots of the bird strike risk when it is necessary. 5. In recognition of the specific safety threat posed by the increasing population of Canada Geese, the CAA published, in 2001, a document entitled Large Flocking Birds—An International Conflict Between Conservation and Air Safety to provide information relating to the management of this particular wildlife hazard. Between 2003 and 2008, there have been 29 reported bird strike events involving geese in the UK. Of these, six resulted in damage to the aircraft and in one case the aircraft returned to the departure airport. However, the overall trend for bird strikes involving geese has reduced from ten in 2004 to four in 2008.

UK Pilot Training for Emergency Landings on Water 6. Current European training requirements for flight crews of commercial air transport aeroplanes include the need for pilots to be trained on all major emergencies within a three-year period. Individual European operators may tailor their training programmes to suit their operation, but the programmes must be acceptable to their respective National Aviation Authorities (the CAA in the UK). The programmes need to include all elements required by regulation, must meet periodicity requirements and must address appropriately perceived safety risks. Although the majority of such training will be carried out in simulators, some scenarios are more eVectively dealt with through the classroom environment. In addition, the specific emergency procedures for major aeroplane types are determined by the manufacturer and are used worldwide, with minimal local variation, during training for that type. 7. Training for emergencies requiring immediate actions to be performed from memory, for example double engine failure on a twin-engined aeroplane, are generally required to be practised more frequently than other emergencies. Normally, a simulator scenario for this type of emergency would commence at an altitude much greater than that achieved by the Hudson River accident aircraft when it suVered the loss of power. This allows those immediate actions that must be performed from memory, and the subsequent checklist actions, to be put into eVect, and the relighting of at least one engine to be attempted. There is no requirement in the USA or Europe for a landing with no power to be practised. This is mainly because simulators are not capable of reproducing water landings (ditchings) with fidelity, as the data to enable this is not available. However, the procedures for landing (either on water or on land) with no engine power are generally trained in the classroom. February 2009

Supplementary memorandum from the Civil Aviation Authority (AIR 33B) 1. Following the CAA’s appearance before the Committee on 22 April, the CAA is pleased to provide the following additional information, requested by the Committee, which we hope will be helpful to the inquiry.

Whether the CAA is a statutory consultee in planning applications to change airports into diVerent alternative use (Qq 552–557) 2. Section 19 and Schedule 2 of the Civil Aviation Act 1982 makes provision for the CAA to be a statutory undertaker for a number of purposes, none of which includes the purpose described by the Committee. In addition, planning legislation sets out a number of consultation requirements for developments, but again the CAA is not a statutory consultee for the purpose described. However, the CAA would be made aware if a licensed aerodrome was to cease to be an aerodrome because the licensee would be required to surrender the licence. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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3. The Department for Communities and Local Government has recently concluded a public consultation on a list of statutory consultees for National Policy Statements. The consultation included a proposed Statutory Instrument—Infrastructure Planning (National Policy Statement Consultation) Regulations 2009—which will include the CAA as a consultee where any National Policy Statement relates to airports. The CAA supported its inclusion on the list. May 2009

Memorandum from M I Rushton, Cambridgeshire (AIR 35) I would like to submit my concerns over proposed changes to flight paths in this area. My great concerns are: — Safety issues: which would arise due to any increase in air traYc in an area already coping with considerable military aircraft. — Intolerable noise levels: where not only would residents, but also the racing industry, be aVected badly. — Alternatives are available: ie using space over the sea where quality of life to people living below would not be aVected. — Concern as to whether UK airports can safely handle much greater volumes of passengers than they do already, especially at a time of environmental issues. — I can only see the balance of conflicting interests being struck by compromise, financial and growth matters not always being allowed to destroy others peace and tranquility. October 2008

Memorandum from the Airport Operators Association (AOA) (AIR 36)

1. Introduction This response to the House of Commons Transport Committee’s invitation to submit evidence on its Inquiry into the use of airspace is submitted by the Airport Operators Association (AOA), the trade body that represents the interests of and speaks for British airports. AOA’s membership is drawn from a wide range of British airports and includes all of the nation’s major international and regional airports and a significant number that operate in the field of business and general aviation. A listing of our membership is attached at ANNEX 1.

2. Summary — AOA believes that the forecasts presented in the 2003 Future of Aviation White Paper continue to be valid; — Greater strategic interplay between military and civil airspace is required with a key component being the critical examination of “ownership” of airspace and the potential release of military airspace for civilian commercial use; — The development of a UK Airspace Master Plan is essential; — The present framework for airspace development is demonstrably piecemeal; — The current framework for consideration of airspace changes in the civil sector contains comprehensive environmental impact and stakeholder engagement provisions; — All UK aviation stakeholders, legislators, regulators, air navigation service providers, airspace users and airports, must support the development and implementation of the Single European Sky ATM Research (SESAR) programme and by doing so contribute to the new technologies and techniques that will be delivered; — SESAR presents the opportunity for a pan-European solution to address the current fragmented nature of airspace over Europe and thereby to facilitate greater eYciencies in the system and enable capacity for the forecast demand in air transport to be met; — Consistent with the work being undertaken in SESAR there has to be a more co-ordinated approach to the planning and design of airspace in the UK with a clear understanding of the roles and responsibilities of entities such as CAA, DAP and DfT; — AOA considers that Government should be responsible for the funding of the structured programme for the redesign of UK airspace but that changes or developments within that redesigned framework should be funded by the party proposing the change or development; Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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— There are issues that have airspace impacts and are of particular concern to airports but which are not being addressed by the Committee’s Inquiry. These include the development of windfarms in the local airspace under the control of airports and the potential impacts on air traYc control radar and aircraft approach procedures. These issues are of significant safety concern; — In addition, there are current proposals developed by Ofcom for radio spectrum pricing which will, if implemented, impose significant costs for the provision of essential aviation safety systems e.g approach radar and approach navigational aids. As the Ofcom proposals potentially impact operations within local airport airspace we consider it appropriate to mention it in this response.

3. Responses

“What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide increased passenger demand likely to be implemented?” 3.1 AOA continues to believe that the forecast increases in passenger demand over the period to 2030 as presented in the 2003 White Paper are valid despite current economic circumstances which are likely to have a short term impact. Furthermore, we believe that these forecasts will be reflected in the development of airport capacity to meet that demand. 3.2 The 2003 White Paper notes that the additional airport capacity required to meet that forecast demand “must be matched by a corresponding increase in airspace capacity”. However, despite the White Paper’s aims for a structured programme for the redesign of UK airspace being brought forward by the CAA there has been little obvious movement towards this objective. The development of airspace would appear to continue to be progressed on a somewhat piecemeal basis.

“Can safety be maintained as airspace is increasingly utilised? Is there suitable interface between military and civilian arrangements for air traYc control?” 3.3 Safety within aviation always has to be maintained at the highest possible levels and AOA is confident that the exceptional record of all of the stakeholders in the UK aviation industry will ensure that these high standards are maintained and enhanced as time progresses and traYc increases. 3.4 At the operational level there is an eVective interface between military and civilian air traYc control. However, we do not consider that this interface is necessarily maintained at the strategic level, particularly in relation to “ownership” of airspace and any strategic initiatives to facilitate the of release military airspace to the commercial civilian sector. If such airspace could be released on a permanent basis, it would enable civilian flights to make use of that additional capacity and potentially facilitate more direct routings, which would have environmental benefits through reduced fuel burn. 3.5 The Committee will be aware that the military does allow short term release of some of its airspace eg at weekends. However, these short term fixes, whilst useful, do not provide the long term airspace capacity gains that would be greatly welcomed by commercial aviation. 3.6 An issue which is very important to UK airports and air navigation service providers (ANSP), is the forecast future critical shortage of qualified air traYc control oYcers. This is an issue which could have serious repercussions for the future development of UK aviation as a whole if it is not addressed. One useful constituent to an overall approach to this issue would be a review of the current lengthy and expensive “conversion” arrangements required for military controllers wishing to become controllers in the civil sector.

“Is the current approach to planning and regulating the use of airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently?” 3.7 The responsibility for planning and regulating airspace lies with the Civil Aviation Authority and more specifically its Directorate of Airspace Policy (DAP). While we believe that DAP is an eVective airspace regulator we also believe that there is little evidence of it developing the inclusive “structured programme for the redesign of UK airspace” as envisaged by the 2003 White Paper. In the five years since the publication of the White paper, AOA has not been invited, as the representative body for UK airports, to field any experts to contribute to this much needed work. 3.8 AOA fully supports the development of a UK Airspace Master Plan covering the period of the White Paper and beyond. Indeed, such a Master Plan could complement the work being undertaken in Europe on the SESAR initiative (covered in more detail in paragraphs 3.15 to 3.23 inclusive). A Master Plan would provide a structured framework within which airspace development could be progressed and implemented and with a presumption in favour of such developments. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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“How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck?” 3.9 Airspace change proposals are supported by a CAA document, CAP 725 Airspace Change Process Guidance. This document was initially published in 2002 but has been updated as since that time “public interest in aviation-related environmental matters has greatly increased, in part prompted by the Government’s Air Transport White Paper in December 2003. At local level, noise and emissions have emerged as significant issues…”40. Accordingly, environmental considerations play a key part in any proposal to introduce or change airspace. 3.10 Appendix B to CAP 725, Airspace Change Proposals—Environmental Requirements states: “The Civil Aviation Authority (Air Navigation) Directions 2001 (incorporating Variation Direction 2004) (HMG, 2001) requires the CAA to take into account “the need to reduce, control and mitigate as far as possible the environmental impacts of civil aircraft operations, an in particular the annoyance and disturbance caused to the general public arising from aircraft noise and vibration, and emissions from aircraft engines”. And “It is the function of this document to assist those preparing airspace change proposals in providing suYcient environmental information for public consultation and to inform the decision making process”. 3.11 CAP 725 requires airspace change proposals to be supported by: — A description of the airspace change; —TraYc forecasts; — An assessment of the eVect on noise; — An assessment of the change in fuel burn / CO2; — An assessment of the eVect on local air quality; — An economic valuation of environmental impact. 3.12 In terms of public consultation, CAP 725 requires the proposer of the airspace change to identify “all of the diVerent parties aVected by the design options”41 and to have undertaken a stakeholder analysis to ensure that it can be demonstrated that a complete consultation on the proposal has taken palace. 3.13 Regarding the balancing of conflicting interests, CAP 725 states: “Consensus is not necessary nor should it be expected. However, a Change Sponsor will be accountable for their decisions to either accommodate or disregard consultees’ responses and for providing timely feedback to the consultees. These decisions will be scrutinised and form part of the Directorate’s (DAP’s) assessment criteria at the Regulatory Decision stage. AOA considers that CAP 725 provides comprehensive and proper provisions in relation to environmental issues arising from proposals to introduce airspace changes and to take account of the views of the general public and other stakeholders in the proposal consultation process.”

“How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries?” 3.15 It is widely acknowledged that airspace over Europe is highly fragmented having developed largely around State geographic borders / boundaries. This fragmentation does not provide for a high level of air traYc management (ATM) eYciency and unless it is addressed the system will become more congested as traYc continues to grow. 3.16 As a direct result of the need to completely reconsider how European ATM will deal with the future demands for sustainable growth in air transport, the SESAR (Single European Sky ATM Research) initiative was introduced. For the first time in European ATM history an ATM improvement programme involving all of the aviation stakeholders (civil and military users, ANSPs, airports, aerospace manufacturing, regulators and legislators) has been launched with the objective of achieving a “paradigm shift” through a pan-European approach to the planning and delivery of European ATM and in support of Single European Sky legislation. 3.17 The first phase of the SESAR project was completed in March 2008 with the production of an ATM Master Plan which will form the basis of the project’s next phase, the Development Phase, to be completed by 2013. The intention is that the ATM Master Plan will be a living document which will be updated as progress is made. 3.18 SESAR is the only pan-European ATM development programme and it will only succeed in delivering its objectives through the commitment of all of the ATM stakeholders. To date the CAA, DfT, NATS, UK airports and some airlines have been directly involved.

40 CAP 725 CAA Guidance on the Application of the Airspace Change Process—Foreword 41 CAP 725 CAA Guidance on the Application of the Airspace Change Process, Page7, Paragraph 14 Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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3.19 The SESAR objectives are extremely challenging: — A three fold increase in capacity which will reduce delays both on the ground and in the air; — Improve safety performance by a factor of 10; — A 10% reduction in the eVect that flights have on the environment; — A reduction of at least 50% in the cost of providing ATM services to airspace users.

“What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements?”

3.20 Fundamental to the success of SESAR is the development and application of new technologies and techniques and as such a huge eVort is going into the necessary research and development that will enable these factors to be delivered. Associated with many of these applications is the need to deliver quantifiable environmental improvements in all phases of flight. 3.21 The aviation industry is however not sitting back and waiting for SESAR to make things happen. New air traYc control techniques including Continuous Descent Approaches (CDA) are being introduced at some airports which deliver benefits including reduced noise, less disturbance to local residents and lower fuel burn. In addition, airports generally are highly pro-active in promoting and delivering environmental mitigation and improvement schemes, many in consultation with their community stakeholders. 3.22 The work undertaken in SESAR is already starting to demonstrate how new ATM techniques and arrangements may provide benefits. Initiatives such as Collaborative Decision Making (CDM) will deliver eYciency gains by improving the processes whereby airports, ANSPs and airspace users interact and thereby deliver environmental benefits through less unnecessary fuel burn both on the ground e.g by more eVective taxiing; and in the air through more direct routings and sequenced operations that reduce the need to “stack”. 3.23 The flexible use of airspace will also enable capacity gains to be achieved as will the use of military airspace. Furthermore, the development of Functional Airspace Blocks (FABs) between neighbouring States will reduce the fragmentation of airspace over Europe and deliver improved ATM eYciency.

“In relation to the redesign of UK airspace of the roles and responsibilities of each of the interested parties— Department of Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play?

3.24 AOA has some concern that the roles and responsibilities for airspace redesign are not particularly well defined or understood. DAP is undeniably acts as an airspace regulator but there is no obvious evidence that DAP is undertaking the function of a strategic planner of airspace as envisaged by the Government in the 2003 White Paper. 3.25 Many AOA member airports consider that the overall process for airspace capacity and planning does not work well. It is piecemeal, as previously stated, is protracted in terms of process and creates diYculties for airports in planning their development plans.

“Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning?”

3.26 Airspace management can impact airport development proposals. While it is diYcult to be definitive on this issue it is possible that an airport’s development plans may include and, to some degree, be dependent upon changes to its airspace. 3.27 A more fundamental issue is that of airspace capacity and the impact that deficiencies in capacity will have on the ability of airports to eVectively bring forward development proposals to meet their plans to cope with increased demand for air transport services. Airspace is this respect becomes a key factor in the overall capacity equation. 3.28 AOA is not aware of how airspace considerations will be taken into account by National Policy Statements on airport planning. What is required is a National Policy Statement on airspace and the production of an Airspace Master Plan. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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“What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined?” 3.29 It is undeniable that changes to airspace management to enable capacity gains at major airports could impact upon the stakeholders referred to in this question. However, as stated above (paragraphs 3.9 to 3.14 inclusive) CAP 725 provides a comprehensive framework for consideration of such airspace changes and allows for all stakeholders and parties aVected by the proposed changes to be fully consulted. This CAP also includes appropriate provisions whereby conflicting priorities can be addressed. 3.30 It is also perhaps noting that the airports industry has been central to the development of a safety framework for flying undertaken outside of controlled airspace—Air TraYc Services Outside of Controlled Airspace (ATSOCAS). This framework is primarily for the benefit of general aviation and recreational flying operated from small aerodromes. The ATSOCAS service is provided at no cost to the users of uncontrolled airspace.

“Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity?” 3.31 This question has two basic components ie airspace design and air traYc control management. 3.32 In terms of airspace design, there is a shortage of qualified designers in the market with the primary resource coming from parties that were once employed by DAP when it used to provide an airspace design service. While there is little evidence that this level of approved design supply is causing current problems, but this may change over time. 3.33 Once changes have been approved they have to be implemented and this is where the requirement for air traYc control staV to manage the revised airspace comes into play. As previously stated, there is a critical forecast shortage in the supply of qualified air traYc control oYcers and while automaton and new technologies may address some of this anticipated shortfall there remains a clear need to find means whereby supply can match demand. This will involve additional training resources and initiatives such as making the transition from military to civilian air traYc control more streamlined and less diYcult.

“Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity?” 3.34 AOA believes that the responsibility and funding for the development of a structured programme for the redesign of UK airspace as proposed in the 2003 White Paper should lie squarely with Government. While execution of this process would lie with CAA the costs should not be included in CAA’s charges to airspace users and airports. 3.35 Insofar as funding individual airspace change proposals e.g at airports, AOA considers that it is appropriate for such costs to be the responsibility of the change proposer. In this regard it will be for the proposer to determine and source the funding to progress and implement the airspace changes envisaged. October 2008

Annex 1

AOA AIRPORT MEMBERS BAA Aberdeen Airport Ltd BAA Edinburgh Airport BAA Gatwick Airport BAA Glasgow International Airport BAA Heathrow Airport BAA Plc BAA Scotland BAA Southampton International Airport BAA Stansted Airport Barra Airport Belfast International Airport Benbecula Airport Birmingham International Airport Blackbushe Airport Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Blackpool International Airport Bournemouth Airport Bristol Filton Airport Bristol International Airport Cambridge City Airport CardiV International Airport Ltd Carlisle Airport Chester Hawarden Airport City Airport Manchester City of Derry Airport Coventry Airport Denham Aerodrome Dundee Airport Durham Tees Valley Airport East Midlands Airport -Nottingham, Leicester, Derby Elstree Aerodrome Exeter International Airport Fairoaks Airport George Best Belfast City Airport Glasgow Prestwick International Airport Gloucestershire Airport Guernsey Airport Highlands and Islands Airports Ltd Humberside International Airport Infratil Airports Europe Ltd Inverness Airport Isle of Man Airport Kemble Airport Kent International Airport-Manston Kirkwall Airport Leeds Bradford International Airport Liverpool John Lennon Airport London Ashford Airport (Lydd) London Biggin Hill Airport London City Airport London Farnborough Airport London Heliport London Luton Airport London Southend Airport Manchester Airport Manchester Airports Group plc Newcastle International, Airport Newquay Airport Norwich International Airport Oxford Airport Peel Airports Ltd Redhill Aerodrome Regional Airports Ltd Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Retford (Gamston) Airport Robin Hood Airport Doncaster SheYeld Shoreham Airport Stornoway Airport Sumburgh Airport Sywell Aerodrome TBI Plc Thruxton Airport (Western Air ) Ltd Tiree Airport Warton Aerodrome Wick Airport

Supplementary memorandum from the Airport Operators Association (AOA) (AIR 36A)

