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Walney TMZ – Airspace Change Proposal
Date: 5 March 2015 (Redacted 9 Jan 2017) Author: Revision: Issue 3 (Redacted) Osprey Ref: 70791 019
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Document Details
Reference Description
Document Title Walney TMZ – Airspace Change Proposal
Document Ref 70791 019
Issue Issue 3 (Redacted)
Date 5 March 2015 (Redacted 9 Jan 2017)
Client Name DONG Energy
Classification Nil
Approval Level Authority Name
Author Osprey CSL
Internal Approval Osprey CSL
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Executive Summary
DONG Energy Walney Extension UK Ltd (DONG Energy) plans to develop an extension to the existing operational Walney Offshore Wind Farms in the Irish Sea. The Walney Extension Offshore Wind Farm will cover an area of 145 kilometres (km)2 and have an estimated generating capacity of up to 750 Mega Watts (MW). The project development site will be located west of the operational wind farms, approximately 33 km (17.8 Nautical Miles (NM)) northwest of the Fleetwood and Blackpool coast, and 31 km (16.7 NM) east from the Isle of Man.
The Issue The operation of the Walney Extension Wind Turbine Generators (WTGs) would affect BAE Systems Warton (Warton) Aerodrome flying and Air Traffic Service (ATS) operations and potentially those of BAE Systems at Barrow/Walney Island Aerodrome, with the most significant effect being the detection of the Walney Extension WTGs by the Warton Primary Surveillance Radar (PSR).
WTGs located within PSR coverage can present themselves as a large number of reflecting moving targets to the radar, which look very similar to aircraft radar returns. These false radar returns (also known as ‘clutter’) displayed on the radar screen can be confusing to air traffic controllers, which has the potential to erode levels of effectiveness and efficiency for the provision of air traffic services to aircraft flying in the area of the Walney Extension Offshore Wind Farm.
DONG Energy are working with Warton to identify a mitigation to the effect of the WTGs on the PSR which will enable the Walney Extension WTGs to be built without affecting Warton flying operations.
Proposed solution In developing the plans to resolve the issues described above, DONG Energy and Warton have considered a variety of options to determine how best to meet the needs of Warton, and Barrow/Walney Island Aerodrome, as well as other aviation and non-aviation stakeholders.
Warton’s preferred solution is to establish a Transponder Mandatory Zone (TMZ1) around the Walney, West of Duddon Sands (WoDS), Ormonde and Barrow operational Wind Farms and
1 A TMZ is defined by the CAA as “a volume of airspace where aircraft wishing to enter or fly within the defined area will be required to have and operate secondary surveillance radar equipment”. TMZs are notified for the purposes of Article 39(2) of the Air Navigation Order 2010.
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Walney Extension up to Flight Level (FL)100 (10,000 ft), to be active during the Warton Lower Airspace Radar Service (LARS) provision times2. The proposed TMZ (outlined in green) is illustrated in Figure 1 below.
The existing operational WTGs of Walney, Ormonde and Barrow do not affect the Warton PSR; however, the operational WoDS WTGs do affect3 the Warton PSR with extensive ‘clutter’ in the area of the Wind Farm. For the purposes of this document, these wind farms are therefore collectively referred to herein as the Morecambe Bay Offshore Wind Farms. It would be difficult for a pilot to make a visual distinction between the existing Morecambe Bay Offshore Wind Farm turbines and those of the planned Walney Extension Offshore Wind Farm. Therefore, from an airspace user’s visual perspective, DONG Energy and Warton consider that if mitigation involves a change to local airspace arrangements, then it is simpler to encompass all WTGs in the immediate area within an airspace boundary.
Figure 1 Walney Proposed TMZ Reproduced from CAA digital map data © Crown copyright 2014. UK IAIP ENR
2 Monday to Thursday 07:30 – 19:00, Friday 07:30 – 17:00 (local time). 3 Subsequent to previous issues (1 and 2) of this document, it can now be shown that there is an impact, in the form of ‘clutter’, on the Warton PSR due to the presence of WoDS WTGs.
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The proposed establishment of the TMZ is one element of a 3-part Mitigation Package aimed at negating the effect of the clutter from the Walney Extension Offshore WTGs upon the Warton PSR. The three parts are:
Element 1: Establishment of a TMZ; Element 2: Authorisation to control Secondary Surveillance Radar (SSR4)-only and; Element 3: Suppression of PSR returns within the boundary of the Walney Extension Offshore and WoDS Wind Farms.
The authorisation to control using SSR-only would be determined by the UK Civil Aviation Authority (CAA) in parallel to the TMZ Regulatory Approval. The PSR returns from the WTGs can be supressed in a number of ways including blanking of the PSR, or more sophisticated methods.