REQUEST FOR INQUIRY: OFCOM PROPOSALS TO INTRODUCE SPECTRUM PRICING FOR AVIATION AND SHIPPING The Airport Operators Association is the trade association that represents the UK airports industry. In our submission to your committee’s recent inquiry into the use of airspace we commented on Ofcom’s proposals to introduce Administered Incentive Pricing (AIP) for the use of aeronautical and maritime spectrum. Our members, along with other aviation users, have significant concerns with the proposals being set out by Ofcom. Aviation’s use of spectrum is mandated internationally, under the Chicago Convention (1949). Both ICAO and the World Radio Communications Conference (International Telecommunications Union) have a role in setting internationally agreed spectrum allocations for aeronautical use. Changes in these allocations cannot be imposed or changed by one state acting unilaterally. AIP will introduce a significant new cost to the aviation industry- AOA has found that an airport the size of Birmingham would pay between £800,000 and £1,100,000 per annum. NATS En Route would also have a significant liability. This cost is coming at a time where, as demonstrated by the failure of XL, the industry is under significant financial pressures. Some airports will, given their profitability, be presented by significant costs from AIP. In the case of Humberside these costs would represent almost half of its profits. Inverness airport, which is currently owned by Highlands and Islands Airports Ltd (itself owned by the Scottish Government and operated to provide lifeline services in the north of Scotland), would see its losses increased by a further sixth. This would impose a cost on the taxpayer for little discernable gain, whilst diverting funds currently used for the benefit of those taxpayers. AIP will bring with it potential environmental disbenefits. The money raised from the industry by AIP would be unavailable for investment in technological and operational changes to allow UK aviation to benefit from the changes being made at a European level by SESAR and SESII. In the longer term this will reduce the ability to UK aviation to increase the capacity of controlled airspace, to shorten routes, and to minimise the environmental impact of aviation through more eYcient flight controls. There is also a safety aspect to these proposals. Ofcom has argued that as the use, or carriage, of safety equipment is mandatory for some aircraft and airports it would be impossible for AIP to bring about a detrimental impact on safety. Some parts of the aviation system are not subject to mandatory safety requirements—particularly the general aviation sector. Introducing an elective cost on the use of VHF and navigational aids and some GA flyers will vote with their feet: foregoing VHF systems on their aircraft, and flying from unlicensed aerodromes which aren’t subject the CAA’s rigorous licensing criteria. This could represent a material detriment to safety. A final concern is that Ofcom is eVectively going beyond the recommendations of the Cave Audit, which was accepted by the government as the basis of its policy on spectrum charging. The 2005 Cave Audit of spectrum recommended the application of AIP to “public-sector” spectrum uses in order to establish a market mechanism to encourage the more eYcient use of that spectrum. It was, however, noted that: “If there is judged to be no prospect of alternative use due to international restrictions and since the UK is unable to act unilaterally in spectrum that is internationally harmonised for on-board use, then the opportunity cost of the spectrum for alternative use should be judged to be zero.”(Cave Audit p.56) Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Ofcom has signally failed to demonstrate what spectrum eYciencies it believes the introduction of AIP to aeronautical uses will bring, given the largely international nature of aeronautical spectrum allocations. As proposed, AIP fails to recognise the essentially international nature of aviation spectrum use. Instead it seeks to impose a market mechanism where Professor Cave’s review of spectrum management argued there can be no market. Given the nature, timing, and potential consequences of these proposals for aviation (as well as the maritime sector), AOA believes that is a subject that deserves scrutiny by the Transport Select Committee. December 2008

Supplementary memorandum from the Airport Operators Association (AOA) (AIR 36B) Further to the appearance of representatives from BAA, Birmingham International Airport, London City Airport, Manchester Airport and AOA before the Transport Committee on 1st April, we were asked to submit supplementary evidence on matters relating to Continuous Descent Approaches (CDA) and AOA’s position on the Competition Commission’s views on the competition between airports, specifically in the south east of England in the context of the recommended sales of Gatwick and Stansted Airports. The data on the percentage number of CDAs flown at Heathrow, Gatwick, Birmingham and Manchester is as follows:

Year Heathrow Gatwick Birmingham Manchester 2004 83% 77% "" 2005 82% 78% "" 2006 84% 80% " 74% 2007 83% 80% " 76% 2008 82% 83% 87% 80%

Further analysis of the month by month figures contributing to these annual percentages can be presented if desired. Because of the complexities of the operational approaches at London City Airport no CDA analysis is available. In respect of the recommendations of the Competition Commission, it has to be understood that given AOA’s remit to represent all British Airports, the scope of any position AOA holds is limited strictly to general assumptions about how we see competition in the UK airports market in general. As a rule we do not take positions on questions of ownership of our member airports. Our remit is to make representations on behalf of our members on public policy issues where they hold a common interest. Although the Competition Commission’s recent activity regarding BAA might be considered to have public policy interest, in our case it is clear there is, as I stated to the Committee on 1 April, no common position among our members. However, we do have views on the Competition Commission’s perception of the UK airports market as a whole. We attach great importance to the recognition that UK airports operate in a climate, where they compete with each other, and airports in Europe, for airline routes and passengers. During the framing of the recent EU Airport Charges Directive, AOA invested a great deal of time working with EU opinion formers to explain the uniquely liberal nature of the UK’s market in air transport, which includes the majority of British airports. As a result, airports (and their passengers) have partially avoided a costly Directive that would have brought little benefit. It is extremely important to us that this hard won recognition remains foremost in the minds of those influencing both UK and EU policy in this general area. April 2009 Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Memorandum from the Omega Academic Partnership of UK Universities (AIR 37)

Summary — The Omega42 Partnership is working in several areas to characterise ineYciencies in the air transport system and to oVer knowledge to the sector and Government to enhance performance: air traYc management (ATM) eYciency is included in the scope of work. — Contextual studies are underway on environmental topics that bear upon the management of airspace. These include the possible implications upon future flight patterns from maturing knowledge on contrail and induced cirrus cloudiness, the eVects of more fuel eYcient engine technologies upon ATM through possible slower and lower flight and the eVects of diVerential charging regimes for airspace use upon route mileage. — One particularly relevant Omega study is focussing on ineYciency within the European air traYc management system and assessing how to improve its environmental performance in the future. EVective international integration of advanced aircraft and ground technologies, enhanced airport and airspace capacity and “green” operating procedures are of paramount importance. Even with improved ATM performance, total environmental impacts of aviation are likely to increase due to traYc growth, and hence incorporating aviation into an eVective emissions trading system is an important consideration.

Omega Partnership Work on Aviation Sustainability 1. This submission is oVered by the Omega academic partnership of UK universities. The substance of the document is output from Omega work undertaken by the University of Cambridge examining ineYciencies in the air traYc management system that incur environmental penalties. The Omega partnership, funded by Government, develops and transfers knowledge that can improve the long-term sustainability of the air transport sector. 2. At a time of heightened concern about the climate impacts of aviation, there is a strong imperative to reduce ineYciencies in the ATM system and so save fuel and CO2 emissions. ATM issues have an important role in environmental impact mitigation because they have an impact on all the aircraft within the system. Future ATM designs may be influenced by the development of understanding about impacts and also by environmentally-motivated technology changes. As delivery of ATM improvement solutions is far from speedy, it is appropriate to flag some of the environmental issues that may aVect the functionality of the system over the coming decades. 3. The scientific community continues to examine the climate impacts of aircraft contrails and induced cirrus cloudiness. Current expectations are that it may be up to 10 years before knowledge on this issue is suYciently mature to say whether the eVects require any diVerent technological or operational response. However, there remains the possibility that operational practice in relation to cruise altitudes or flight trajectories might need to be altered to suppress the formation of contrails. That would, in turn, have implications for aircraft design. In such circumstances, there would be major implications for the control and capacity of airspace use. Omega supported work in this area, to review the state of knowledge, is about to be reported. 4. Fuel and CO2 pressures are critical drivers for technologies being considered for future aircraft designs. With the prospect of single aisle replacements for the B737 and A320 aircraft families in about a decade, serious consideration is being given to powering such aircraft with “open rotor” power plants. The significance of this issue for ATM is that aircraft powered by such engines may fly slower and lower. Aside from the acceptability of such technologies to the traveller (and to airport communities given that “open rotor” powered aircraft may be more noisy than shrouded fan engines), there are ATM implications associated with part of the aircraft fleet operating in a diVerent manner and how it would be integrated with a “traditional” jet fleet in ATM terms. Omega is currently examining the projected noise performance associated with this technology, the scope to reduce it to acceptable levels and the trade-oVs between noise and emissions. The study will be reported in December and will feed into developing industry thinking on the viability of “open rotor” engine technology. 5. A further issue currently being examined by the Omega partnership is the environmental penalties linked to diVerential charging for use of airspace in Europe. Anecdotal evidence suggests that significant excess mileage is flown on some routes in Europe in order that airlines can avoid more expensive national

42 Omega is a one-stop-shop providing impartial world-class academic expertise on the environmental issues facing aviation to the wider aviation sector, Government, NGOs and society as a whole. Its aim is independent knowledge transfer work and innovative solutions for a greener aviation future. Omega’s areas of expertise include climate change, local air quality, noise, aircraft systems, aircraft operations, alternative fuels, demand and mitigation policies. Omega draws together world-class research from nine major UK universities. It is led by Manchester Metropolitan University with Cambridge and Cranfield. Other partners are Leeds, Loughborough, Oxford, Reading, SheYeld and Southampton. Launched in 2007, Omega is funded by the Higher Education Funding Council for England (HEFCE). www.omega.mmu.ac.uk Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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airspace charging areas. With a view to informing the European debate on more eYcient use of airspace, Omega is seeking to quantify the excess mileage and associated emissions penalties arising from this practice. Results will be available in early 2009.

Response to Transport Committee Questions 6. This submission primarily addresses the main environmental question posed by the Transport Committee—What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? 7. In an ideal world, all aircraft would fly optimal trajectories between airports, comprising the most direct route (accounting for wind), at their most fuel-eYcient altitude and speed. This would lead to lowest CO2 emissions, as well as reducing most other environmental impacts if designed appropriately. However, real world constraints lead to aircraft flying less eYcient trajectories and hence at greater environmental impact than is ideal. The practicalities of the air traYc management system directly influence the trajectories that aircraft can fly,and hence improvements to the ATM system oVer the potential for better environmental performance of all aircraft within a given region. The often-cited Intergovernmental Panel on Climate Change (IPCC) 1999 report “Aviation and the Global Atmosphere” suggested that improvements in ATM could help to improve overall fuel eYciency by 6–12% per flight. But it is only fairly recently that there has been a concerted eVort to understand where these eYciency gains could be obtained, and what their environmental impacts would be, not only in terms of fuel burn, but also noise and local air quality emissions. For the past two years, the University of Cambridge has been analysing global flight data (and more recently as part of an Omega study with a focus on Europe) to (a) understand ineYciency levels in ATM and verify the accuracy of the IPCC estimate; (b) decompose the overall ineYciency levels into causes in order to better understand how they might be reduced; (c) determine how future ATM systems could be designed to address the causes of ineYciency, and (d) assess the overall environmental impacts of possible ATM evolutions. The current findings in each of these areas are pertinent to the question raised by the Transport Committee, and are summarised briefly below. 8. Overall flight ineYciency levels: there are a number of ways of measuring flight ineYciency (eg excess distance flown beyond the shortest (great circle) distance, extra fuel burn beyond fuel-minimum, etc.). The former, although not ideal, is the simplest form and is currently used by Eurocontrol as their ATM performance metric, so is mostly used here (current on-going analysis is using the superior fuel-based metric, but it is more complex). The University of Cambridge global flight data analysis suggests that overall ineYciencies of 12–14% excess track distance per flight are realistic for flights within Europe and the US. Flights within lower traYc regions such as Australia and Africa generally have smaller excess track distance characteristics of 4–8% (most likely due to lower traYc densities). Flights through some inter-continental regions have similar ineYciency characteristics (eg North Atlantic flights), while others can exhibit much larger ineYciency levels (eg over 20% for some Europe to South East Asia flights which can equate to an additional 1000 nm being flown relative to the shortest route). Given that flights within Europe and the US account for around 50% of flights, the characteristics of these regions dominate the global ineYciency characteristics. Using the simplification that excess flown distance is proportional to excess fuel burn, the IPCC estimate appears somewhat low. Some of this discrepancy may be due to the increase in traYc between the 1990s IPCC estimate and the 2005–08 analysis discussed here and the fact that not all of the extra track distance observed can be directly attributable to ATM, as discussed next. 9. Causes of flight ineYciency: the causes of flight ineYciency can be considered to be any factor that causes an aircraft to fly a trajectory diVerent from its “four-dimensional” optimal (ie latitude/longitude ground track, vertical profile, speed profile). This includes indirect routes and holding/stacking mentioned in the question posed by the Committee, plus many other elements as shown below and discussed further next. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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10. Adverse Enroute weather Airspace Congested airspace Expensive Arrival fix airspace Standard routes & Flight LevelsRestricted airspace Holding & Departure fix Vectoring Destination Arrival Terminal procedures Departure Airspace procedures Origin Terminal Airspace

11. On take oV, ineYciencies can be introduced by the departure procedures that often require aircraft to fly specific paths and profiles for noise abatement and/or traYc separation purposes. Aircraft may also have to leave the origin airport terminal area over specific departure fixes which link with appropriate downstream air routes but which may require non-optimal climb profiles and/or a longer flight path within the terminal area compared to a more direct route. In the enroute airspace, standard (and often sub-optimal) air routes and flight levels are typically used and aircraft often fly around regions of restricted or congested airspace, as well as adverse weather. On approach to the destination airport, aircraft typically enter the terminal area via an arrival fix which may also require non-optimal descent trajectories. If there is airport congestion, aircraft may need to enter holding stacks or be “vectored” (given heading changes to lengthen or shorten their flight tracks) for separation purposes. Finally, the lateral and vertical elements of the arrival procedure will likely be constrained by the need to space, merge and sequence traYc for landing which may force them away from their optimal approach procedure. Our studies indicate that, in the current US ATM system, the biggest contributor to excess flight distance is standard routings, accounting for about 30%. The next biggest contributors are holding/vectoring in the destination terminal area and standard arrival procedures, each accounting for around 20% of extra track distance on average. Congested airspace, adverse weather and standard departure procedures each accounted for about 10% of the extra track distance flown on average. Because the characteristics of the European air transportation system are similar to the US, these relative contributions to excess flight distance can be considered representative of Europe too.

12. Implications for future ATM designs: the findings discussed above give pointers towards appropriate priorities for future ATM designs to reduce flight ineYciency. The biggest contributor was observed to be standard routes and restricted airspace (they are combined due to the fact that standard routes were observed to accommodate many airspace restrictions). This ineYciency could be improved through operating paradigms that allow more widespread use of flight away from the rigid airway structure, as proposed in many “free flight” or user-preferred trajectory concepts (including the Single European Sky ATM Research (SESAR) initiative). There are many studies to assess how this removal of airspace structure aVects the air traYc control process, and this needs to be carefully considered to maintain safety at high levels. But if such concerns can be addressed, these strategies would improve eYciency in both the enroute and oceanic airspace, allowing more direct routes and flight at user-preferred cruise altitudes and speeds which minimise fuel burn. There are also Communication, Navigation and Surveillance (CNS) limitations in enroute and oceanic airspace in many parts of the world. There are moves in the US and Europe to transition away from the legacy system design of VHF radio communication, ground-based navigation and radar surveillance to more sophisticated infrastructures involving datalink communication, satellite-based navigation and aircraft-based automatic dependent surveillance. These technologies should enable ineYciencies in these regions to be reduced to handle the forecast traYc growth, for example by reducing separation minima. TraYc is growing most rapidly in some parts of the world where the current infrastructure is unlikely to be able to accommodate it (eg India and China). However, it is likely that technological advances and global ATM harmonization eVorts will enable step-changes in CNS capability in these regions instead of the slow incremental evolution observed in the more developed regions of the world where growth has been more gradual. The high ineYciency results observed in the Europe to Asia flights highlight the adverse eVect of large areas of restricted airspace which, in long distance flights, can lead to significant extra distance being flown. Increasing the number of available airways with the ultimate goal of wholesale removal of these large restricted areas would therefore be highly beneficial, but this may be a political rather than technical challenge. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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13. The second most important ineYciency source was observed to be arrival holding/stacking and vectoring. Limited airport capacity causing arrival delay is the root cause of this issue. Planned increases in airport capacity are unlikely to keep pace with growth in aircraft movements, and hence it will become increasingly important to manage arrival delay in a more environmentally-friendly way. Future concepts that involve four-dimensional trajectory management, and tailored arrivals in particular, should greatly reduce the need for holding and vectoring within the destination terminal area. It would enable delays to be determined far in advance of an aircraft’s arrival into the terminal area, allowing a more eYcient accommodation of delay. For example, by slowing the cruise speed of an aircraft by a few knots on a long distance flight to manage its arrival into the terminal area at a pre-determined time when it can be accepted without delay is much more eYcient than having aircraft enter the terminal area at an unplanned time, then holding them until a runway slot is available. Elements of four-dimensional trajectory management are already deployed in parts of the US, but major eYciency gains could be achieved by system-wide application, as is proposed in the European SESAR and US NextGen concepts. 14. Standard arrival procedures (excluding holding and vectoring) were the next biggest ineYciency source. The need for alignment of the flight path with the limited set of runway orientation available at any airport and the need to maintain a minimum separation distance between aircraft to ensure safety implies there will always be some excess track distance observed in this phase. However, careful relaxation of constraints (such as reduced stabilization criteria and/or separation minima) imposed on standard arrival procedure design without compromising safety could help to minimize this contributor to ineYciency. The same comments are valid for the standard departure procedures. 15. Congested airspace related ineYciency should also be helped by 4-dimensional trajectory management. However, the relationship between traYc levels (which are likely to continue to increase in the future), airspace capacity and congestion-related ineYciency is highly complex and will need further research. 16. The need to avoid regions of adverse weather is likely to continue into the future to maintain passenger comfort and safety. However, better forecasting and adverse weather detection to allow aVected regions to be avoided more eYciently should be possible in the future. 17. Environmental impacts of ATM: the discussions above illustrate that there is significant scope for ATM advanced technologies and procedures to improve environmental performance of the air transportation system. Future plans for European ATM (eg SESAR) incorporate many of the improvements suggested above which, if implemented in a timely and integrated fashion, should enable per flight reductions in fuel burn and associated emissions due to ATM of up to 10%. Local environmental eVects of air quality and noise would be helped through initiatives during the take-oV and landing stages of flight that allow aircraft to fly closer to their optimal vertical and speed profiles, eg Continuous Climb Departures (CCDs) and Continuous Descent Approaches (CDAs). The objective of a CDA, for example, is to minimise periods of level during the descent and approach phases of flight, thereby keeping aircraft higher and at lower thrust for longer, reducing fuel burn, emissions and noise impacts. Enabling aircraft to do this during the entire descent and approach phases can reduce fuel burn and associated emissions during the descent phase by as much as 50% per flight compared to a standard descent and approach, while peak noise is also reduced by 3-6 dBA per flight in some regions. More radical techniques at reducing noise during the entire approach involve landing further down the runway (currently possible at Frankfurt) and steeper approach angles (currently performed at London City but only possible for some aircraft types), but these would require detailed studies (eg regarding impacts on safety, infrastructure, pilot training, etc.) before they could be deployed more widely. 18. The major challenge in all of these cases will be improving environmental performance in the face of growing traYc demand. Congestion was identified as an important contributor to flight ineYciency in the current system, and its importance is likely to increase in the future without major capacity enhancements. Capacity is needed on the ground and in the air, through added infrastructure (eg runways and airspace), technological investment and procedural changes that allow more eYcient use of the capacity that is available. Even then, the aggregate emissions from aviation are set to increase in the coming decades because traYc growth will exceed the possible eYciency gains (even given aircraft technological improvements). Hence, policy measures such as Emissions Trading Schemes which incorporate aviation in an eVective manner will have a major part to play in managing the environmental impacts of aviation’s activities. 19. A further question posed by the Transport Committee bears upon environmental performance—How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? 20. Whilst the practical eVects are best characterised by ATS providers, it is worth noting that environmental penalties will accrue from failure to achieve full gate to gate co-ordination. The text provided to the question on opportunities for reducing indirect routing and stacking highlights the importance of more eYcient “four-dimensional” management of aircraft trajectories. This can only be achieved through close cooperation between all of the agencies involved in handling a given flight. For example, Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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accommodating an ideal Continuous Descent Approach (CDA) procedure into London Heathrow would require careful coordination with French air traYc managers. To obtain maximum environmental benefit from the CDA, the flight should be cleared for the approach while still at cruising altitude in French airspace, so the flight crew can determine their optimal start of descent point that enables them to descend the whole way at minimum engine power. Achieving this, and other strategies for reducing environmental impact, for ALL aircraft is a major ATM challenge, but one that the industry should aspire to. It requires aligned strategies, infrastructure, technologies and procedures across national boundaries, and the SESAR initiative is tasked with delivering these aspirations within European ATM in the future. October 2008

Memorandum from Elizabeth M Balsom (AIR 38) — More flights into Heathrow airport and the accompanying additional noise will bring a severe deterioration on the quality of life of those of us under the flight path. — We already experience planes coming in at 2000 ft every 82 seconds for half the day, a constant ceiling of sound. Planes all day would be intolerable. — Aircraft noise starts at 4.40am; the last planes go over around 10.45pm-11pm. As I try to sleep, what am I supposed to do? Lie back and think of England? — There is no such thing as a quiet aircraft. Claims to the contrary are nothing but biased spin. The noise is disturbing inside; outside you cannot hear yourself speak. — The amount and intensity of aircraft noise has increased exponentially since I came to Putney in 1981; it is oVensive to assume we don’t notice it. — It is profoundly disquieting that the government is seeking derogation from the EU Air Quality Directive, which will be breached if Heathrow expansion goes ahead. I am very worried about the health implications from more planes and increased road transport to the airport. — There is no way that I, a pensioner with a small fixed annuity can share in the much-vaunted growth in wealth that will allegedly stem from Heathrow expansion. — There is the distinct possibility that more aircraft noise will have a depressing eVect on property prices in aVected areas. — The government’s arguments for expansion, eg “the financial services sector flies six times more than other businesses”, would be laughable if the situation were not so grave. — The consultation exercise has been derisory; no government-organised meetings have been held in aVected areas, no minister has come to justify the degradation to our quality of life; no documents were distributed by the government to aVected households. — When Stephen Byers sanctioned Terminal 5 he accepted the recommendation that air traYc movements should be limited to 480,000 a year, because more would have an unacceptable impact on people over a wide area. How can I trust a government that is reneging on this undertaking?

1. I wish to express my thanks to the Committee for the opportunity to describe what it is like living under the flight path to Heathrow airport. Although proposed expansion of the airport is not among the topics to be investigated, the Committee is examining: “How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck?”

2. Expansion of Heathrow would involve a major intensification in the use of airspace en route to the airport, with significant implications for those of us already aVected by aircraft noise. There are two aspects to Heathrow expansion, the third runway and the abolition of runway alternation which gives residents under the flight path some hours of peace each day. The news that a decision on the third runway has been postponed leaves me profoundly afraid. Heathrow expansionists can achieve their aims in a flash by abolishing alternation, at no cost to themselves, but at irreparable and instant harm to us. The runway will take longer. I have heard local friends in my age bracket say, “perhaps I’ll be dead [by the time the runway is built].” Any government should hang its head in shame if its citizens prefer death to enduring its policies.

3. When Stephen Byers gave the go-ahead for Terminal 5 he accepted an inspector’s recommendation that air traYc movements should be limited to 480,000 a year, because more would have an intolerable impact on people in a wide area of west and south-west London. Now the government is seeking to increase this number by many tens of thousands, perhaps more. This is a complete betrayal of trust. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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4. Because I am writing as a private individual, my account is personal. I quote dates and times when I or a neighbour noted distressing noise in an attempt to convey what it is like; bodies like NATS and the CAA have records of flights, so you will know I am not making it up. I am not alone in the distress aircraft noise causes; about 3,500 signed up for our MP’s campaign against expansion; the number usually sampled in national opinion polls is around 1,200.

The Impact of Aircraft Noise 5. I bought my house in Putney in 1981. For years aircraft noise was simply not an issue; I barely noticed planes. In recent years this has changed. Planes are now a very noisy, constant, intrusive aspect of life here. Had I known how things would deteriorate I would have made a life for myself in a quieter part of London. I often hear this from people who came to Putney, Richmond, Barnes, Chiswick years ago and are now very angry at what has happened to their quality of life. Over the past couple of years four good friends, have left this road, citing aircraft noise as among their reasons for leaving. It is not a case of caveat emptor; the rules of the game have been changed radically, adversely, unfairly. 6. Indeed, we know the government and expansionists do not take adequate account of the detrimental impact of noise: Para 3.35 of the DfT document “Expanding Capacity at Heathrow Airport” states: “Unlike road or rail projects, we do not currently include the impact of noise as an economic factor in our cost-benefit analysis of aviation projects.” Might one be so presumptuous as to ask, why not? The Times reported, 27/11/08: “BAA, the Spanish-owned airport company, plans to increase the number of flights over several years in the hope that those living under the flight path will not notice that noise is spreading throughout the day.” This takes me for a fool, and I find it deeply oVensive. I have news for BAA and the government: we do notice planes overhead at a mere 2000ft; the tailfins are clearly visible. To set this in context, the World Trade Center was 1350ft. We have become accustomed to the expansionists’ spin that the noise environment has improved around Heathrow. It there is one single message that I would like to leave with the committee it is that in Putney, the reverse is the case. There is no such thing as a quiet aircraft. 7. Some examples from 2008: On July 26 a neighbour recorded 175 planes flying over our houses between 15.00–19.00 when he gave up in despair. This is par for the course, and works out at a plane every 82 seconds. Please take a moment to think about this; it is a lot of planes and a lot of noise. As the noise of one aircraft passes into the distance, it merges with the next one approaching. The weekend July5&6waswrecked because there was not one moment free from aircraft noise. Planes were flying overhead from early morning til after 11.15 pm at night. There was no peace. Lunch on Saturday in my neighbours’ garden was ruined because we could not hear ourselves speak as planes continually came in low and loud. The instant one was gone, another heaved into earshot. Incessant noise at these levels is dementing and, because of the stress it induces, damaging to health. Phil Specter created a “wall of sound” in a recording studio; overflying planes create a constant ceiling of sound. June 14 a friend brought her 2 1/2 year old daughter to visit. We went into my garden. To my surprise, the little girl repeatedly pointed skywards saying “noisy aeroplane”; I had not thought a child would be bothered by the noise, yet an infant who is unaware of the debate about Heathrow was clearly upset. 8. Please don’t run away with the idea that once you’re inside you’re protected from the noise. I have double-glazing, but planes are still audible inside my house. They are particularly disturbing at 10.30-11 pm when I would like to go to sleep, and when they come over my house just after 4.30 am. November 19 was particularly bad for there seemed to be no break; it was impossible to get back to sleep. At 7 am the noise was still penetrating. Again I would ask you, please think about this, if the only peace we are allowed is from 11 pm to 4.30 am. What am I supposed to do? Lie back and think of England? 9. Even during the day, and inside the house, constant aircraft noise is upsetting. I know the government, BAA and BA are determined to deprive us of our half day’s freedom from noise, and I find it hard to contemplate this. Some areas of Putney already notice no respite; friends in SW15 1NA complain they are subjected to constant aircraft noise. Indeed, there are days when I have noticed this myself.

Air Pollution 10. In addition to noise, there is the crucial matter of air pollution which is linked to both aircraft and increased road traYc to the airport. The EU is attempting to control aviation pollution, but our government is seeking derogation from the air quality directive. The directive is presumably there to safeguard our health. It is unconscionable that our government should seek to wriggle out of this duty, thereby putting our health Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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at risk. I would be truly grateful if the committee is able to examine this aspect. It is hard to grasp the mindset of a government which will prevent us buying light bulbs by which you can actually see, apparently in the cause of saving the planet, yet has no qualms about a damaging rise in flights over south-west London. 11. In history marauding conquerors mostly reserve such treatment for subjugated peoples, like the Japanese in China and Korea. But some have no compunction at disregarding the welfare and well-being of their own people. I do not think it hysterical or exaggerated to recall Stalin, Pol Pot, Mugabe. I cannot but be concerned about the health implications of breaching the air quality directive. If I were younger or had children, and were looking into a future of many, many years, I would be very worried indeed. Again, please take a moment to think about this. I consider it a complete breakdown of trust in the government.

Balance between Conflicting Interests:Financial,Economic and Health Implications

12. I am a pensioner with a small fixed annuity; by definition my income cannot rise. The DfT’s consultation document claims that planes over our heads all day are absolutely necessary to generate “net economic benefits of around £5 billion in net present value terms” (summary consultation document, para. 1.8) This raises a number of questions. How do the government and Heathrow expansionists plan that this wealth will filter down to me, given my restricted income prospects? (Chanting the mantra “schools and hospitals” just raises a hollow laugh, by the way.) 13. How do they propose to compensate me for the degradation to my quality of life that will result from non-stop aircraft noise? I would very much like an answer, given that I have all of the pain and none of the gain. The Times, 27/11/08, reported Willie Walsh as saying all he heard as the planes fly over is the sound of cash tills ringing. I hear an intolerable racket, and to express such sentiments is a cavalier disregard for my quality of life. 14. And when all’s said and done, the net £5 billion quoted in the DfT consultation document is pretty small beer, barely more than a couple of years’ profits from the likes of boring old Unilever. Hardly worth sacrificing the quality of life of hundreds of thousands of people. (The 2M group of local councils represents twenty-one councils, over four million people.) 15. Table 16 on page 176 of the DfT document shows no Wandsworth residents working at Heathrow. So this borough gets the hardship of aircraft noise, but no employment benefits from the airport. 16. The deleterious impact on property prices of more intensive use of the airspace above us is a major worry. An article based on conversations with leading estate agents by Elaine Moore in the FT, 1/11/08, confirms my fears. She examines factors influencing property prices and writes: “unappealing new features, such as airport developments can knock thousands from a property’s value.” A neighbour told how when she was selling her house in Barnes, prospective buyers fled when, as they came up the garden path, planes flew over. They did not bother to look inside. I would be interested to know how the Heathrow expansionists propose to compensate us for loss in value. Will the government compel them to do so, or will its attitude be:” Tough. Put up and shut up?” 17. I do wonder at the intellectual calibre of the people who have penned the expansion document. Given the turmoil in the financial markets which has brought our economy to the brink of disaster, and which was precipitated by the recklessness of sector participants, one might query the DfT’s contention that Heathrow should be expanded because “the financial services sector uses six times more air travel than other businesses” (Summary Consultation Document, para 1.1) If only these people had stayed home we might all be a damn sight better oV. I struggle to understand the DfT’s thinking, as exemplified by this quote from the DfT website. “The Department is conducting an Equalities Impact Assessment (EqIA) to broaden its understanding of the potential impacts of Heathrow’s development on individuals living within the 57dBA Leq noise contour, in terms of race, gender, disability, age and social deprivation. This EqIA is what the Department is now consulting on.” What on earth have these factors to do with noise hitting your eardrums from 2000ft? Noise is noise, whatever the colour of your skin. Some of my friends who most resent the destruction of our quality of life are men. Fancy that! But my quality of life may be determined by people who come up with this sort of nonsense. It leaves me very afraid. (My spellcheck oVers “daft” for DfT.) 18. Stephen Byers’ acceptance of the inspector’s recommendation of an annual limit of 480,000 flights into Heathrow, in theory, balanced the interests of residents and those of the aviation industry. How can I trust a government that is now grossly recalculating this balance in favour of the aviation industry to the detriment of those of us under the flight path? Despite the noise science spinning of the government and aviation industry, planes are every bit as noisy as when Byers set that limit. 19. This year I have visited friends in Bath, Leamington Spa, Liverpool, Plymouth and Worthing. As I sat in their houses I was always thinking: no noise. Why must I be penalised for a decision I made 27 years ago when Heathrow was not the blight on the environment it now is? Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Consulting those Affected

20. The Committee is asking who should be consulted about changes in the use of airspace. Over the past year, during the so-called period of consultation on the expansion of Heathrow, my impression has been that the government has been determined not to consult those most aVected. In my view everyone who is currently aVected by aircraft noise, plus those who might be aVected in future, should have been oVered detailed explanations of what lies ahead, for instance, the opportunity to attend presentations by NATS. The channels for objections should have been very clear. Some of the arguments in the consultation document, when not totally fatuous, are couched in technical jargon, impenetrable acronyms and illegible maps that render them totally inaccessible to most ordinary people; the spinners’ aim is to blind us with science. We should have had the opportunity to seek face-to-face clarification.

21. Putney is blighted by aircraft noise, but the Government organized no meetings here. Not one Government minister has been here to justify to us depriving us of half a day’s respite from aircraft noise as they plan to do, nor to justify seeking derogation from the EU air quality directive, which cannot but have harmful implications for us. No consultation documents, long or short, were distributed here by the government; interested residents had to request the document themselves. A DfT exhibition was held at the Wetlands Centre in Barnes, but this is awkward to teach by public transport and I do not have a car. Again, this was not publicised in Putney, but a councillor friend took me. This is where I obtained my copy of the consultation document.

22. Were it not for the eVorts of Wandsworth Council, the activities of pressure groups like Greenpeace and HACAN, I would be unaware that a “consultation exercise” had been taking place. Indeed, my impression is that our government is determined that we should not know what lies ahead.

23. Earlier this year I attended a meeting in Wandsworth Town Hall organised by the council. A woman in the audience said she had attended a meeting with Jim Fitzpatrick led by her MP (Battersea). She reported that the minister had discussed the merits of various earplugs. This is the level of government interest in our plight.

24. When Heathrow expansion has been raised at PMQs the incumbent’s response has been arrogantly indiVerent. At a PMQs session in spring 2004 Jenny Tonge, then MP for neighbouring Richmond Park, asked a question about the noise which those of us under the flight path in southwest London endure. Blair’s arrogant, dismissive demeanour encapsulated the government’s attitude to us. The question had been put calmly, unconfrontationally, yet she, and thus all of us under the flight path, was tossed haughtily aside. I cannot recall the date, but it sticks in my mind. 12 November 2008 an Ealing MP asked a question about Heathrow expansion. The prime minister arrogantly dismissed him. When I watch these exchanges, the thought cui bono? runs through my mind, together with the realisation, it’s certainly not me. The decision has been taken and the “consultation” exercise was a farce.

25. Companies like BAA and BA have easy access to the media, where they argue for Heathrow expansion; likewise bodies funded by the aviation industry like Future Heathrow. It is unfortunate for us that they do not tell the whole truth. For instance, last September Future Heathrow took a full-page advert in the Financial Times saying “Frankfurt’s got three runways, so we want three”. In making this argument Future Heathrow never gives details of the number of people under the runways to so-called competitor airports compared with those under the flight path to Heathrow, located at the west of one of the world’s most densely populated conurbations. Heathrow is quite simply in the wrong place.

26. The government and Heathrow expansionists are riding roughshod over us. I find it cruelly ironic that it was in Putney that 360 years ago the soldiers of the New Model Army declared: “the poorest he that is in England hath a life to live, as the greatest he.” Not if you object to your quality of life being destroyed by aircraft noise. Our only saviour is the East Wind. December 2008

Memorandum from EUROCONTROL (AIR 39)

In response to the call for written evidence launched by the UK House of Commons Transport Committee, please find below the EUROCONTROL’s responses regarding your inquiry into the use of airspace. All the views expressed below are coordinated within the EUROCONTROL Agency and are based on the latest status of development of our activities. Our responses are in italics below your questions. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

Ev 226 Transport Committee: Evidence

1. What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented? Additional airport capacity would mean a necessary associated increase in airspace capacity in order to handle the increase in traYc into/out of the airports at the same time. Depending on whether this is to an increased capacity at an existing airport (eg by additional runways), to an airport that is currently underused or to an all-new airport, the need for additional feeder and departure routes emerges. It also means that the required dimensions of the supporting airspace need to be increased. With the London Terminal Airspace (TMA) currently already on the edge of its capacity limits, and given its close proximity to the airspace of the Netherlands, Belgium and France, this could not be accommodated without more advanced interfaces to the ATC facilities supporting those airspaces or, preferably, a common, integrated airspace design between London TMA and adjacent airspace. The application of advanced navigation capabilities will be a must as this will enable a better airspace design to respond to safety, capacity, environmental and flight eYciency challenges. This would require a closer integration of the UK ATC system with the adjacent systems. A change of how the airspace is managed would therefore, for the London area, seem to make sense.

2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for air traYc control? The interface between civil and military control is, in the case of the UK and for those areas in the UK that are positively controlled (all aircraft receive mandatory ATC, irrespective of the flight rules under which they operate), already optimal. The requirement to handle more traYc into the London area with the same or better safety levels will, however, require a fresh look at the sustainability of the amount of uncontrolled airspace just Northeast of London below FL 245 (% 24.500 ft altitude). Any airspace changes of this size will be supported by a Safety case whereby the demonstration of maintenance or improvement of safety levels will be required. UK has long experience in implementing Safety Management System in Air TraYc Management (eg UK NATS is actively engaged in EUROCONTROL Safety Team since its inception 10 years ago). Therefore it is expected that a robust safety case will be put forward covering the complete lifecycle of the airspace change, prior, during and past implementation. In addition, the implementation of advanced navigation applications and capabilities will play a major role in maintaining and enhancing the current safety levels.

3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently? Whereas the current approach to the planning and regulation of the UK airspace will certainly be adequate, it should be understood that the interface with the adjacent, non-UK airspace will become increasingly important. Currently there are no formal planning and/or regulatory mechanisms to cover that, except those as contained in the European Commissions (EC) Single European Sky (SES) regulations and those contained in the European airspace planning process as executed by EUROCONTROL. The UK observer status in the development of the Functional Airspace Block Europe Central (FAB EC), covering Benelux, France, Switzerland and Germany, does not seem to be a suYcient measure to overcome this. An Airspace Master Plan covering the period of the White Paper and drafted in consultation with and commitment of the FAB EC States seems a bare minimum. A European network approach to the airspace design will for sure overcome the inadequacies of a piecemeal approach and will avoid the necessity to redesign airspace at a later stage. The European airspace planning process as executed by EUROCONTROL is well placed to support such an approach.

4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? Although higher traYc loads in and out of airports will undoubtedly increase noise and emission levels, a number of steps can be taken to mitigate against, or at least reduce, the negative impact, such as: — Steeper, improved and unrestricted climb-out procedures; — Steeper, improved continuous descent profiles into airports; — Holdings (if necessary) at higher, more optimum altitudes; and — Financial incentives for encouraging the use of more environmental-friendly aircraft; disincentives for less environmental-friendly aircraft. Who should be consulted and how a proper balance should be achieved between conflicting interests is not an Air TraYc Management (ATM) issue but rather one of political consideration. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? The design, planning and management of airspace in Europe needs to be moving towards an increased level of (international) integration. This is particularly pressing for the very dense airspace of Northwest Europe (area Manchester-London-Paris-Zurich-Frankfurt-Amsterdam-Manchester) where arrival and departure procedures are by nature cross-border and where rigid State borders and issues of national sovereignty are no longer conducive to facilitating optimum flight profiles. It is for that very reason that the EC has insisted on the creation of FABs, although the EC view appears to be even more ambitious than what is currently achieved by eg FAB EC (see pt 3 above). An integrated design, planning and management of airspace for Northwest Europe is considered a firm prerequisite for future cost-eYcient and environmental-friendly aviation growth.

6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? The application of “User Preferred Trajectories” (or direct routes) is clearly a requirement by the airline industry and it has the potential to bring tangible benefits for the en-route part of the flight. Such initiatives are emerging in the European airspace, including the United Kingdom Positive eVects can be also expected from a better metering long-range sequencing of arriving traYc into TMAs and airports, with early speed adaptations to avoid “stacking”. Although current avionic capabilities on board modern aircraft certainly have the capability to adjust speed to a certain extent to meet the so-called “Required Time of Arrival” (RTA) over a geographical point, the scope for this should also not be over-estimated, as the speed range of an aircraft at cruising altitude is very limited (around 20 kts (nautical miles per hour) either way). A speed reduction of 20 kts at cruising altitude for a total flight-time of 75 minutes results in no more than 2 minutes delay. The ability to reduce or increase speed of an aircraft significantly increases at lower altitudes; yet this is highly undesirable as the fuel and emission penalty would be disproportional. The solution would therefore be an increased and improved linkage between the planning of a flight’s departure slot (eg at Frankfurt) and its arrival slot (eg at Heathrow), with improved sequencing tools in the ATC systems in the TMA.