This document outlines the proposal from DONG Energy to maintain the effectiveness and efficiency of the airspace surrounding the Morecambe Bay Offshore Wind Farms by mitigating the effects of the WTGs on BAE Warton and Barrow/Walney Island Aerodrome flying operations and BAE Warton PSR-based ATS operations.
Consultation NATMAC members plus selected additional stakeholders were directly consulted. In addition, general public consultation was undertaken by publication of the consultation material on the DONG Energy website. A list of identified stakeholders is at Annex A5 (individual members of the public who submitted unsolicited comments are not listed). The purpose of the consultation was to seek primarily industry comment on DONG Energy’s proposal and to refine this accordingly prior to implementation.
4 SSR is a radar system used in Air Traffic Control (ATC) that not only provides controllers with azimuth position information, but also requests additional information from the aircraft itself such as its altitude.
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Contents
1 Glossary 9
2 Introduction ...... 15
2.1 General 15 2.2 Purpose and Objectives ...... 16 2.3 Consultation ...... 17 2.4 Related Documents ...... 17 2.5 Document Structure...... 18
3 The Need for an Airspace Change Proposal ...... 19
3.1 Overview 19 3.2 General flying operations at Warton Aerodrome ...... 19 3.3 Justification for the Airspace Change Proposal ...... 20
4 Proposed Design ...... 24
4.1 Overview 24 4.2 Option 0 – Do nothing ...... 24 4.3 Option 1 – A PSR solution ...... 24 4.4 Option 2 – A Radio Mandatory Zone (RMZ) ...... 25 4.5 Option 3 – A Secondary Surveillance Radar (SSR)-only Service ...... 25 4.6 Option 4 – Primary Surveillance Radar (PSR) blanking or Non-Auto Initiation Zone (NAIZ) only 25 4.7 Option 5 – A Radio Mandatory Zone (RMZ) with associated PSR Suppression Techniques ...... 26 4.8 Option 6 – A Transponder Mandatory Zone (TMZ) with associated PSR Suppression Techniques 26 4.9 The Proposed TMZ ...... 27
5 Impact of the Proposed TMZ ...... 31
5.1 Overview 31 5.2 Impact of the TMZ on military operations ...... 31 5.3 Impact of the TMZ on light GA operations ...... 31 5.4 Impact of the TMZ on offshore helicopter operations ...... 32
6 Environmental and Economic Considerations of a TMZ ...... 34
6.1 Overview 34
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6.2 Impact of noise ...... 34
6.3 Anticipated level of fuel burn/CO2 emissions ...... 34 6.4 Anticipated effect on local air quality...... 35 6.5 Environmental implications ...... 35
7 Consultation Response Analysis ...... 36
7.1 Overview 36 7.2 Consultation summary ...... 36 7.3 Consultee organisations...... 37 7.4 Response analysis ...... 38 7.5 Meetings with Major Stakeholders ...... 39 7.6 Consultation support ratio ...... 39 7.7 Objection 40 7.8 Isle of Man Airport PSR Concerns ...... 41 7.9 Confidentiality ...... 41 7.10 Publication...... 41
8 References ...... 42
A1 Walney Extension Offshore Wind Farm Line of Sight Assessment ...... 43
A1.1 Overview ...... 43 A1.2 Boundary Details ...... 43 A1.3 Boundary Graphic ...... 44 A1.4 LoS Assessment Methodology ...... 44 A1.5 LoS Assessment Results ...... 45 A1.6 Conclusion ...... 46
A2 West of Duddon Sands Line of Sight Assessment ...... 47
A2.1 Overview ...... 47 A2.2 Boundary Details ...... 47 A2.3 Boundary Graphic ...... 48 A2.4 LoS Assessment Methodology ...... 48 A2.5 LoS Assessment Results ...... 48 A2.6 Conclusion ...... 49
A3 Proposed TMZ Co-ordinates ...... 50
A4 Consultation Background and Methodology ...... 52
A4.1 Background to the Consultation ...... 52 A4.2 Method of Consultation ...... 52
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A5 Stakeholder / Consultee List ...... 54
A5.1 Aviation Consultees ...... 54 A5.2 Aerodromes / Local Aviation Consultees ...... 56 A5.3 Non-Aviation Consultees: National Bodies ...... 56 A5.4 Non-Aviation Consultees: Regional Council Authorities ...... 57 A5.5 Non-Aviation Consultees: Council Wards / Local Authorities ...... 57 A5.6 Information Organisations: Members of Parliament ...... 58 A5.7 Information Organisations: Civil Aviation Authority ...... 59