7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play? The roles and responsibilities with respect to the redesign of the UK airspace are clear and well understood. However, as stated above (see pt 5 above), airspace planning, design and management and the pre-requisite processes can currently hardly be considered as a national, sovereign responsibility anymore and really needs to be addressed in a pan-European context, perhaps facilitated by a suitable entity such as EUROCONTROL, with full participation and commitment of national bodies.

8. Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? Until now, airspace design and ASM have not impeded airport developments, as the latter appears to be more political sensitive and time consuming. However, it is certainly true that with dynamic and ambitious airport development plans in place, airspace design and ASM could, due to its cross-border dimension, become a more constraining factor than today.

9. What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined? Higher demand for access into and out of large(r) airports certainly mean the requirement for more enlarged areas of fully controlled airspace. This is certainly true for the airspace below 24.500 ft altitude to the Northeast of London (see pt 2 above). However, by adopting the requirement for enhanced departure and arrival profiles (see pt 4 above), the impact on the lower airspace (certainly below 10.000 ft altitude) in the proximity of these large(r) airports could be minimized for the operation of low-level recreational aircraft and helicopter traYc. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? Whereas it would certainly be possible to recruit and train such staV, another possibility is to make use of pan-European expertise which already exists.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? Airspace design is considered to be an element of ATM, together with ATC provision and Air TraYc Flow Management ATFM, which cost is or can be fully covered through the mechanism of charging the airspace users for the ATM services through the EUROCONTROL Central Route Charges OYce (CRCO) in Brussels. Should you have any questions or comments on the responses above please do not hesitate to contact me. I am also available, if requested, to support with my presence the debates you may have during your inquiry. Please accept Sir, the assurances of my highest consideration. February 2009

Memorandum from British Microlight Aircraft Association (AIR 40)

1. What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented? 1.1 No comment.

2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for air traYc control? 2.1 No comment.

3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently? 3.1 With the concept of the Single European Sky and the desire of Government to increase air traYcto facilitate commercial interests it is unthinkable that the basic layout of the UK airspace plan would not be under consideration. If there has been no coordinated study to date it should form the backbone of any proposed airspace development. Adding airspace as-and-when will result in conflict of interest and a haphazard outcome.

4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? 4.1 No comment.

5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? 5.1 See our comment at 3.1 above. The UK airspace system and traYc flow must be integrated with the rest of Europe to achieve standardisation which will result in a higher level of safety, and cooperation which will achieve a higher level of eYciency.

6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? 6.1 No comment. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play? 7.1 The role of non commercial General Aviation should be considered when airspace is designed. Civil aviation is not all commercial aviation. There are many more private aircraft being flown by many more private pilots than there are commercial aircraft. Whilst the scale of commercial operations is understood, and important, there must always be a consideration for non commercial activities which fly as a right and not just as a result of a charitable gesture from commercial operators.

8. Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? 8.1 No comment.

9. What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined? 9.1.1 Referring to the answer given in 7.1 above it must be remembered that the number of non commercial aircraft is greater than commercial and these are flown by a great deal more people than fly commercial operations. There has been a frantic desire among commercial operators to expand their capacities to have a larger share of a, prior to now, growing market. Although a commercial airport on the doorstep of every citizen of the UK may be the dream of some it is an unsustainable and unrealistic dream. There is a limit to the number of passenger seats available in the air at any one time and at some point expansion must cease as capacity is reached. In my opinion this point came during, if not before, 2008. Continuing to attempt to expand commercial air transport for the wealth of a few against the tide of economic downturn and supposed attempts to reduce the aVect of aviation on the environment is folly. Planning airspace should now concentrate on eYcient use of that available by using shorter track miles, better coordination of flights to avoid stacking and requiring aircraft to be flown at high capacities rather than half full to maintain a timetable. Recreational aviation has enough space now but commercial activity expansion for the sake of financial gain cannot be allowed to reduce that capacity.

10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? 10.1.1 No comment.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? 11.1 Airspace changes should always be funded by those who benefit. This will usually be the commercial carriers and users of the airports that require the airspace and the airspace controllers, usually NATS. These airspace changes which benefit the user must be funded by the user. They can always pass the costs on to the customer in the form of increased fare and freight charges. February 2009

Memorandum from the General Aviation Safety Council (GASCo) (AIR 41) In response to your request for a submission we would like to make it clear that GASCo’s objectives are to improve safety in general aviation in the UK and our response only covers this area. You ask about the eVect on smaller airfields, recreational flying and changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports. Very briefly: — Expansion of regulated airspace would generally lead to a narrowing of corridors freely available for general aviation use and to the worsening of “choke points”. This increases the risk of mid-air collision and of airspace infringements. The problem is worst around large conurbations. — Expansion of existing airports or development of new ones should only be permitted when there are no other airports within reasonable reach. — Proposals to set up “Mandatory Transponder Zones” around regulated airspace are impossible for aircraft ranging from vintage types such as the Tiger Moth to microlights and gliders. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

Ev 230 Transport Committee: Evidence

— Furthermore any expansion of such airspace could result in forcing general aviation aircraft to fly round such areas taking them over built up areas, high ground, over water or close to wind farms. This is highly undesirable. — Under some circumstances general aviation aircraft can be cleared by air traYc control to route through regulated airspace but this is dependent upon controller workload. Any proposed expansion must ensure staYng levels able to handle general aviation traYc. — The Inquiry should bear in mind that most airline pilots have started their flying careers and /or gained experience through general aviation flying and the recent successful Hudson River ditching may in part owe it’s outcome to the pilots gliding background. We hope this is of help to the Inquiry. February 2009

Memorandum from Airbus UK (AIR 42)

1. Introduction 1.1 Airbus welcomes this opportunity to contribute its views as part of the Transport Select Committee’s inquiry into “The use of airspace”. Airbus in the UK is a subsidiary of Airbus SAS and owned by EADS NV, a global leader in aerospace, defence and related sectors. Airbus is a global company with major design and manufacturing facilities in France, Germany, the UK and Spain as well as subsidiaries in the US, China and Japan. 1.2 Over the past three decades Airbus has developed into a European success story, securing market parity with Boeing in a market previously dominated by US companies. Airbus delivered 483 jetliners in 2008, surpassing its previous year’s total by 30, and achieving the highest ever on-time rate and quality level. As of 31 December 2008, Airbus has delivered a total of 5,500 aircraft and has total sales of more than 9,200. 1.3 Airbus’ strong sales and continuing growth mean that we have a significant interest in preventing the saturation of the skies above the UK. A clear plan to improve the current Air TraYc Management (ATM) system will allow airline capacity to meet continued growth in passenger and cargo demand. Airbus’ mission is to meet the needs of airlines and operators by producing the most modern and comprehensive aircraft family on the market, complemented by the highest standard of product support. 1.4 This submission sets out Airbus’ views on the Use of Airspace and provides responses to some of the specific questions posed by the Committee. The submission primarily addresses the technological advances in ATM, and the environmental, safety, and air traYc benefits that these will bring.

2. Airbus and the Environment 2.1 Airbus places its environmental responsibilities at the forefront of its considerations when planning future developments. As part of our commitment to reducing the environmental impact of our manufacturing and operating aircraft Airbus is committed to a number of initiatives. 2.2 Airbus invests up to ƒ500 million per year so that all new Airbus aircraft types entering the market from 2020 onwards will be designed to produce 50% less CO2, 80% less NOx and 50% less than comparable aircraft designed and operated in 2000. 2.3 Specific ambitious targets have been set to reduce the environmental impact of Airbus manufacturing activities. With 2006 as a baseline, the objectives for 2020 are to reduce: — Energy consumption by 30%. — CO2 emissions by 50%. — Water consumption by 50%. — Water discharge by 80%. — Waste production by 50%. 2.4 In January 2007, Airbus became the first aerospace company in the world to receive the international ISO 14001 certification for environmental management systems covering its 16 manufacturing sites and head oYce in Toulouse, as well as all products throughout their lifecycle. 2.5 Airbus is involved in the Atlantic Interoperability Initiative to Reduce Emissions (AIRE), ASPIRE (Airservices Australia and the Asia and South Pacific Initiative to Reduce Emissions) and INSPIRE (Indian Ocean Initiative to Reduce Emissions Group). AIRE’s role is to make it possible to speed up the application of existing technologies and new operational procedures which will have a direct impact in the short and medium term on greenhouse gas emissions. AIRE will be based on “gate to gate” test campaigns and experiments, which will assess the new measures’ environmental benefits and their operational and technical feasibility. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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3. Airbus and Air Traffic Management 3.1 Airbus has no significant business interests in ATM technology itself. However, allowing the sustainable growth of air transport is clearly relevant for the aircraft manufacturing industry. 3.2 Boeing and Airbus signed an agreement to work together at the third Aviation and Environmental Summit in Geneva in April 2008, to ensure global inter-operability in Air TraYc Management as part of an eVort to help reduce the impact of aviation on the environment. This joint initiative to help the aviation sector and governments choose the most direct path to a modernised air traYc management system is part of a three-pronged approach to help improve the environmental performance of aviation. 3.3 Airbus is using its expertise as an industrial architect in the Single European Sky ATM Research (SESAR) programme. Boeing is using its expertise in the equivalent programme in the USA, the Next Generation Air Transportation System (NextGen) programme. NextGen and SESAR work in co- ordination with each other, sharing developments and advances in order to reach the common goal—an eYcient integrated global ATM network. 3.4 The SESAR programme is a European public-private partnership involving 29 partners working to develop a modernised ATM for Europe. In order to support the growth of air traYc whilst reducing the environmental impact of each flight by 2020, SESAR’s targets are: —SuYcient planning for a threefold increase in airspace capacity in Europe. — Air traYc safety improved by a factor of 10. — The environmental impact of each flight reduced by 10%. — The cost of ATM halved. 3.5 The SESAR programme has now completed its Definition Phase producing an ATM Master Plan. The SESAR Joint Undertaking (SJU), involving the EC, Eurocontrol, and 15 industry members has been set up in order to implement the Development Phase of SESAR. Specific aims of the SJU are to save, on average, per flight: — 8 to 14 minutes. — 300 to 500 kg of fuel. — 945 to 1575 kg of CO2. 3.6 Airbus, with support from other divisions of EADS, including EADS Defense and Security, and EADS Astrium, is responsible for the industrial support function of SJU. This will ensure the technical coherence of the SJU work programme executed by the members. The Industrial Support function involves providing expertise in industrial methods and tools to all participants to ensure the proper integration of all programme results into the new global ATM system. 3.7 Airbus will also be a major contributor to the operational work packages supporting the Operational Requirements and Interoperability Standards development activities within SESAR. Airbus leads SESAR’s aircraft system work package. The Research and Development activities focus on the evolution of ATM capabilities of the aircraft platform.

Responses to Specific Questions

4 Q2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for air traYc control? 4.1 In the frame of an integrated performance-based approach, safety can be maintained as airspace is increasingly utilised. One of the major stated goals of SESAR is a threefold increase in airspace by 2020 whilst increasing safety by a factor of ten. The main constraint to airspace capacity is controller workload. To address this issue SESAR has indentified several areas which can be improved. SESAR targets improvements that will lead to a significant reduction in the need for tactical intervention by an air traYc controller by: — Reducing the number of potential conflicts of flightpaths using a range of methods. — Possibly redistributing some tactical interventions to the pilots. This will be enabled by the future Communications, Navigation and Surveillance (CNS) systems and ATM applications installed on the aircraft (eg ASAS (see Q.6 below). It is part of the SJU mission to develop those tools and verify that the capacity and safety balance is met. 4.2 The SESAR project believes that optimising military and civilian ATM activities is essential. The SESAR Definition Phase involved military organisations in the establishment of the new ATM concept. The SJU has established a dedicated plan for civil-military coordination to ensure continued integration and co- operation. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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5 Q3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently? 5.1 Airspace optimisation should go hand in hand with the renewal of the ATM system to overcome current fragmentation. SESAR final targets can only be reached when the institutional and regulatory measures are deployed. Anything less than a planned long-term integration risks a continuation of the current fragmentation and associated ineYciencies. In this respect, Airbus fully supports the implementation of the four Single European Sky (SES) II regulations, in particular: — “The SESAR (Single European Sky ATM Research) programme should help in the development of future technology.” 5.2 Developments in the ATM system should be taken with a clear focus on global interoperability. To achieve this, these developments should proceed as part of a co-ordinated evolution, designed from the outset with a view to achieving an ultimate goal of integration. Any single development should have the primary goal of improving a higher-level, unified ATM network / system.

6 Q4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? 6.1 The role of ATM is to enable airspace users to fly their preferred trajectory. This trajectory is typically a trade oV between the economic, network, and environmental concerns, and as such will contribute to the reduction of the fuel consumption to the maximum extent possible in a given context. An eYcient and optimised ATM system will ensure minimum aircraft waiting time (stacking) near airports and as such will not only reduce local air and noise pollution but also total flight time and consequently overall flight emissions. Locally (at airports), the discussion should involve airspace users together with the airport operator and the surrounding community representatives and groups to find the right balance between eYcient aircraft movement and noise. Some examples are “Green approaches” such as CDA (see Q.6), and reduction of holding patterns and taxi time.

7 Q5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? 7.1 As discussed previously, since air traYc is a global activity it is important that developments and management of the European ATM systems be planned in a global context.

8 Q6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? 8.1 Airbus’ key ATM targets compliment Airbus’ activities for SESAR. Airbus’s ATM vision is set out in the following three targets: — More precise aircraft navigation to give the ability to fly more eYcient routes. More eYcient routing means that aircraft performance can be optimised during a given flight, resulting in lower fuel consumption and gaseous emissions. — More autonomous aircraft to increase flexibility and further reduce risks. More autonomous aircraft will be able to operate more independently of ground infrastructures in lower equipped airspaces and airports, and with increasing situation awareness in dense traYc areas and bad weather conditions. — More communicative aircraft that will have an improved ability to transmit data not only from individual aircraft to ground stations, but also inter-aircraft. The more communicative aircraft will also transmit a larger range of information in order to facilitate the improved ATM system. 8.4 To meet the SESAR and Airbus’ co-ordinated ATM vision Airbus is engaged in trials of various concepts and technologies. Airbus operators will be able to take full advantage of new technologies through the enhanced Communications, Navigation and Surveillance (CNS) capabilities that will be introduced onboard Airbus aircraft in the coming years. Several of technologies/concepts are set out below, including some that are already being used on in-service aircraft: — Low Required Navigation Performance (RNP). RNP is a standard that defines the accuracy of the measured location of the aircraft. A low RNP means that the aircraft will fly with high accuracy along the desired flightpath. A RNP value of 0.1 for example means that an aircraft must fly within Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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0.1 nautical miles of the centreline of the flight path, with a 95% probability of that accuracy. The increased accuracy of a low RNP means that aircraft, terrain and obstacle separation distance can be reduced, hence increasing air capacity. — Continuous Descent Approach / Tailored Arrivals. Continuous Descent Approach involves calculating the optimal aircraft approach to an airfield. Calculating this approach allows a continuous steady descent with engines at idle, hence reducing fuel burn, gaseous emissions, and noise pollution. Airbus A380s have been used in the ASPIRE and INSPIRE programmes testing this very concept. The trials have been a great success, saving hundreds of tonnes of fuel and carbon dioxide emissions. Closer to home, Airbus A330s and A340s have been used as part of AIRE transatlantic trials of similar techniques, which again produced very positive results. — Airborne Separation Assistance Systems (ASAS). Technologies such as the ADS-B (Automatic Dependent Surveillance—Broadcast) surveillance tool are already being deployed across new aircraft. Currently most surveillance data is sent only between an individual aircraft and the ground stations. With ADS-B the aircraft related data is sent to whoever is equipped to receive it, ie other aircraft. This can provide a quicker and more accurate display of traYc information to each aircraft. It can also be used in areas with low or no radar coverage, significantly increasing the safety of flying in those areas. Most new Airbus aircraft are fitted with ADS-B capabilities, with the possibility of an easy upgrade to all older Airbus aircraft. The Airbus ADS-B system has been designed to work along with the corresponding ground station systems, such as AURORA (http:// www.adacel.com/press/whitepapers/Aurora White Paper 07.pdf). Trials of the technology are being conducted within Europe as part of the Eurocontrol Cascade programme. (http:// www.eurocontrol.int/cascade/public/subsite homepage/homepage.html). The first operational approvals for ADS-B in a non-radar environment are expected by late 2009. — On Board Airport Navigation System (OANS). An OANS system is a highly useful tool for the crew of an aircraft. It includes, among other features, an airport moving map with aircraft overlay. This provides the crew with improved situational awareness on the airport surface, and so will cut down on time spent on runways and taxiways especially in poor visibility conditions. The OANS also gives prompts for the next course of action, ie braking selection or Air TraYc Control (ATC) path. OANS is already a feature of the A380 and has been in service since October 2007. Airbus is continuously working on ways to utilise fully the potential of OANS. OANS has been designed in such a way that upgrades can easily be added to the system as and when the new capabilities achieve certification. — Brake to Vacate (BTV). BTV is a system that allows pilots to select the appropriate runway exit while the aircraft is making its landing approach. When the aircraft touches down the system regulates deceleration, enabling the aircraft to reach any chosen exit at the correct speed under the optimum conditions—no matter what the weather and visibility. Ensuring aircraft are at the correct speed at the runway exit enables less time to be spent on the runway, thereby making more eYcient use of the runway and allowing for higher levels of traYc. BTV will go into service on the first Air France A380, due to be delivered in early 2009. — On Board Information System. Onboard Information Systems (OIS) entered into service with the Airbus A380 aircraft. Among other information, the OIS provides the crew with performance calculations, electronic navigation charts and maps, and electronic operational documentation for the aircraft, such as flight crew operating manuals. Improving the flexibility, clarity and interactivity of the OIS will allow crew to use the new technologies with ease, as well as reducing the time spent selecting existing functions. 8.4 Developments in CNS technologies and techniques will result in greater flightpath predictability for less conflicting / more direct routings. This will reduce stacking and in turn result in reduced fuel burn, gaseous emissions, and noise pollution. February 2009

Memorandum from the British Parachute Association (BPA) (AIR 43)

INCORPORATION OF SPORT PARACHUTING ACTIVITY WITHIN UK CONTROLLED AIRSPACE.

Background Sport Parachuting in the UK is a large, well organised sector of the recreational aviation spectrum. The British Parachute Association (BPA) has been in existence for nearly 50 years and its member clubs now perform in the region of 250,000 parachute descents every year which includes an average of over 30,000 participants each year. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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The UK is a particularly busy parachuting nation. It is the most active of the European nations. This is illustrated by the fact that, apart from France and Germany (which are also very active), the UK performs more jumps annually than all the rest of the EU nations put together. It is now very strong in international competition and holds current world championships in several parachuting events. The organisational structure of parachuting has changed considerably over the past few decades. Thirty years ago there were over forty parachute clubs in the UK. There are currently only 22, though these fewer number of clubs perform much more parachuting than previously. The main reason for the decline in club numbers is the diYculty which is now encountered in obtaining planning permission for locations at which to conduct parachuting. Very few new sites get planning permission. This means that existing sites must be regarded as immovable and when the locations come into conflict with the developing resource requirements of other agencies (eg NATS requirements for controlled airspace) then every eVort must be made to incorporate parachuting activity within those developments.

Regulatory Structure

Sport parachuting is regulated in the UK by the BPA under the terms of an Approval issued by the CAA. The BPA therefore conducts the day to day regulation of parachuting but this process is overseen and audited by the CAA. Although it is possible, under CAA provisions, for a parachuting operation to be set up independently of the BPA, it would prove to be a diYcult process. For this reason there are currently no independent organisations, so the BPA eVectively controls all civilian and military sport parachuting. Several BPA clubs currently operate within controlled airspace. These operations are usually conducted under the terms of a letter of agreement between a specific club and the relevant Air TraYc Service Unit (ATSU). The agreement will detail the precise way in which parachute operations will be conducted in that particular sector of controlled airspace and the terms under which the ATSU will provide a service to the club.

Current Situation

The decline in the number of locations at which parachuting can be conducted has resulted in a trend towards the acquisition of larger and faster climbing aeroplanes in order to cope with the increasing demand for the activity. This has provided a beneficial environmental spin oV, insofar as the trend has been away from a large number of small piston engined aircraft towards a smaller number of turbine engined aircraft. In terms of ATC management this is also advantageous. The larger turbine aircraft are faster and service a set number of parachute jumps with fewer number of flights than their smaller piston engined predecessors. This makes it easier for ATC to incorporate a parachute operation within its routine activity. The amount of airspace which parachuting activity takes up within the UK is also tiny. Each notified drop zone occupies a circle with a radius of 1.5 nautical miles and a maximum altitude of Flight Level 130. It is not permitted for parachute descents to take place outside of this area. Although the aircraft performing parachute drops will often fly outside of this area in the course of their ascents and descents, they do not need to move far from the area and can easily be directed to conform with immediate air traYc control requirements.

Future Requirements

It is clear that the need for controlled airspace is increasing and will continue to do so and that this increase will necessarily be at the expense of the finite area of uncontrolled airspace within the UK. This will inevitably mean that parachuting drop zones will become increasingly located within areas of controlled airspace. It is obvious that parachuting activity close to a major airport would not be desirable and this is reflected by the fact that drop zones do not exist close to them. They do, however, exist in wider areas of controlled airspace and have done so successfully for many years. Future airspace planning policy should therefore incorporate provision to enable parachuting activity to be conducted within controlled airspace. There is perhaps a tendency for parachuting to be regarded as a nuisance factor within enroute air traYc control systems. This is simply a reflection of the fact that recreational aviation generally has come to be regarded as expendable when set against the sacred totem of commercial air transport. The only rationale behind this is that commercial air transport is a bigger industry. This does not, however, make it any more worthy and we believe that airspace planning policy should make provision for parachuting operations to be catered for within any airspace expansion plans. The BPA wishes to ensure that it is closely involved with any planning procedures that are likely to aVect its continued activity and would welcome assurances that it will be involved in this way. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Summary 1. Sport parachuting is well organised and thriving within the UK. 2. Some clubs currently operate successfully within controlled airspace. 3. Parachuting locations are few and planning restrictions make them immovable. 4. The total airspace required by parachuting activity is tiny and manageable. 5. Future airspace planning should therefore incorporate parachuting activity if necessary. 6. Parachuting should not be regarded as expendable in airspace planning but as a rightful user whose requirements can be managed within an ATC system. The British Parachute Association appreciates being given the opportunity to make this submission and will be happy to expand upon any of the brief detail included here. Any request for further information will be given immediate attention to enable a rapid response. February 2009

Memorandum from BAA Airports Limited (AIR 44)

1. Introduction This paper sets out the policy position of BAA Airports Limited (BAA) on the use of UK airspace generally and in relation to the demands placed on it by the forthcoming expansion of airport capacity as presented in the 2003 Future of Aviation White Paper. BAA has worked collaboratively with NATS and CAA’s Directorate of Airspace Policy (DAP) on these issues in the preparation of Heathrow’s Runway 3 and Stansted’s G2 proposals. BAA has also been involved in the recent AOA submission to the Committee.

2. Response BAA believes that a consolidated approach to the future strategy for UK Airspace is essential for considering the future increase in demand for air traYc capacity in the UK. In our view it appears likely that the CAA’s DAP is best placed to receive and coordinate views in establishing and being subsequently accountable for such a strategy. BAA agrees that the correct approach to developing controlled airspace in the UK is to establish the operational, safety and environmental case within such an overall strategy and masterplan to ensure that the future needs of all airspace users are met and that balance is achieved between their respective interests. This would mean that controlled airspace is only increased to meet the sustained needs of commercial air traYc but no more and that other airspace users who require unfettered use of uncontrolled airspace could be expected to do all they can to ensure that such controlled airspace that exists is not infringed, standards of airmanship improved and radio contact maintained where this can be proved by ANSP’s to deliver the desired safety and capacity benefits. BAA believes that it will become increasingly diYcult to completely reconcile the interests of all stakeholders in future airspace change proposals made necessary by increased aviation activity. In our view it is unrealistic to expect any airspace change proposal to pass through unchallenged and therefore we believe that the DfT and DAP have an accountability to stakeholders to establish the weighting put to the varied interests surfaced by an airspace change and this will greatly assist in building in robustness to proposals. Sponsors of the change and relevant stakeholders should not be delayed unnecessarily in hearing the outcome of an airspace change proposal. Where an increase to the extent of controlled airspace is desirable, the costs of the processing of an airspace change proposal through the regulator and all associated design and public consultations should be met by the beneficiaries of such an increase, which would be the airspace users. For the future, BAA is committed to the aims and objectives of the SESAR (Single European SKY ATM Research) programme in increasing capacity up to three times present levels, halving the cost of en route air traYc services to airlines, improving safety by a factor of ten and reducing environmental impact per flight by 10%. Recent initiatives to use airspace more eYciently and collaboratively through civilian/military interaction and the creation of FABs (Functional Airspace Blocks) are to be welcomed and expedited to meet some of the SESAR initiatives. Examples of this would be the reduction in miles flown for a given sector because of more direct routeing and the reduction in costs as the creation of FABs transcends the need for sovereign airspace, controlled by the most eYcient service providers. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Other examples of where SESAR might make a diVerence in the UK would be the reduced requirement to hold aircraft awaiting arrival at our most congested airports. There are tools and techniques under development which could unlock solutions in this area. CDM (Collaborative Decision Making) is another example where the prospect of sharing and communicating data oVers step changes in the eYciency of the aircraft turnaround process reducing delay, improving punctuality and predictability and making best use of costly infrastructure and assets namely runways, aircraft parking stands and aircraft. At a time when the industry is becoming seriously eVected by global economic instability, measures such as these are essential rather than desirable. BAA has just submitted a bid to become a member of the SESAR Joint Undertaking alongside Aeroports de Paris, Schiphol Airport, Munich Airport, Fraport (Frankfurt) and Unique(Zurich). Our bid has not only been coordinated amongst the members of the SESAR European Airport Consortium (SEAC) to provide a focus on the way in which Air TraYc Management issues are developed at airport level but has also been coordinated with other authorities and agencies such as AENA and Eurocontrol to ensure a truly Pan European solution. All members of the SEAC Consortium will liaise with their respective associations whether they be national, in the case of the UK, the Airport Operators Association or European, ACI (Airports Council International) Europe to ensure that all airports can be involved and participate in SESAR development. The work eVort invested in SESAR will produce, in time, an ATM framework which will address the current fragmented state of airspace development and will ensure global interoperability through international agreement with the FAA’s NextGen programme and with ICAO. Above all it is essential for the UK Aviation sector to become involved in SESAR to make sure the outcomes of the development and deployment phase enhance the UK’s track record in these areas and not be driven by outside interests. The SESAR programme funding is made up of 2.1 billion euros of cash and in kind contributions from a wide number of industry stakeholders and, despite the economic downturn, there has never been a time in aviations brief history when innovation is more acutely required. 2008 was a diYcult year for air transport and 2009 is set to be even tougher. However demand in the longer term is set to rise substantially with traYc surging to 18 million movements in 2030. This is no time to lose sight of the long term challenges and goals, because the challenges continue to require decisions and actions today. January 2009

Memorandum from the European Commission (AIR 45)

IMPACT OF AIRSPACE DESIGN IN OTHER EUROPEAN COUNTRIES

European Commission Views

The House of Commons Transport Committee has asked the Commission to present its views on “How does the management of airspace in the rest of Europe aVect flights into UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries?” The question above is very relevant, since all route networks and air traYc hubs have an impact on each other. This happens mostly between neighbouring areas, but in Europe’s congested airspace, there is often a ripple eVect on areas further oV as well. All of the core area of Europe is strongly interdependent and this is especially the case for the London- Paris-Amsterdam triangle, where we have both Europe’s densest traYc areas and where some of EU’s busiest airports are so close to each other that their descent and climb paths interact. The European Commission has been closely involved in matters of reorganising European airspace and ensuring maximal use of this scarce resource in the face of increasing traYc, through its “Single European Sky” (SES) initiative. This initiative first materialised in 2004 with the adoption of four Regulations. These are the Framework Regulation (EC 549/2004), the Service Provision Regulation (EC 550/2004), the Airspace Regulation (EC 551/2004) and the Interoperability Regulation (EC 552/2004). In June 2008 the Commission proposed a second package (SES2) of measures to update the abovementioned Regulations and at the time of writing, these Regulations are being finalised with adoption expected in the 2009. In particular two aspects of the new Single European Sky 2 regulations aVect airspace planning also in the UK: Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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1. Functional Airspace Blocks

The functional airspace blocks are a concept that was introduced already in 2004 to encourage national air navigation service providers to co-operate and organise their airspaces without regard to political boundaries, but with a view to the actual traYc streams and the needs of all airspace users. Since progress has been slow, the Single European Sky 2 proposal introduces a firm deadline (2012) for all States to implement functional airspace blocks. At the same time in Single European Sky 2 the concept is being widened from pure airspace related co-operation to a wider and more flexible range of ways in which the service providers can optimise their operations and improve performance. In addition to the UK-Irish initiative for a functional airspace block, there are other functional airspace blocks being formed around the UK airspace in the neighbouring countries and since these will lead to changes in their respective airspaces, there will also be impacts on UK traYc flows. Most notably in the core areas of Europe, the “FAB EC” initiative is moving towards integrating the service provision of Belgium, France, Germany, Luxembourg, the Netherlands and Switzerland and thus reorganising their airspaces. On the north side of UK, there exists the “NEFAB” initiative, which includes the five Nordic countries, and Ireland. This project in turn will impact the traYc flows over the Atlantic and over the Nordic area. It has always been EC view, that the functional airspace blocks should not be created in isolation, but with a European network approach in mind. The blocks can be truly functional, only if they co-operate also with each other and seek to optimise their airspace planning so that a continuum of airspace is created over the whole of the European airspace. It is for that reason that the new legislation requires Member States and their service providers to form co-operation or integration arrangements also with neighbouring functional airspace blocks.

2. Network management function

A new concept in the Single European Sky 2 proposal is the Network management function. It aims to introduce an element of planning on network (European) level and thus to maximise the use of scarce resources, such as airspace, radio frequencies and their like. The route design part of the Network management function will create a central planning function that aims to draft the en-route part of existing route network in a manner that is based primarily on airspace users needs. Studies have shown that today most national route networks are still built with the needs of the national air traYc service provider and local airlines in mind. Hence traYc today flies an average distance of 49 kilometres too long on intra-European routes. Under current planning the other Network management function parts will concentrate on co-ordination and allocation of radio frequencies and certain codes, which are currently in short supply due to poor co- ordination amongst States. However in the future the European ATM modernisation project SESAR will probably bring more duties for the Network management function to perform and these may also have airspace impact.

3. SESAR

SESAR is the technological pillar of the Single European Sky. This public/private partnership has very ambitious objectives to provide additional enhanced safety, capacity, environment and flight eYciency. Funded by the European Union (700 M ƒ), Eurocontrol (a similar figure) and European industry, it has the potential to radically change the management of airspace in Europe. UK national service provider (NATS) is one of the key contributors. March 2009

Supplementary memorandum from the European Commission (AIR 45A) During the Transport Committee evidence session on 18 March 2009 concerning the use of airspace, the discussions about the network management function in the recently adopted Single European Sky II package left one particular question unanswered. I would therefore like to come back to the questions 328 to 331 from the evidence session and provide you with some further clarifications. The air traYc management (ATM) network will allow optimum use of airspace and ensure that airspace users can operate preferred trajectories, while allowing maximum access to airspace and air navigation services. The network management function has been designed to assist aviation stakeholders in this process Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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from a European network perspective and to complement the introduction of the performance regulation. It will comprise a range of tasks, exercised by diVerent actors including: — European Route Network Design: to ensure that local design solutions are consistent with European network eYciency requirements within a multi-modal policy and that all airspace users can fly optimal trajectories; — Management of scarce resources: to optimise the use of scarce resources, like frequencies or transponder codes, through a centralised inventory of these resources, with a view to overcoming sometimes conflicting local solutions; —TraYc Flow Management, slot coordination and allocation: to allocate slots as a function of the “required time of arrival” to improve the predictability of operations; — Management of the deployment of SESAR technologies and the procurement of European-wide infrastructure elements: to ensure consistent and synchronised availability of suitable equipment and management of information networks, as defined in the ATM-Master Plan. The modalities for executing the functions will be developed in implementing rules, guaranteeing public interest impartiality and ensuring appropriate industry involvement. The development of these implementing rules will follow the “Community method” (the standard EU decision-making procedure, embracing the Single Sky Committee, the Industry Consultation Body, the social dialogue Committee43 and Eurocontrol44 in an institutional framework with wide stakeholder consultation) that has been instrumental in establishing Single European Sky rules since 2004. Member States will therefore not only have the ability to address their particular interests in the development steps of the implementing rule. They will also have the possibility to address concerns, if they are not convinced about the content of the implementing rule, in the Single Sky Committee where the EC has to obtain a positive opinion of Member States with qualified majority voting procedure. And finally there is always the possibility for Member States to use the “safeguard clause” in the framework regulation which allows Member States the application of measures to the extent to which these are needed to safeguard essential security or defence policy interests. The success of the Single European Sky is dependent upon the alignment of all actors towards one single goal which is to oVer the most performing air traYc management (ATM) infrastructure to the needs of an evolving aviation industry. April 2009

Memorandum from The British Gliding Association Ltd (BGA) (AIR 46) It is understood that the Transport Committee will examine progress in preparing for changes to the management of airspace and would particularly welcome responses to the following 11 questions: The British Gliding Association (BGA) wishes to make the following comments. A one-page summary of BGA activities is at Annex A and a Glossary of Terms is included as Annex B. The latter uses words from the Glossary on the web site of the Technical Commission on Airspace and Navigation Systems (CANS) of the Fe´de´ration Ae´ronautique Internationale.

Q1. What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented? A1. For the future management of airspace, the BGA believes that in advance of any proposed changes, all stakeholders should be consulted at the outset of the process. On the passenger numbers and movements of Commercial Air Transport that were predicted in the 2003 White Paper, these may now be an overestimate. There is a risk of that over-estimates may lead to unnecessarily restricted airspace measures being proposed.

Q2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for air traYc control? A2. Our experience is that through co-operation between airspace users, safety can often be maintained while airspace utilisation is increased, avoiding the need to jump to new, and possibly restrictive, solutions before they are required.

43 The Sectoral Social Dialogue Committee on Civil Aviation, established on basis of Commission Decision 98/500/EC of 20 May 1998, extended to ATM. 44 The European Community became a member of the Eurocontrol Organisation under Council Decision 11053/2 Aviation 121 of 17.7.2002. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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In terms of future airspace management, the BGA is aware of a future Air TraYc Management (ATM) system based on Satellite Navigation rather than radar. This is already in use in Australia and is planned to be introduced in the rest of Europe and North America in the next decade. It is called Automatic Dependent Surveillance—Broadcast (ADS-B) and more detail is given in the Glossary. Aircraft ADS-B equipment has the accuracy of Satellite Navigation systems such as the U.S. Global Positioning System (GPS), positional errors being of the order of 10 metres. Such positions are broadcast to ATM ground stations for control purposes and also to other aircraft for proximity warning (anti-collision) purposes. This is much more accurate than any radar-based system. Furthermore, accuracy is uniform over large areas compared to radar where accuracy degrades with distance away from the radar head. However, it appears that there is no coherent plan in the UK for the future replacement of radar-based ATM systems with those based on satellite navigation. The relevant UK Authorities should be asked to formulate one. Some advantages of ADS-B over radar are summarised in Annex C which consists of extracts from the U.S. Federal Aviation Administration (FAA) Notice of Proposed Rulemaking (NRPM) 7–15 dated October 2007. On the civil/military interface the BGA has no comment except to note that the incidence of Military-to- Commercial Air Transport Aircraft Proximity (AirProx) reports is significant and greatly in excess of those involving General Aviation and air sport aircraft (figures, Annex D).

Q3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently? A3. In terms of planning and regulation, the BGA believes that the current approach using CAP 724 and 725 procedures backed by regular liaison of all stakeholders with ATM authorities, is satisfactory. First, measures that increase coherence and minimise the resources (from all stakeholders) required by the current system should be considered. The cost/benefit of a future and diVerent Airspace Master Plan should be carefully analysed before proceeding. However, in certain areas diVerent circumstances may apply and could be overlooked or inappropriately dealt with an over-rigid master plan. It is therefore important that case- by-case considerations are taken into account. In terms of future aircraft equipment, the BGA is concerned that there has been a proposal by the CAA Director of Airspace Policy (DAP) to impose radar-based Mode S transponder devices on every aircraft flying anywhere in UK airspace45. For visual flight outside Controlled Airspace (CAS), this was strongly resisted by UK air sport associations including the BGA. Clearly, electronic identification devices such as Mode S radar transponders and future Satellite-based systems are required inside busy Controlled Airspace, for the continued safety of the fare-paying passenger. However, when the whole volume of UK Airspace is concerned, Commercial Air Transport represents a small number of aircraft compared with the total number of aircraft currently based in the UK (numbers, annex D). The current result appears to be that, after a second consultation in 2008, DAP is now concentrating on the establishment of Transponder Mandatory Zones (TMZs) as an addition to existing CAS. However, it is noteworthy that the DAP Summary of Responses document Issue 1.1 dated 4 December 2008 ends with the words “the carriage and operation of Mode S transponders in all UK airspace will continue to be encouraged and the benefits publicised”. For visual flight outside CAS, the BGA believes that this is unnecessary. Furthermore, we question radar-based transponders as the long-term technical solution, in view of the remarks on ADS-B above and in Annex C. We would like to see a plan from the DAP or other relevant areas of the CAA for the future transition from radar-based aircraft ATM equipment to that based on Satellite navigation. Currently, pilots are taught to practice regular visual scans and adopt the “see and avoid” principle. The BGA believes that, outside CAS, a universal radar-based electronic identification policy is not only unnecessary, but shows a disproportionate approach not only to the 2,500 UK gliders but also to the many thousands of light General Aviation (GA) and air sport aircraft currently able to fly in the UK. These aircraft operate with little adverse interaction with Commercial Air Transport. It is understood from statistics from the UK CAA that the GA and sport aircraft sector in the UK comprises some 96% of aircraft based in the UK. These are tabulated at Annex D in terms of broad aircraft categories and total nearly 26,000 aircraft. Of these 26,000 aircraft, some 13,000 have little or no electrical generation capability and clearly would have diYculty in eVectively operating any equipment that has high current drain, high weight or large volume. One advantage of GPS-based systems is low current drain and low weight, and many Light GA and air sport aircraft already carry GPS equipment. In the case of competition gliders it is normal to carry two GPS-based recording devices and many carry a GPS-based proximity warning (anti-collision) system called FLARM (“Flight Alarm”, for more details see the Glossary). However, in areas where electronic identification may be required in the future, it is essential that ADS- B equipment is available that not only has low current drain but is at a low enough cost to be aVorded by the Light GA and sport aircraft sector. We use the term “Light GA” to describe the lower-cost end of the

45 Proposal to amend the Air Navigation Order for the purpose of improving the Technical Interoperability of all aircraft in UK Airspace. Director of Airspace Policy document P-RIA 1.2 for responses by 29 August 2006 Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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GA market, excluding aircraft such as business jets and turboprops. A modified version of FLARM with a longer-range ADS-B-compatible broadcast link, might be suitable. The BGA would like to see the development of such systems. These should be accepted by the ATM authorities for flight in areas where it is deemed that electronic identification is required and the “see and avoid” principle has been positively shown to be inadequate for the traYc densities in the area concerned.