Table of Figures Figure 1 Walney Proposed TMZ ...... 4 Figure 2 Location of BAES Warton in relation to the proposed TMZ ...... 21 Figure 3 Walney TMZ Proposal including the internal 2 NM Buffer Zone ...... 29 Figure 4 Distribution of Consultees ...... 38 Figure 5 Responses from Listed Consultees ...... 39 Figure 6 Support Ration from Listed Consultees...... 40 Figure 7 Illustration of the Walney Extension Boundary Points ...... 44 Figure 8 LoS Profile between Warton (PSR) and Point 5 ...... 46 Figure 9 Illustration of the WoDS Boundary Points ...... 48 Figure 10 LoS Profile between Warton (PSR) and Point 4 ...... 49
Table of Tables Table 1 Responses from Consultees ...... 38 Table 2 Table of References ...... 42 Table 3 Summary of Turbine/Boundary Details ...... 43 Table 4 Summary of Turbine/Boundary Details for WoDS LoS Assessment ...... 47 Table 5 Proposed Walney TMZ Co-ordinates ...... 51 Table 6 Proximity of the Proposed TMZ to Local Military and Civilian Aerodromes ...... 51
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1 Glossary
Acronym Meaning
AAIB Air Accident Investigation Board
AARA Air-to-Air Refuelling Area
ACC Airport Consultative Committee
ACP Airspace Change Process
ACAS Airborne Collision Avoidance System
AEF Air Experience Flight
agl above ground level
AIP Aeronautical Information Publication
AIRAC Aeronautical Information Regulation and Control
ANO Air Navigation Order
AOA Airport Operators Association
AOPA Aircraft Owners and Pilots Association
AR Airspace Regulation
ARA Advisory Radio Area
amsl above mean sea level
ATC Air Traffic Control
ATM Air Traffic Management
ATSOCAS Air Traffic Service Outside Controlled Airspace (now UK
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FIS)
ATS Air Traffic Service
ATSU Air Traffic Service Unit
BAA British Airports Association
BABO British Association of Balloon Operators
BALPA British Airline Pilots’ Association
BATA British Air Transport Association
BBAC British Balloon and Airship Club
BBGA British Business and General Aviation Association
BGA British Gliding Association
BHA British Helicopter Association
BHPA British Hand Gliding and Paragliding Association
BIA Blackpool International Airport
BMAA British Microlight Aircraft Association
BMFA British Model Flying Association
BPA British Parachute Association
CAA Civil Aviation Authority
CAP Civil Aviation Publication
CAS Controlled Airspace
CAT Commercial Air Transport
CO2 Carbon Dioxide
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CTA Control Area (Class D UK Airspace)
DAATM Defence Airspace and Air Traffic Management
Directorate of Airspace Policy (part of the CAA – now DAP SARG)
DIO Defence Infrastructure Organisation
DfT Department for Transport
DS Deconfliction Service
ELFAA European Low Fares Airline Association
FIS Flight Information Services
FJ Fast Jet
FL Flight Level
ft feet
GA General Aviation
GASCo General Aviation Safety Council
GAT General Air Traffic
GAPAN Guild of Air Pilots and Air Navigators
GATCO Guild of Air Traffic Control Officers
HCGB Helicopter Club of Great Britain
HQ DAAvn Headquarters Director Army Aviation
IAIP Integrated Aeronautical Information Package
IFP Instrument Flight Procedure
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IoMA Isle of Man Airport
km kilometre
kts knots
LAA Light Aircraft Association
LACC London Area Traffic Control Centre
LARS Lower Airspace Radar Service
LJLA Liverpool John Lennon Airport
LoA Letter of Agreement
LoS Line of Sight
m metre
MAA Military Aviation Authority
MoD Ministry of Defence
MSSR Monopulse Secondary Surveillance Radar
MTWA Maximum Total Weight Authorised
MW Mega Watt
NAIZ Non-Automatic Initiation Zone
NATMAC National Air Traffic Management Advisory Committee
National Air Traffic Service
NATS Provider of en-route air traffic services in the Scottish and London Flight Information Regions and at some civil airports.