Q4. How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck?

A4. The eVects of noise and emissions are taken into account during Airspace Change Proposal (ACP) consultations. We support the current CAA document CAP725 process for taking these factors into account. In the future these procedures will become more important. However, as broad a stakeholder community as possible should be involved. Finally, we should point out that gliding generates very low noise levels and very few emissions.

Q5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries?

A5. The BGA understands that the rest of Europe is progressing towards the ADS-B system mentioned above and recommends harmonisation of UK systems through bodies such as Eurocontrol, EASA and EUROCAE (details in the Glossary) under the SESAR programme (Single European Sky Air TraYc Management Research, see the Glossary). The BGA engages with European airspace issues through Europe Air Sports (EAS) which represents all air sport organisations in Europe. At an international level, the BGA is represented at the Fe´de´ration Ae´ronautique Internationale (FAI) which has its HQ in Lausanne, Switzerland. It should be noted that FAI has a Commission on Airspace and Navigation Systems (CANS), on which the UK is represented and provides the Commission secretary.

Q6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive stacking while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements?

A6. ADS-B will enable safe separation distances to be reduced and more versatile tracking to be obtained compared to flying direct tracks between fixed radio beacons. This is clearly indicated in the U.S. FAA document quoted in Annex D. It is understood that separation distances for Commercial Air Transport are likely to be substantially reduced when ADS-B is fully operational. A figure of three Nautical Miles has been mentioned, compared to the current five nautical miles. However, the BGA does not believe that airliners should be encouraged to fly in otherwise free airspace, but should normally fly in the Controlled Airspace that has been provided for them. The implications to other airspace users of allowing or encouraging airliners to fly “oV airways”, could have serious implications to both them and the many other users of this airspace, particularly in the lower levels below, say, 10,000ft.

Q7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties Department for Transport, the CAA, airport operators, NATS, etc, appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play?

A7. The BGA believes that the light GA and sport flying sectors should have more representation in these processes, particularly in the early stages of any possible changes. The owners and operators of nearly 26,000 UK aircraft in this sector (figures, annex D) should have the opportunity to be represented by their relevant Associations. The BGA and other air sport and GA bodies include highly qualified aerospace professionals within their membership (as was stated in our last submission to your Committee in the late 90s) and would like to have greater involvement in the study and planning for these future generation systems. This has already been suggested to the DAP area of the CAA. Such forward planning would be to identify at an early stage where trade-oVs can be made, in order to benefit particular aviation sectors without disadvantaging others. As an example, DAP’s proposal that Mode S should be fitted to all aircraft flying in all UK airspace including outside CAS, took the GA and sport aviation movements by surprise, although as we now know, the planning for Mode S ground infrastructure had been in place for many years. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Q8. Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? A8. The BGA is satisfied with the existing CAA airspace change procedures laid down in the CAP724 and CAP 725 documents, if properly applied and with due consideration to all airspace users. It is particularly important that when an increased volume of Controlled or Restricted Airspace is being contemplated, the eVect on all airspace users should be taken into account and not just the few. Particularly, it should be recognised that expansion of CAS in one area can lead to so-called “choke points” in others, into which other aircraft movements will then be concentrated. Already, in some areas near CAS, other traYc has already been squeezed into increasingly smaller airspace volumes, with consequent increase in risk. Examples include near Bristol, the narrow gaps between the Brize and Lyneham areas, between Lyneham and the Salisbury Plain ranges, under Daventry CAS, the periphery of the London Terminal Area, Doncaster Robin Hood airspace, Humberside, and so forth.

Q9. What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? A9. The BGA is concerned that smaller airfields and recreational and sport flying generally could be seriously threatened by unnecessarily large increases in controlled airspace. It is also concerned at the trend not only to allow, but apparently to encourage, airliners to fly outside Controlled Airspace (CAS). It believes that CAS is designed for the protection of the fare-paying passenger and that flight outside it by airliners should be the exception rather then the rule, particularly in lower altitudes such as below 10,000ft where many thousands of light GA and sport aircraft fly.

Q10. How should an appropriate balance between conflicting priorities be determined? Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? A10. The BGA believes that a rigorous risk analysis should always take place before any increase in Controlled Airspace is agreed. This should be based on facts rather than surmise, taking into account better utilisation of existing CAS and an assessment of risk, particularly to the fare-paying passenger. The number of actual Commercial Air Transport (CAT) movements at a given airport and area should be taken into account when a new volume of Controlled Airspace is being considered. In the case of low densities of CAT, consideration should be given to smaller CAS volumes and/or time scheduling of the application of CAS in accordance with the actual presence of CAT aircraft. In terms of AirProx reports, the BGA notes that many are assessed as “no risk” and are essentially “sighting reports”; these should be not be used in risk assessments when new airspace is being considered. However, the low-power low-cost ADS-B equipment mentioned above will help light GA and some air sport aircraft to have continuing access to lower-densities of CAS. As stated above, the existing CAA procedures laid down in CAP724 and CAP 725 documents are considered satisfactory, if properly applied and with due consideration to all airspace users.

Q11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? A11. The BGA believes that those who directly benefit from and use CAS should fund airspace changes. Aircraft such as gliders flying outside controlled airspace, should not be subject to extra costs due to future changes in airspace or avionics. March 2009

Annex A

SUMMARY OF ACTIVITIES OF THE BRITISH GLIDING ASSOCIATION The British Gliding Association (BGA) is a member’s organisation that has for 70 years successfully provided the safe, self regulated framework for the sport. It has also taken responsibility for managing the regulation of gliding in the UK under the oversight of the CAA. The BGA is made up of 90 not-for-profit clubs run by volunteers with some 9000 regular participants and 30,000 occasional participants operating some 2,300 gliders along with some 150 self-launching gliders (using a small engine), static winches for launching by cable, and towing aircraft. In addition to instructional flying primarily in the area of each gliding site, when the weather conditions are suitable, flights over long distances are common. In these cases, planned flights, including competitive races, are made around turning points with the aim of returning to base. This fundamental element of the sport requires participants to utilise thermal up-currents under cumulus clouds, rising air from atmospheric waves in the lee of hills and mountains, and ridge lift where air rises over steep ground features. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Promotion of youth participation in the sport is a priority for the BGA, and it works closely with Sports Councils and other agencies to ensure the maximum engagement with all communities. With progress in structural and aerodynamic technologies, the modern high-performance glider is a sophisticated aircraft capable of flying many hundreds of miles using the thermal and wave energy already mentioned. Maximum glide ratios have increased steadily over the years. 45:1 is typical of a 15 metre competition glider and larger gliders approach 60:1. By comparison, a hang glider has a glide ratio of 10 to 15:1. This ratio is of forward speed to sinking speed, and at 50:1 a glider starting at 5000 feet over Northampton could glide to Evesham (in still air conditions) without any thermal or wave lift. The longest straight glider flight in the UK was from Lasham in Hampshire to Portmoak, north of Edinburgh, during a national championship. The longest out-and-return flight was from Lasham to Durham and return, and several flights with multiple turning points of over 1000km (620 statute miles) have been flown. These flights can take up to 10 hours to complete. Between May and September each year, some 500 entries are accepted in BGA-organised competitions with many hundreds more taking part in club-organised events and leagues. Tasks are scored for speed around a diVerent course each day which varies with wind and the forecast thermal or wave lift. For the higher performing competition classes, average speeds round the set course are frequently in excess of 100 kilometres per hour (62mph) and courses can be up to 500 km in length (311 statute miles), avoiding Controlled Airspace by suitable placing of Turning Points. In thermal lift the height band most frequently used is between about 2000 and 6000 feet above ground, but in wave lift, flight to 20,000 ft and above is not unusual. As mentioned in the main text, competition gliders all carry GPS equipment and GPS-based recording devices are used for scoring. The GPS information is also used for flight instruments and for navigation, and almost all gliders have their GPS position and any nearby controlled airspace presented on a moving-map display in the cockpit. Similar to sailing dinghies, gliders do not generate electrical power. They rely on batteries to power radios and navigational instruments. Gliders range in value. The older wood, metal and fabric covered types commonly used by young people, low income participants and for training because of their low capital and running costs, can be purchased for as little as £3,000. A top of the range composite-structure competition glider is at the other extreme where a syndicate could pay more than £100,000. In this respect the sport is again similar to sailing. At an international level, British glider pilots regularly bring back Gold medals, and Gliding Team GB is one of the most successful in the world. A final and important point is that, because a glider pilot needs to be constantly searching the sky ahead for the next source of “lift”, visual lookout and scan is an integral part of gliding. The “see and avoid” principle is highly eVective in this sector of aviation and the unwanted imposition of other electronic devices in the cockpit could even detract from it.

Annex B

GLOSSARY OF TERMS This material is taken from the Glossary of the Fe´de´ration Ae´ronautique Internationale’s Technical Commission on Airspace and Navigation Systems (CANS): http://www.fai.org/system/files/cans glossary 2009 1 6.pdf ADS-B—Automatic Dependent Surveillance—Broadcast. The ADS-B system uses Global Navigation Satellite System (GNSS) position data and a relatively simple broadcast communications link. It has been said that the ADS-B system is the future for worldwide Air TraYc Management (ATM) and for proximity warning between aircraft. Programmes implementing ADS-B include CASCADE and SESAR in Europe and NextGen in the USA (see elsewhere in this Glossary). The initials ADS-B originate from the following: it is Automatic, in that it is always live and requires no operator action. Dependent, in that it depends on a GNSS system such as GPS for position data. Surveillance, in that it provides this 3D position data to ground controllers and other aircraft. Broadcast, in that it broadcasts data on pre-set radio frequencies to any aircraft or ground station equipped with ADS-B that is listening. Unlike radar, ADS-B accuracy does not diminish with range, atmospheric conditions or target altitude and has the same accuracy as GNSS. ADS- B aircraft equipment takes GNSS position data and combines that data with other aircraft information, such as pressure altitude, airspeed and flight/aircraft identification. This information is then broadcast to other ADS-B-equipped aircraft for proximity warning (anti-collision) purposes. It is broadcast also to ADS-B ground stations for identification, surveillance and Air TraYc Control purposes. It will also work on the ground, for instance in monitoring airfield movements and the choice of the correct runway for takeoV in conditions of poor visibility. ADS-B with an appropriate network of ground stations also works in remote areas or in mountainous terrain where there is either no radar coverage, or where radar coverage is restricted by obstacles in the line-of-sight. An ADS-B ground station consists of antennas and other equipment to receive and request aircraft data and either land-lines or microwave links to communicate with Air TraYc Control Centres. An ADS-B ground station is much simpler and less expensive than a surveillance radar station. As ADS-B becomes operational, the large surveillance radars presently used for civil air traYc control, can be phased out in favour of a network of ADS-B ground stations. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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ADS-B in North America. In the USA, the FAA awarded a contract on 30 August 2007 to a consortium led by ITT Corporation to provide ADS-B surveillance uplink (ground-to-air) and downlink (air-to-ground) services, Automatic Dependent Surveillance Re-broadcast (ADS-R), TraYc Information Services— Broadcast (TIS-B) and Flight Information Services—Broadcast (FIS-B). Ground stations in Florida were completed in September 2008 and other areas in North America follow including Canada and the Gulf of Mexico. Under FAA NPRM 7–15 dated 1 October 2007, infrastructure for ADS-B Out, including broadcast services and 548 ground stations, is to be available by the end of Fiscal Year 2013. The FAA compliance date for aircraft to be fitted with ADS-B is 2020, and some aircraft (such as those of the freight carrier UPS) are fitted now. ADS-B Out will use the 1090 MHz Extended Squitter (1090ES) or the 978 MHz Universal Access Transceiver (UAT) broadcast links. UAT will also be used to uplink Flight Information Service (FIS) information to aircraft. EASA—European Aviation Safety Agency, the EU regulatory agency for aviation, headquartered in Cologne. EUROCAE—European Organisation for Civil Aviation Equipment. The organisation for certifying aviation equipment in Europe. It is a non-profit organisation formed from manufacturers of aircraft, airborne equipment, Air TraYc Management (ATM) systems and ground equipment, Service Providers, National and International Aviation Authorities and Users (Airlines, Airports, operators) from Europe and elsewhere. EUROCAE develops performance specifications and other documents that are referenced as a means of compliance to European Technical Standard Orders (ETSOs) and other regulatory documents. EUROCAE works with US standardisation bodies to produce harmonised specifications where possible. EUROCAE documents also take into account ICAO standards and ARINC specifications. Eurocontrol—the organisation for the harmonisation of air navigation services across Europe. It is a civil and military inter-governmental organisation, currently with representation from 38 Member States. Its mission is to harmonise and integrate air navigation services through a uniform Air TraYc Management (ATM) system for civil and military users. Implementation will include a system known as the Single European Sky (SES). Eurocontrol is based in Brussels, Belgium, and has oYces in six other European countries. FLARM—A proprietary GPS-based short-range proximity-warning system for light aircraft, gliders and other sport aircraft, developed by the Flarm company of Zurich, Switzerland, using frequencies in the 800 MHz band. The name is taken from the words FLight AlaRM. It transmits the GPS position and pressure altitude of the own aircraft (the “ownship”) to other Flarm-equipped aircraft and displays proximity information in a cockpit indicator and also through cockpit audio. It was originally developed for flights over the Alps but has worldwide applications. It uses the Swiss uBlox TIM-LP 16-channel GPS receiver board. An ADS-B-compatible version is being developed. See www.flarm.com SESAR—Single European Sky Air TraYc Management (ATM) Research Programme. This is a European-wide ATM improvement programme involving civil and military, legislators, industry, aircraft operators, ground and airborne users. It also supports Single European Sky (SES) legislation. SESAR objectives include transforming the European ATM system, eliminating the previous fragmented approach to ATM across European Nations, synchronising plans of the diVerent partners and pooling of resources. SESAR is being run in three major phases: 2005–08, Definition Phase; 2008–15, Development Phase; 2014–20, Deployment Phase. The equivalent programme in the USA is called NextGen.

Annex C

EXTRACTS FROM U.S. FEDERAL AVIATION ADMINISTRATION (FAA) NOTICE OF PROPOSED RULEMAKING (NRPM) 7–15, ISSUED IN WASHINGTON, DC, ON 1 OCTOBER 2007 Not printed as already in public domain. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

Ev 244 Transport Committee: Evidence Annex D about 96% % and climb and to save from field landing - V BGA operated aircraft 2007 BGA gliders & MGs Balloons, Powered Hang Gliders but is used to save from field landing V n a 5 hour soaring flight 9.9 10.3 9.5 9.9 of UK total of GA 62 0.2 0.2 SLMG 112 0.4 0.4 Tugs 2,511 9.3 9.7 Gliders GENERAL AVIATION AIRCRAFT OPERATING IN UK AIRSPACE * Self-Sustaining Gliders (SSGs) have- small The engines engine and cannot no be electrical used generation for takeo ** SLMGs have electrical generation but only run the engine for initial takeo - Typically 10 minutes of*** engine Touring i Motor Gliders (TMGs)aircraft have in the motor engine glider in mode the they nose will and spend can long be periods operated soaring either without as engine a motor glider or as a light Those without any electrical generatorsBGA Sep 2006 club returns Total BGA 10,350 38.3 39.9 Hang/Para Gliders, Gliders, Balloons 2,685 ClassAeroplanes (GA types)Helicopters & Gyroplanes (GA types)Hang gliders & Para GlidersMicrolightsGliders, SSGs*, SLMGs**Balloons & AirshipsPowered Hang Gliders & Para GlidersTotals 1,560Excepting aeroplanes & helicoptersLittle or no electrical generation 8,900 5,960 5.8 1,050 Numbers 2,540 15,500 32.9 22.0 6.0 3.9 13,450 1,850 4,100 Includes 9.4 250 % Gyroplanes 57.3 34.3 23.0 49.7 Excludes microlights 4.0 6.8 (included below) 15.2 9.8 25,960 59.7 % CAA Could figures be do Remarks regarded not as 51.8 include Sport TMGs*** Aircraft total 15.8 7.1 Hang/Para Gliders, 96.0 half of Microlights, Gliders & Motor Gliders**, 100.0 Total gliders 2,573 Source: GA Alliance P-RIA response to the CAA, para 3.5.1 GA compared to total UK aircraft The numbers are mainly fromListed CAA in reviews numerical of order UK of General aircraft Aviation numbers, Aeroplanes & Helicopters first Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Memorandum from Birmingham International Airport (AIR 47)

Background

1. Birmingham International Airport welcomes the opportunity to contribute to the Inquiry into the use of Airspace. 2. Birmingham International Airport employs NATS to undertake air traYc control at, and in the airspace surrounding, Birmingham Airport. 3. The airspace serving Birmingham International Airport is located between some of the busiest and most congested volumes of airspace in the world. The London Area controlled airspace to the south and the Manchester Area controlled airspace to the north already, on occasions, place restrictions on the ability of Birmingham International Airport to operate punctually. The high degree of utilisation and congestion results, occasionally, in the imposition of departure flow restrictions on air traYc leaving Birmingham International Airport. 4. Birmingham International Airport has a significant role to play in providing additional airport capacity for the United Kingdom, as set out in the 2003 White Paper—The Future of Air Transport (ATWP). Birmingham International Airport’s overriding concern is to ensure that future capacity growth of the Airport is matched by growth within the local and national airspace environments. Furthermore, that changes in the structure and management of United Kingdom en route airspace is fully co-ordinated with airports and other airspace users, within the context of a comprehensive framework. 5. Birmingham International Airport has submitted a planning application for a runway extension and associated infrastructure and the Local Planning Authority, Solihull Metropolitan Borough Council, is minded to approve the planning application, subject to final agreement on a Section 106 Planning Agreement. The final planning decision is expected in March 2009. Birmingham International Airport would then commence a detailed CAP 725 Airspace Change Process (ACP) with regard to airspace changes resulting from the planning application to extend the runway. Therefore, it would be premature to comment fully to the Select Committee on the process, but certain key issues are highlighted. 6. The response to questions raised by the Transport Select Committee are shown below.

Question 1 What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented?

7. The forecasts in the ATWP have been shown to be relatively robust, with only a slight reduction for 2030 in the latest DfT forecasts. Birmingham International Airport’s Master Plan forecasts of 32.6 mppa by 2030 in the ATWP have now been revised to a figure of 27.2 mppa by 2030. 8. The ATWP and the ATWP Progress Report (December 2006) are very clear that a structured programme for the redesign of UK airspace is required to accommodate the forecast increase in Air Transport Movements (ATMs) by 2030. The Civil Aviation Authority (CAA) is responsible for the planning and regulation of UK airspace, but will involve NATS and other interested parties. 9. It is worth noting that a specific responsibility of the CAA Directorate of Airspace Policy (DAP) is “Preparation and maintenance of a co-ordinated strategy and plan for the use of UK airspace and for air navigation” (Airspace Charter CAP 724). 10. Although Birmingham International Airport is committed to providing the infrastructure necessary to meet the anticipated growth in passenger volumes, it is concerned that there is not yet a robust national plan in place to deliver the airspace capacity growth in line with projected airport capacity growth.