NERL NATS En-Route Ltd
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NCHQ Navy Command Head Quarters
NM Nautical Mile
NOTAM Notices to Airmen
NO2 Nitrogen Dioxide
OS Ordnance Survey
PINS Planning Inspectorate
PSR Primary Surveillance Radar
RAF Royal Air Force
RMZ Radio Mandatory Zone
SARG CAA Safety and Airspace Regulation Group
ScACC Scottish Area Control Centre
SSR Secondary Surveillance Radar
TMZ Transponder (SSR) Mandatory Zone
UAS University Air Squadron
UAV Unmanned Air Vehicles
UKAB UK Airprox Board
UKFSC UK Flight Safety Committee
VFR Visual Flight Rules
VGS Volunteer Gliding Squadron
VHF Omni Directional Radio Range; a type of short-range VOR radio navigation system for aircraft
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WAL Wallasey VOR
WoDS West of Duddon Sands
WTG Wind Turbine Generator
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2 Introduction
The operation of the Walney Extension Offshore Wind Farm would affect BAE Systems Warton Aerodrome flying and Air Traffic Service (ATS) operations, and Barrow/Walney Island Aerodromes flying operations, with the most significant impact being the detection of the WTGs as unwanted clutter by the Warton Primary Surveillance Radar (PSR). DONG Energy and BAE Systems have worked together to identify a suitable mitigation which will enable the Walney Extension Wind Farm WTGs to be built without affecting Warton flying operations.
2.1 General DONG Energy Walney Extension Ltd (DONG Energy) wishes to develop an extension to the existing Walney Wind Farms, referred to as the Walney Extension Offshore Wind Farm. The project development site will be located West of the operational Walney Wind Farms (1 and 2) and the operational offshore wind farms in the Irish Sea to the North West of Morecambe Bay, approximately 33 kilometres (km) (17.8 Nautical Miles (NM)) northwest of the Fleetwood and Blackpool coast, and 31 km (16.7 NM) from the Isle of Man.
The presence of the Walney Extension Wind Turbine Generators (WTG) would affect BAE Systems Warton Aerodrome flying and Air Traffic Service (ATS) operations and potentially BAE Systems operations at Barrow/Walney Island Aerodrome; thereby requiring a change to the arrangements and procedures in the immediate airspace surrounding the Wind Farms.
WTGs located within PSR coverage can present themselves as moving targets to the radar, which look similar to aircraft radar returns. These false radar returns (‘clutter’) displayed on the radar screen can be confusing to air traffic controllers and has the potential to erode levels of effectiveness and efficiency for provision of air traffic services to aircraft flying in the area of the Morecambe Bay Offshore Wind Farms.
False radar returns may cause disruption by forcing air traffic controllers to take unnecessary action in order to maintain radar separation in accordance with Civil Aviation Authority (CAA) regulations. Hence, any loss of radar performance in this area, along with any misleading or unnecessarily distracting displayed radar information, has the potential to erode the effective and efficient use of the airspace in the area of the Walney Extension Offshore Wind Farm as well as the wider area of the Morecambe Bay Offshore Wind Farms.
Analysis completed as part of the Planning Application for the Walney Extension Offshore Wind Farm concludes that it is highly likely that the Warton PSR will detect all WTGs located within the planned Extension area. Annexes A1and A2 provide example theoretical radar Line of Sight
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(LoS) profiles for the Warton PSR looking towards the Walney Extension Offshore and West of Duddon Sands (WoDS) Wind Farms. The Walney Extension Offshore WTGs are expected to be detectable to the Warton PSR and the recently operational WoDS WTGs are detectable5 to the Warton PSR showing as extensive ‘clutter’ in the area of the Wind Farm.
The existing operational Walney 1 and 2, Ormonde and Barrow Wind Farms do not affect the Warton PSR, as the wind turbines are smaller than those planned for the Extension and not detectable. However, whilst the existing operational turbines do not affect the Warton PSR, from an airspace user’s visual perspective DONG Energy and Warton consider that if mitigation involves a change to local airspace arrangements, then it is simpler to encompass all WTGs in the immediate area. It would be difficult for a pilot to make a visual distinction between the existing Morecambe Bay Offshore Wind Farm WTGs and those of the planned Walney Extension.
The degradation in the detection and tracking capabilities of the Warton PSR in the area of the Walney Extension is of particular importance with regard to the flight test area in which the Wind Farm is centred. The airspace within the vicinity of the proposed site is uncontrolled Class G and is regularly used by aircraft from Warton, as it provides a sufficient volume of airspace away from airways and other Controlled Airspace (CAS), for the evaluation and testing of advanced air systems.
If there was a reduced or limited ATS provision from Warton Air Traffic Control (ATC) in the area of the Walney Extension turbines, it would significantly restrict Warton’s current operations in the Irish Sea. Other airspace users requiring a service from Warton ATC may also experience disruption due to unnecessary route deviation in the absence of the TMZ.