Question 2 Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for air traYc control?

11. The Airspace Charter (CAP 724) states the role of the DAP as “To ensure that UK Airspace is utilised in a safe and eYcient manner”. Likewise, NATS is required under its licence from the CAA to ensure the safety and eYciency of the UK airspace system. Therefore, it is appropriate for CAA/NATS to advise on this issue. Birmingham International Airport expects that safety can, and will, be maintained within UK airspace, but has no specific expertise in this area. Likewise, Birmingham International Airport holds no views on the question of military and civilian air traYc control interfaces. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Question 3 Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently?

12. A structured programme for redesign, as suggested in the ATWP, is required. However, an “Airspace Master Plan” would probably be too detailed and could be inflexible, but there does need to be a more structured approach compared to the current piecemeal approach. 13. Birmingham International Airport would view favourably a structured programme to co-ordinate changes in the management of neighbouring volumes of airspace that cause “knock on” changes to be made to airspace serving airports. The current piecemeal approach to airspace redesign occasionally results in redesign projects in airspace adjacent to that of Birmingham, requiring changes to the design of the airspace serving Birmingham. 14. As previously mentioned, it is too early to be commenting on a revised Airspace Change Process (ACP) (which was only introduced by the CAA in March 2007), bearing in mind that Birmingham International Airport is only part way through an ACP regarding a proposed change to flight paths resulting from the runway extension. 15. However, it is evident that where an airspace change is due to a change in infrastructure on the ground, such as a runway extension or new runway, then the ACP potentially presents a huge commercial risk to airport operators. DAP approval comes very late in the process, typically an airport company would have to commit to significant capital expenditure at some risk as the required DAP approval typically, would not be forthcoming until construction is either well under way or completed. 16. This is potentially an unacceptable risk to shareholders and a way has to be found of changing the ACP, when major infrastructure on the ground is involved, which enables approval to be obtained at an earlier stage, hence reducing commercial risk without undermining the comprehensive and appropriate nature of the consultation process.

Question 4 How are the eVects and aircraft noise and emissions taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck?

17. Detailed requirements on assessing the environmental impacts are laid down in CAP 725 CAA Guidance on the Application of the Airspace Change Process (March 2007). These requirements are already very complex and comprehensive and should not be added to. 18. Ultimately, it is the CAA’s role to approve airspace changes and it is appropriate that the CAA retain this responsibility which includes assessing conflicting interests.

Question 5 How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries?

19. No comment—for CAA/NATS to advise.

Question 6 What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements?

20. Detailed questions on new techniques and technologies are best answered by the CAA, NATS and airlines. Environmental benefits will result from a reduction in stacking and flying reduced distances. However, as a general point, there needs to be a co-ordinated approach through a structured programme for redesign, as discussed in Q3 above. The “Sustainable Aviation” programme (of which Birmingham International Airport is a signatory) provides a good approach to co-ordinated action. An example of Continuous Descent Approaches being introduced does show that noise and emissions can be reduced. 21. An example of new technology being applied is the design of new Standard Instrument Departure routes, in relation to Birmingham International Airport’s proposed runway extension, using PR-NAV (Precision Area Navigation), but clearer guidance is required from the DAP as to what future navigation design/procedures should be. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Question 7 In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play? 22. Roles and responsibilities are clearly stated in CAP 725 and these are primarily stated as the CAA (Department of Airspace Policy), ANSPs (Air Navigation Service Providers such as NATS) and airport operators. In reality, airport operators will rely heavily on the advice and expertise of the CAA and ANSPs as they would not have the in-house expertise to carry out an airspace design change.

Question 8 Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? 23. The Airspace Change Process should be considered in the context of strategic airspace design decisions and it is correct that the responsibility for the planning and regulation of UK airspace lies with the CAA and not with Local Planning Authorities. Provided that airspace change issues are considered as part of the CAP 725 Airspace Change Process, which can run in parallel to but not as part of the planning process, there should, in theory, be no delay to airport development through the planning process. However, the ACP does have the potential to delay the provision of infrastructure after the planning process is complete and, in extreme cases, result in a redesign, further consultation and consequently significant overall delay to infrastructure development projects.

Question 9 What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined? 24. No comment.

Question 10 Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? 25. No comment—for CAA/NATS to advise.

Question 11 Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? 26. Airports already fund airspace changes required as a result of infrastructure improvements— including the undertaking of relevant impact assessments and public consultation. General en-route airspace redesign should be funded by Government through the CAA or NATS, whichever is deemed most appropriate. March 2009

Joint memorandum from the General Aviation Alliance and the Light Aircraft Association (AIR 48) 1. This paper on the use of airspace by General Aviation Alliance (GAA) and the Light Aircraft Association (LAA) supplements that presented on 28 Feb 09 to the Inquiry into the future of aviation by the GAA (attachment). That paper set out the size, value and scope of GA whilst this paper explains the airspace issues relevant to it. The GAA is a group of organisations representing the interests of many in the UK General Aviation Industry (GA). The LAA is an organisation which supports aVordable flying and is the focus of amateur built aircraft in the UK. It is a member of the GAA. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Make- up of UK GA, 2005

commercial non-GA aircraft balloons and airships 4% 7% “traditional” single- engined piston 21% hang gliders & paragliders (including powered) 26% multi-engined piston and larger singles 2% turbine 1% helicopters and gyroplanes 6%

gliders vintage and historic (including SLMG) 2% 10% microlights amateur-built 15% (fixed-wing) 6%

2. GA is the term used for all aircraft and flying machines other than those operated by airlines. GA ranges from privately owned Airbus and Boeing aircraft and business jets to balloons, light aircraft, gliders and para-gliders. Its aircraft are used for business, training, recreation, sport and pleasure and as a means of transport. 3. The GA sector comprises about 26,000 of the 27,000 aircraft on the UK register, the remaining 1000 belonging to airlines—see the Civil Aviation Authority (CAA) chart at right. GA employs some 17,000 people and has a value to the economy around £1.4 billion, about the same as Virgin Atlantic Airways or 8% of the total economic contribution of UK commercial aviation. 4. GA aircraft use all types of airspace: business and some private aircraft mainly use controlled airspace but the majority used for recreation and sports remain in uncontrolled (class G) airspace but need to cross controlled airspace on occasions. As we noted in our submission on “The Future of Aviation”, the issue of the use of airspace was covered in much detail in the CAA’s Strategic Review. Section 3.1 of the report neatly summarises the problem: “As with all forms of aviation, GA needs a certain level of access to infrastructure in order to operate, although this may vary widely across the diVerent types of GA. There are two main infrastructure issues: airfields (or some form of fixed site to take oV and land): and access to airspace. GA is currently facing increased diYculty in accessing both of these, particularly in the more congested areas of the UK.” This situation prevails and is becoming, and forecast to become worse due to growth in demand for controlled airspace from Commercial Air Transport (CAT), more controlled airspace around airports and new reserved airspace for unmanned aerial vehicles, the latter both from Ministry of Defence and private contractors.

Executive Summary — Number of flights in the UK has not increased as much as commercial operators suggest. — Controlled airspace (CAS) has expanded significantly and continues to do so: — Parts of it are barely used but are not given up. — The CAA appears to have a conflict of interest arising from the Civil Aviation Act 1982. — GA wants to integrate safely without disproportionate restrictions. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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— Sponsors of CAS applications tend to ignore the impact on other airspace users: — This produces an adversarial relationship rather than cooperation for safety. — Increased CAS forms choke points and forces GA aircraft lower increasing intrusion. — Continuous Descent Approaches (CDA) reduce noise and the need for lower level CAS: — But airspace is rarely given up. — Spread of CAS threatens GA airfields, an issue which the CAA recognises: — CAA has no statutory remit to defend GA infrastructure and does not do so. — Flexible Use Airspace (FUA), which is used in the EU, would help share important areas. — Airspace safety information is not “user friendly” but CAA and NATS decline to change. — Airprox (close encounters) numbers are very low. In last reporting period: — None in the UK involving actual risk of collision. — Only two involving GA/CAT where safety was compromised: — One when CAT flying outside CAS — One inside CAS when both aircraft under ATC control (inadequate separation). — Sky is important national asset — Commercial organisations now sponsor and control CAS: — NATS is powerful and owned by shareholder airlines. — CAA has statutory duty to support UK airlines.

Changes to Management of Airspace 5. The inquiry notes that UK passenger numbers may double over 25 years and that UK airspace, particularly in the south will need redesign. Although airport developers like to use passenger numbers to highlight business growth, aircraft are getting larger and airspace demand is dependent on aircraft not passengers. CAA statistics (Annex A) show that passenger numbers have grown 48% in 10 years but flights by only 29%. Moreover there has been no aircraft growth since 2006 and recent figures are down significantly. This suggests growth and capacity projections for commercial airports are wrong and are not a valid basis for airspace planning. However, developers continue to use these figures for their own purposes. 6. The CAA report that in 1997 controlled airspace covered 13% of the UK and in 2004 this had risen to 20%. We understand that the CAA is about to produce a current figure but since 2004 there has been significant growth in controlled airspace at major airports and particularly at regional airports.

Safety through Co-operation 7. The GA community is a responsible stakeholder in UK airspace and has a good record of integrating safely with other airspace users. Our experience is that safety can be maintained through co-operation between airspace users, avoiding the need to exclude GA from large areas or to force disproportionate and impractical technology solutions.

Airspace Planning and Regulation 8. The current Airspace Change Process managed by the CAA backed by regular liaison of all stakeholders and with ATC authorities is generally satisfactory. It ensures all stakeholders are able to scrutinize proposals and express their views before the CAA makes a decision. However we would draw attention to a possible conflict of interest within the Sponsorship Statement for the CAA (verbatim extracts follow): The Civil Aviation Act 1982 requires the CAA to perform its functions in the manner it considers best calculated: “to secure that British airlines provide services which satisfy all substantial categories of public demand …., at the lowest possible charge consistent with a high standard of safety in operating the services and an economic return to eYcient operators on the sums invested in providing the services and with securing the sound development of the civil air transport industry in the UK; and to further the reasonable interests of users of air transport services”. Later in the Act it is stated that (the CAA) has a function to : “determining policy for the use of UK airspace so as to meet the needs of all users, having regard for national security, economic and environmental factors, while maintaining a high standard of safety”. Lord Turner, commenting on his recent review of the banking industry noted that “…a regulator which has a statutory duty to one part of the industry it regulates clearly has a conflict of interest”. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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We have heard it stated within the CAA that it takes the view that Government has determined the public has a right to fly (via commercial air transport), and if that means more airspace has to be classified as “controlled” thereby limiting the amount freely accessed by GA, then so be it. This policy tends to support our view that balance is not achieved. We also understand that Government may be about to review the Civil Aviation Act. Although an Airspace Master Plan might be important for en-route airspace, at lower levels, specific individual consultation ensures the balance between business growth, the environment and other airspace users. A pre-approved master plan would remove the check and balance and make consultation less eVective.

The Environment 9. Compared to the airline industry, GA has only a minor impact on the environment. Its emissions, noise and visual intrusion are small and it seeks to minimize its impact wherever it can. GA airfields and flying sites always try to be good neighbours but changes to airspace can and do have a negative impact. Because most GA aircraft cannot fly in controlled airspace they have to route around or below it. Where controlled airspace is expanded or new airspace introduced it forces them closer to the ground increasing their noise and visual intrusion. It often causes congestion as aircraft are funnelled through choke points between controlled and restricted airspace blocks increasing risk and intrusion. For this reason we seek to minimize the expansion of controlled airspace into areas where this would be a problem but the interest of commercial operations usually prevails.

Aircraft Equipment 10. The CAA has an aspiration to impose radar-based Mode S transponder devices on every aircraft flying anywhere in UK airspace. These make the aircraft identifiable to radar systems and to anti-collision systems installed in airliners and are mandatory for public transport aircraft flying in controlled airspace. The majority of GA have no right to fly in controlled airspace and generally do not do so. They are able to enter and cross it with specific ATC permission and under control. For visual flight outside controlled airspace where CAT aircraft are generally not encountered, imposition of Mode S was strongly resisted by all UK air sport associations because the equipment is expensive in relation to the hull value of many small aircraft and a many thousands of aircraft have no electrical system to support transponders. Whilst the use of Mode S radar transponders in Commercial Air Transport aircraft flying in controlled airspace is vital to safety (it is a part of the anti-collision system of last resort) it does not benefit small aircraft which do not have the complex anti-collision systems needed to see other transponders and resolve conflicts. Although there are exceptions, in general GA aircraft fly outside CAS and CAT flies within it. Thus the overwhelming majority of GA aircraft never encounter CAT aircraft. 11. Presently, the carriage of transponders is mandatory everywhere in the UK above 10,000ft and this has not been an issue as most GA aircraft do not use that airspace. Gliders do need to fly above 10,000 ft but because of their particular problem of weight, space and power supply they have been exempt but the CAA has now proposed to remove that exemption. This would stop a significant part of the sport which requires cross country racing often above 10,000 ft and destroy the UK’s competitive position in World rankings. Essentially, air sport needs access to the equivalent of Green Belts in the sky and although the community is looking for assurance from the CAA that access will be provided, this has not been forthcoming.

Techniques and Technologies 12. The introduction, over the last five years, of Continuous Descent Approaches (CDA) brings airliners down a 3 degree flight path (310ft per nautical mile) all the way from their cruising altitude to touchdown. Their engines remain virtually at idle throughout reducing noise and emissions and providing substantial fuel and cost savings. This has advantages for the population and for GA because airliners are higher (and quieter) and do not need so much low level controlled airspace. At the same time, the technology available to ATC controllers has enabled them to achieve more eYcient routing and to increase the landing and take- oV rate so better utilizing our existing runways. 13. Although this should have resulted in the release of controlled airspace, in practice National Air TraYc Services Ltd (NATS) and other ATC providers want to retain this resource because there is no business advantage in giving it up and they are operated very much as businesses. For example, using CAA data and charts we find that Gatwick is very eYcient in its use of airspace using only some 1.8 sq km for every 1000 aircraft movements. Glasgow has three times the controlled airspace of Gatwick with only a third of the number of flights but NATS (who operate that airspace) have said they cannot consider releasing unused areas and are presently bidding for a 50% increase. Doncaster has recently been awarded controlled airspace slightly larger than Gatwick but has only 2% the number of flights at Gatwick. We would like to see a proper balance in allocating controlled airspace to airports but business interests work against that. It is clear that NATS and other ATC providers are now very business focused and powerful and see airspace as an asset to be acquired and retained. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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Airspace Planning and Management 14. GA organisations work together to engage with CAT operators, with NATS and the CAA and other airspace stakeholders to try to ensure equitable access to airspace. Although we are able to respond to airspace consultations we are usually in the position of challenging a proposal which has been put together with little regard for the impact on GA. We would rather work together with airspace sponsors during the early stage of the airspace change process to develop a design that meets the operational and safety needs of all airspace users rather than engage in adversarial debate at a later stage. We recognise that the safety of public transport flights must be assured but there are always diVerent ways to achieve that and we look to eYcient and eVective solutions that allocate controlled airspace that is necessary and suYcient for the requirement. 15. We have seen airspace applications where the object appears to be to secure as much of this free airspace resource as possible to increase the capital value of the sponsor’s business. This would be easily identified by an objective, rigorous and detailed risk analysis which should always take place before any increase in Controlled Airspace is agreed. But surprisingly, risk analysis is not a tool widely used in airspace matters by controlled airspace sponsors and seemingly not by the CAA.

Airspace Implications for Smaller Airfields 16. As the main airports have approached capacity and driven by airlines’ search for more business and cheaper landings, regional airports have seen an upsurge in the last five years. This has seen a proliferation of controlled airspace proposals around the country which the CAA has always approved, although with some mostly minor, modification. Controlled airspace now divides the country between the Mersey and Humber with just two access routes north to south. A narrow corridor is defined between Manchester and Liverpool in which GA aircraft have to fly at only 1000ft above the ground and a wider area to the east of Doncaster which is under threat from a bid for airspace from Humberside. There is nothing in between. In central Scotland, controlled airspace extends from the Clyde to the Forth with a corridor between Glasgow and Edinburgh which NATS is now proposing to take for itself, isolating the Highlands from the south for aircraft which are unable to cross controlled airspace and excluding gliders from prime soaring country in the Borders and Highlands. We noted earlier that Glasgow had 3 times the controlled airspace of Gatwick with only one third of the flights. 17. With airports focusing on business and many excluding GA, small airfields, airstrips and gliding sites are a limiting resource to the community. The spread of controlled airspace restricts the use of many small airfields and strips and it is virtually impossible to relocate as communities always fear a small and quiet operation will develop into noisy jet traYc. Our only recourse is to negotiate with airspace sponsors for an agreement to continue access although that often means flying low or in areas we would normally avoid for safety or environmental reasons. We would like to see a better balance achieved by giving appropriate regard to small airfields and including access arrangements and risk analysis at the time airspace is designed.

Flexible Use of Airspace 18. Flexible Use Airspace (FUA) is airspace that is turned oV or on at specific times to meet traYc needs. Currently this occurs in upper airspace allowing short cuts for commercial aircraft when military traYcis not using certain areas. We would welcome built-in flexibility when developing lower airspace, for example giving access to an area that is not needed when a particular runway is being used. This is common elsewhere in the EU.

Presentation of Airspace Safety Information 19. One of the key aspects of airspace is notification so that pilots know where they can and cannot fly. Controlled and restricted airspace changes daily and details are distributed by NATS through Notices to Airmen (NOTAM) which also includes a plethora of other information related to navigation aids and so on46. Airlines have contractors who compile and sift this for their crews but individual GA pilots must work with the raw data themselves. As responsible airspace users, many pilots bought graphical programs that would sort and present the data pictorially so they could relate airspace changes and prohibitions to their route but the NATS NOTAM website format was changed without consultation making these programs useless. Pilots now have to work with pages of text and plot multiple positions manually increasing risk of mistake and forming a major disincentive to meticulous pre-flight planning. This is a particular problem for gliding as cross country routes must follow the energy in the atmosphere so their route cannot be planned in specific detail before flight. The CAA contracts NATS to distribute NOTAMs in the UK but neither body

46 The General Aviation Alliance provided a copy of an example of NOTAM information for a short VFR flight from Elstree aerodrome (just North of London) to Coventry for 1 April 2009. The document is 22 pages long. The GAA said the information provided in the Notice covered a much greater area of the country than was really required for that particular flight, and the areas aVected by each Notice were defined by latitude and longitude references which made it diYcult to interpret and required much time to deal with. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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will provide this data in a suitable graphical format saying the cost is prohibitive. But they have been unable to say what that cost is. We think this a significant airspace safety issue that the CAA could resolve but says it will not.

Low Risk and Proportionate Burdens 20. There is no doubt that there is a need to ensure all aircraft can operate safely within UK airspace. It is testament to the excellent work and risk mitigation by all stakeholders that Airprox (reported close encounters between aircraft) involving light aircraft or gliders (or military aircraft) and commercial air transport (CAT) are at a very low level. The UK Airprox Board in its 20th report notes that in the first half of 2008, GA were involved in only 34% of airprox compared to 50% in 2001. In that period there were no Airprox involving “actual risk of collision” anywhere in the UK and of the two incidents involving GA and CAT where “safety was compromised”, one involved a CAT aircraft flying outside controlled airspace and the other involved inadequate separation when both aircraft were under ATC control within controlled airspace. Operating safely includes of course the need for all pilots to be in flying practice. Increasing costs to those whose aviation activities are taxed, severely limiting access to the sky and developing increasingly over-complex and occasionally confusing regulatory burden results in reduced flying practice and thereby does nothing to increase safety. 21. The sky is an important national asset. With sponsorship and management of controlled airspace being in the hands of business entities and particularly with NATS being so powerful in this area and responsible to its shareholder airlines for delivering their requirements, the Regulator must be proactive and meticulous in balancing the needs of all airspace users. We believe that at the moment the sponsors of controlled airspace give insuYcient regard to the needs and safety of other airspace users and whilst the CAA is required to determine policy so as to meet the needs of all users, it appears to have a conflict of interest arising from its duties under the Civil Aviation Act 1982. March 2009

Annex A

TOTAL UK TERMINAL PASSENGERS 1998 TO 2008—SOURCE CAA STATISTICAL TABLES

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 161M 170M 182M 183M 191M 202M 218M 230M 237M 243M 238M

300000000 Passenger growth 48% in 10 years 250000000

200000000

150000000

100000000

50000000

0 98 99 00 01 02 03 04 05 06 07 08 Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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TOTAL UK AIR TRANSPORT MOVEMENTS 1998 TO 2008—SOURCE CAA STATISTICAL TABLES

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 1.9M 1.9M 2.0M 2.1M 2.1M 2.1M 2.2M 2.4M 2.4M 2.4M 2.4M

3000000 Flight Growth 29% in 10 years 2500000

2000000

1500000

1000000

500000

0 98 99 00 01 02 03 04 05 06 07 08

Annex B

THE GENERAL AVIATION ALLIANCE (GAA) The General Aviation Alliance (GAA) is a group of organisations representing the interests of many in the UK General Aviation Industry (GA). It was formed in 2004 due to concerns about the fragmented representation of GA and the need for co-ordinated UK level responses to CAA and EU initiatives, the latter through a pan-EU representative organisation, Europe Air Sports. The term General Aviation (GA) describes all aviation activity except airlines and military ie a civil aircraft operation other than a commercial air transport operation. The principal sectors of the GA industry include sport and recreational aviation (S&RA), personal transport for business and private purposes, flying training, corporate aviation, aerial work and a wide range of ancillary activities from maintenance to airport services. There are approximately 7,500 UK registered and certificated (including approximately 1,000 helicopters) plus 1,000 USA registered GA powered aircraft in the UK, 2,300 microlights, 2,600 gliders, 740 balloons/airships, 62 gyroplanes plus 5,500 hang and paragliders and approximately 1,000 UK civil airliners. In addition parachuting activities are within the scope of CAA regulation as well as aero-modelling. It is understood that air shows are now the UK’s second most popular spectator activity with some 6.6m attending annually (Source: Air Display Association (Europe)). Members of The Alliance include: British Balloon and Airship Club (BBAC) British Gliding Association (BGA) British Hang Gliding and Para Gliding Association (BHPA) British Microlight Aircraft Association (BMAA) British Parachute Association (BPA) Helicopter Club of Great Britain (HCGB) Light Aircraft Association (LAA) PPL/IR Europe—European Association of Instrument Rated Private Pilots Royal Aero Club of the United Kingdom (RAeC) The Alliance coordinates about 72,000 subscription paying members of these bodies. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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Annex C

THE LIGHT AIRCRAFT ASSOCIATION (LAA) The LAA is a national association of some 8000 members which promotes safe and economical operation of Sports and Recreational aircraft, with minimum regulation, through excellence in: Promotion of amateur aircraft construction Provision of aircraft engineering support Protection of flying rights and ownership Preservation of vintage aircraft Discharge of regulatory duties Encouragement of pilot training and skills Promotion of public opportunities to experience aviation We promote aviation to the general public through practical educational experiences including Build-a- Plane projects where groups of young people participate in the construction of a kit aircraft and are then able to fly in it. We also oVer youth air experience events and training in both flying and engineering skills as well as promoting “air mindedness” wherever we can. The LAA is the UK focus for amateur built aircraft, operating a delegated regulatory system enabling members to design, build, maintain and fly their own aircraft. Many members build aircraft from kits or from plans; there are about 2000 aircraft under construction in the UK at any time. The LAA also supports many vintage aircraft which might otherwise be lost to our national heritage. Our goal is to bring low cost flying within the reach of anyone who has the desire to fly. The LAA regulates the airworthiness of over 2000 recreational and homebuilt aircraft on behalf of the CAA, and currently has over 280 diVerent aircraft types and models on its approval. It is possible to own a simple aircraft for little more than £5,000 or a share in a more complex aircraft might only cost £1,000 or so. Maintenance can be carried out by the owner under the supervision of the LAA’s extensive network of experienced inspectors enabling operating costs to be very low. To manage the operation and safety of this large spectrum of aircraft the LAA maintains a substantial professional engineering department with specialist and unique aeronautical skills. Born as the Popular Flying Association in 1952, the present LAA continues to bring flying within the grasp of everyman. LAA pilots operate mainly in day visual conditions but its aircraft fleet ranges from historic examples to modern high performance aircraft with sophisticated navigation systems. Pilot experience and qualification also covers the full spectrum of professional and amateur. The LAA has a high regard for air safety and takes a broad view on airspace matters generally. In considering airspace change proposals we recognise the importance of public safety and place that first but in line with Government and CAA policy we expect airspace to be utilised in a safe and eYcient manner taking into account the needs of all users. March 2009

Memorandum from the British Business & General Aviation Association (AIR 49) As part of your wider engagement with stakeholders, I am pleased to take this opportunity to submit written evidence on behalf of the 170 members of the British Business & General Aviation Association (BBGA). The BBGA’s members are engaged in a wide variety of activities within the General Aviation sector; including the operation of aircraft, maintenance, handling, airfield operation and insurance, among others. Our aircraft-operating membership is almost exclusively made up of companies which use their aircraft as workhorses; either to train pilots or as a means to increase the eYciency of their own or their client’s main business. The businesses that our members operate are not extravagant or run on a “money-no-object” basis; they are businesses operating on margins comparable with other areas of industry, and either competing against foreign companies for work throughout Europe, or using their aircraft as a productivity tool for their own management team. A European Commission paper entitled “An Agenda for Sustainable Future in General and Business Aviation” published on 11 January 2008 has been provided to Government personnel and gives an idea of the important role which the commission recognises is performed by General and Business Aviation. The 2003 White Paper understandably focused on the role of Air Transport in an ever more congested world. Looking back at the document today, it is apparent that the role of Business & General Aviation was in a large part overlooked. During the same time period, valuable Business & General Aviation has continued to be displaced from congested hubs in favour of scheduled Air Transport services, on the Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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principle that “a full aircraft is an eYcient aircraft.” BBGA takes issue with this underlying sentiment, and believes that the United Kingdom needs to start challenging these perceived truths, and start to legislate to protect access to scarce resources by all users. There is a consultation currently concerning the likelihood of London City Airport, a key Business Aviation hub, becoming fully co-ordinated. This will have direct impact on the City of London and our country’s ability to generate wealth as we seek to recover from the present economic downturn. Luton is next, where today Business Aviation traYc makes up more than 22% of the movements. The large air carriers and the operators of the airport terminal shopping malls have scored a march on the small but comparatively far more valuable Business Aircraft user, and it is important to redress this imbalance. It seems anachronistic that a scheduled carrier laden with party-goers destined for a cheap weekend in Prague should have the legal right to displace traYc of far greater net worth to the British economy, but that is the case today. In terms of airspace utilisation, our membership is ready and equipped to take advantage of the latest technologies and infrastructure improvements. These changes typically occur at a much slower pace than we would like. The introduction of 8.33kHz spacing for VHF comm radios is a case in point: All aircraft above FL245 have been required to carry this equipment in Europe since 1999, and yet the first UK 8.33kHz frequency was not introduced until 2005. Time and again, it seems as if the users are forced to “invest” in infrastructure improvements, which for one reason or another turn out to be illusory at best or non-existent at worst. The current SES programme is vital for European airspace eYciency, and should be accelerated by EU Member States.

Summary UK Aviation policy has been inattentive to the needs of Business and General Aviation for too long. To redress this imbalance, BBGA makes twelve key recommendations, as follows: 1) Economic value (including induced value) should be at the heart of every UK aviation policy decision. 2) Congested UK airspace should be addressed in an integrated fashion with those of its neighbours to enable rapid eYciency improvements. 3) Business & General Aviation should be given access rights to scarce resources which could then in turn be used as a model to protect low-cost carriers as Cap and Trade starts to impact their business model. 4) Airport capacity limits should be set with the primary aim of maximising the eYciency of the Air TraYc System. 5) A systematic, cross-functional approach to airspace safety should be undertaken, with a data- driven approach to improving safety statistics. 6) The United Kingdom should re-double its eVorts to drive up European Airspace eYciency metrics through the SES programme as executed by EuroControl. 7) The UK government should make it clear to the electorate that “lifestyle” consultation responses will be of progressively lower value in the decision process in order to speed up attainment of environmental goals. 8) Government should speed the IPC and give it a clear brief including strategic principles for General Aviation and associated assets. 9) The UK should adopt a clearer, risk-sharing, approach to airspace eYciency initiatives, with the UK provider bearing financial risk in the event that promised eYciencies do not materialise despite investment by users and the agencies concerned.

1. What changes to the management of airspace could be required as a result of the additional airport capacity outlined in the 2003 White Paper? Are the White Paper’s projections for increased passenger demand still accurate? Are all the measures to provide for increased passenger demand likely to be implemented? Business Aviation comprises about 8% of (IFR) traYc in Europe. Recently, a Communication from the European Commission entitled “An Agenda for a Sustainable Future in General and Business Aviation” dated 11 January 2008 COM (2007) 869 Final stated that “General and Business Aviation provides closely tailored, flexible, door to door transportation for individuals, enterprises and local communities, increasing mobility of people, productivity of businesses and regional cohesion”. As such, Business & General Aviation operates from a range of airports and aerodromes transporting people and goods directly between the two ends of their journey. For Business Aviation to function eYciently, it must have equitable access to all airports and the airspace must be managed with maximum eYciency as its goal. And yet, in the UK we see airport capacity limits being set no in relation to what makes sense from an airspace design point-of-view, but purely from the point-of-view of what makes sense to people living around an airport. The recent decision backing the expansion of Stansted Airport, General Aviation less than 10 seats was handed an arbitrary limit of 10,000 movements which was inserted by local government Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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representatives without consultation and without any clear reason for doing so. That GA can be marginalised at the hands of local government without the DfT being aware is a result of not having an inclusive plan for access to scarce resources by all forms of aviation. In the mid-term, it seems unavoidable that significant investment will have to be made to improve the eYciency of some UK airspace nearing its capacity limits. For example the London TMA is already at its limits at some periods. Single European Skies is designed to improve the interoperability of adjacent airspace blocks, and it seems sensible to press ahead with these advanced navigational capabilities without delay. In the light of governmental targets for climate change mitigation, it is likely that long-term aviation traYc projections will have to be scaled back. At some stage, we as a society will have to decide whether we are content to allow only the richest to travel by air, or whether a more equitable sharing of resources is possible. BBGA would like to see this equitability addressed now in terms of airport access and airspace design. Once appropriate ratios are arrived at for all users to share scarce resources, they could all be scaled back as necessary to meet environmental obligations. Recommendation 1: Economic value (including induced value) should be at the heart of every UK aviation policy decision. Recommendation 2: Congested UK airspace should be addressed in an integrated fashion with those of its neighbours to enable rapid eYciency improvements. Recommendation 3: Business & General Aviation should be given access rights to scarce resources which could then in turn be used as a model to protect low-cost carriers as Cap and Trade starts to impact their business model. Recommendation 4: Airport capacity limits should be set with the primary aim of maximising the eYciency of the Air TraYc System

2. Can safety be maintained as airspace is increasingly utilised? Is there a suitable interface between military and civilian arrangements for Air TraYc Control?

The UK can be justifiably proud of its ATC safety record, including the interface between civil and military control. The forthcoming ATSOCAS changes will further improve the interface in areas outside Controlled Airspace, and the work of NATS and the CAA in this area is to be applauded. However, in some areas it is apparent that the views of industry concerning safety are ahead of the authorities; for example, the following are established BBGA positions on safety: — The mandatory carriage of TCAS II / ACAS in congested airspace, regardless of aircraft weight. — The mandatory requirement for two-crew operation of complex aircraft in congested airspace. — The introduction of high-performance procedures to suit business jets arriving and departing at airports. — The redesign of airspace to harmonise transition altitudes. The adoption of the four points above would significantly enhance operational safety for all users of congested airspace, and should be addressed in a cross-functional manner involving industry and the various agencies involved. We would encourage a systematic approach to safety in UK airspace, and an approach to apply six sigma methodologies across the functions involved in safety regulation, airspace design and aircraft operation. Recommendation 5: A systematic, cross-functional approach to airspace safety should be undertaken, with a data-driven approach to improving safety statistics.

3. Is the current approach to planning and regulating the use of UK airspace adequate? Would an Airspace Master Plan covering the period of the White Paper be beneficial? Could a piecemeal approach to individual developments necessitate additional redesigns subsequently?

The UK, taken individually, manages its airspace well. However, times are changing and a new approach is necessary for airspace management. Increasingly, the interface between UK airspace and those of neighbouring Member States are the bottleneck for eYciency improvements, and it is here, as part of a EuroControl / SES initiative that the UK should focus its eVorts. Recommendation 6: The United Kingdom should re-double its eVorts to drive up European Airspace eYciency metrics through the SES programme as executed by EuroControl. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [O] PPSysB Job: 412381 Unit: PAG7

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4. How are the eVects and aircraft noise taken into account when changes are made to the use of airspace? Who should be consulted about such changes? How should the balance between conflicting interests be struck? BBGA’s belief is that recent consultations have been well-run and fully inclusive. The care taken with the recent TC North consultation really underlines that point. However, it will become necessary, in order to meet CO2 targets adopted by government, increasingly to override the ‘lifestyle’ views of consultees in the interests of the greater good of reducing climate change. These unavoidable consequences of government policy relate to all aspects of human activity and not just aviation, and should be made clear to the population as a whole without delay. Recommendation 7: The UK government should make it clear to the electorate that “lifestyle” consultation responses will be of progressively lower value in the decision process in order to speed up attainment of environmental goals.

5. How does the management of airspace in the rest of Europe aVect flights into the UK? Is there an opportunity to integrate our plans for changes to airspace management more eVectively with those of other European countries? The design, planning and management of airspace in Europe needs to move towards increased levels of integration, including integration across national boundaries. The European Commission has made it clear that it will not accept national “interests” to override the creation of eVective and widespread Functional Airspace Blocks (FAB’s) which are widely accepted to be the primary method of driving airspace utilisation eYciency up, and user costs down. Airspace users are impatient for these changes, and look to national governments to speed the long-awaited improvements to international airspace design.

6. What opportunities are there to apply new techniques and technologies to reduce wasteful flying on indirect routes and excessive “stacking” while planes wait to land? How can the potential of any such opportunities best be realised? Could environmental benefits be gained as a result of such improvements? Clearly there is a major role for technology to improve eYciency and reduce environmental impact of aviation. The following areas of focus are the most important: — The adoption and use of Required Time of Arrival (RTA) as a collaborative tool to sequence arriving traYc, especially long-haul flights. — A seamless approach to flow management including all aspects of the journey, gate-to-gate and across international borders. — The application of user-defined trajectories for the enroute phase of flight.

7. In relation to the redesign of UK airspace, is the allocation of the roles and responsibilities of each of the interested parties—Department for Transport, the CAA, airport operators, NATS, etc—appropriate and clearly understood? Are the structures of the parties appropriate for undertaking the roles that they should play? BBGA’s belief is that there should be greater strategic cohesion between the domestic agencies listed. For example, no one is clearly tasked with safeguarding aerodromes with the result that many are facing threats from development on or near the site of the aerodrome. There is no plan relating to the distribution of aerodromes and how they should interface with airspace to make maximum use of available capacity, with the result that we as a country will almost certainly not end up with an optimally designed airspace infrastructure. A more inclusive version of the White Paper analysing the entire inventory of the nation’s assets would be welcomed by this association. As stated above, the future of an eYcient airspace infrastructure is increasingly going to have to look outside our national borders for solutions, and it is here that linkages need to be greatly improved. EuroControl should be required to coordinate national ATC agencies in such a way that the eYciency of the network as a whole is optimised.

8. Do airspace management considerations delay the planning processes in relation to airport development proposals? How will airspace management considerations be taken into account by the proposed new Infrastructure Planning Commission and the relevant National Policy Statements on airport planning? Airspace management considerations seem to play at best a minor role in airport development proposals. The Infrastructure Planning Commission must be independent from Government, but set within a clear national policy framework. This framework is largely absent outside the largest airfields and scheduled carriers. Establishing a national spatial infrastructure plan that includes the needs of General and Business Aviation will be key to establishing where major projects will be located and why. This must be linked into airspace considerations, as aviation infrastructure consists of both land and air assets. Processed: 06-07-2009 18:47:00 Page Layout: COENEW [E] PPSysB Job: 412381 Unit: PAG7

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The Farnborough airport situation is a case in point. Its owners have clearly invested millions of pounds into the development of perhaps Europe’s finest and most modern Business Aviation terminal. And yet, it operates under movement limitations dating back to its days as a military establishment and decided in isolation from any airspace considerations. Clearly, if the UK is serious about multi-modal sustainable transportation policy, this is nonsensical. It is BBGA’s hope that the IPC can address this situation. Recommendation 8: Government should speed the IPC and give it a clear brief including strategic principles for General Aviation and associated assets.

9. What could be the implications for smaller airfields, recreational flying and helicopters of changes to airspace management to enable safe and eYcient increases in capacity at the UK’s major airports? How should an appropriate balance between conflicting priorities be determined? If traYc is to increase at major airfields, the requirement for controlled airspace will certainly increase. The impacts to recreational and other users can be mitigated to some extent by adopting new technologies and procedures. Appropriate balance between conflicting priorities should be resolved through a value test. The majority of airline passengers are engaged in a leisure activity (vacation), comparable to the leisure pilots in GA. At some future stage we are going to have to invent a method of comparing the value and desirability of these and other activities which compete for a share of finite resources, be they infrastructural or actual. A low cost airline carrying passengers for one Euro each way does not contribute much to the National economy beyond the value of the fuel they burn.

10. Will it be possible to recruit and train staV in order that airspace changes can be implemented in parallel with additional airport capacity? Yes.

11. Who should fund airspace changes? Is there likely to be enough funding to undertake the redesign required to bring about the necessary additional airspace capacity? Recent events have clearly shown than anything is aVordable if there is suYcient will to do so. To date, users have funded airspace development and design through user fees, and there is no reason to assume that this principle will change in a wholesale fashion. However, the returns to users in the form of promised savings and eYciency gains have often been overstated at best or non-existent at worst. This needs to be addressed so that the agency/ies making commitments to eYciency improvements have more tangible commitment to a successful outcome. This could be in the form of a charging cap imposed in a similar fashion to rail operators which fail to meet standards agreed with their regulator. At the light end of the operational spectrum, the Australian experience with ADS-B is worthy of study. In that case, the Australian government decided to share some of the cost-savings resulting from the decommissioning of radar stations to fund the adoption of Mode S ADS-B systems into light aircraft, which operationally would not have benefitted from the adoption of ADS-B, thus removing the last obstacle to the decommissioning of the radars and allowing the consequent cost-savings. This seems to be a pragmatic solution to a cost-benefit imbalance, which is worthy of imitation. Recommendation 9: The UK should adopt a clearer, risk-sharing, approach to airspace eYciency initiatives, with the UK provider bearing financial risk in the event that promised eYciencies do not materialise despite investment by users and the agencies concerned. Thank you for this opportunity to provide input into the future of Airspace in the UK. We very much hope that our response above indicates the level of thought that the BBGA has given to the topic, and look forward to engaging in further dialogue in due course. March 2009

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