Extensive work to determine a solution to mitigate the potential effect of the turbines on the ATS provided by Warton has been undertaken by DONG Energy and Warton. It has been determined that the introduction of a Transponder Mandatory Zone (TMZ) over the Morecambe Bay Offshore Wind Farms will mitigate the effects of the detection of wind turbines by the Warton PSR. Any change to airspace constructs requires adherence to CAP 725 [Reference 1] and the Airspace Change Process (ACP). DONG Energy is the sponsor of this airspace change and has engaged Osprey Consulting Services Ltd (Osprey) to manage the process on their behalf.
2.2 Purpose and Objectives The purpose of this document is to provide information regarding the proposal to establish a TMZ over the Morecambe Bay Offshore Wind Farms to mitigate the effects of the detection of WTGs by the Warton PSR, because of the operation of Walney Extension. Osprey, on behalf of DONG Energy and Warton and in accordance with CAP 725 [Ref 1], has prepared the document.
5 Subsequent to previous issues (1 and 2) of this document and the theoretical study at Annex A2, it can now be shown that there is an impact, in the form of ‘clutter’, on the Warton PSR due to the presence of WoDS WTGs.
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The objectives of the document are to:
Provide the background to the Airspace Change Proposal; Describe the operations at Warton Aerodrome and how these may be affected by the Walney Extension wind turbines; Detail the proposed change to the airspace over the Morecambe Bay Offshore Wind Farms; and Describe the other options considered and explain why these options were considered insufficient mitigation for the effects of the detection of unwanted wind turbine radar returns by the Warton PSR.
It is DONG Energy’s responsibility, as Sponsor of the proposed change, to consult with all relevant stakeholders who may be directly or indirectly affected by the proposal.
2.3 Consultation NATMAC members plus selected additional stakeholders were directly consulted on the proposal. In addition, general public consultation was undertaken by means of publication of consultation material on DONG Energy’s website. A list of identified stakeholders is at Annex A5 (individual members of the public who submitted unsolicited comments are not listed). The purpose of the consultation was to seek primarily aviation industry comment on DONG Energy’s proposal and to refine this accordingly prior to implementation. Such refinement would result in a reshape of the airspace design.
An analysis of consultation responses is presented in Section 7 of this document.
2.4 Related Documents Request for SSR-Only Control within the proposed Walney TMZ, Issued by BAES Warton to SARG Stirling, (Osprey, 70791 023).
Walney TMZ Consultation Document (Osprey, 70791 009).
Walney TMZ FAQs (Osprey, 70791 012).
Walney TMZ Consultation Record (Osprey, 70791 021).
Walney TMZ Safety Program Plan (Osprey, 70791 015).
Walney TMZ Safety Case Part1 (Osprey, 70791 017).
Walney TMZ Interim Consultation Report (Osprey, 70791 018).
Walney TMZ Final Consultation Report (Osprey, 70791 020).
Walney TMZ Traffic Survey (Osprey, 70791 022).
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2.5 Document Structure This document contains eight main sections and five Annexes, outlined below for convenience:
Section 1 provides a glossary; Section 2, this section, introduces the document; Section 3 describes the necessity for an ACP; Section 4 gives an overview of the proposed design option; Section 5 assesses the impact of the proposed TMZ; Section 6 details the environmental and economic considerations; Section 7 analyses the consultation responses; and Section 8 provides a list of references.
There are five Annexes:
Annex A1 details the radar LoS assessment for the Walney Extension Offshore Wind Farm; Annex A2 details the radar LoS assessment for the WoDS Wind Farm; Annex A3 provides the co-ordinates of the proposed TMZ; Annex A4 describes the consultation background and methodology; and Annex A5 lists the Consultees.
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3 The Need for an Airspace Change Proposal
Warton ATC operates under regulatory oversight of both the Military Aviation Authority (MAA) and the CAA, providing essential ATS to military and civil aircraft in the area of the Morecambe Bay Offshore Wind Farms.
3.1 Overview This section describes the background relevant to this Airspace Change Proposal by providing an overview of flying operations at Warton and by highlighting the primary areas of concern relating to the effects of the Walney Extension Offshore Wind Farm on Warton operations.
In this case, there are three principal issues to be considered: Test flying operations in the area of the Irish Sea; services to aircraft under the Lower Airspace Radar Service (LARS) scheme; the provision of an Approach Control Service to both Warton and Barrow/Walney Island Aerodromes.
3.2 General flying operations at Warton Aerodrome A range of military and civilian aircraft operate from Warton aerodrome. The Airfield carries out, on average, around 1,000 aircraft movements per month, 40% of which are military registered flights, in support of the following operational tasks:
Flight development and test activities, predominantly on Typhoon, Tornado and Hawk aircraft, which can include civilian test support aircraft operations; Production test flying of brand new Typhoon (and soon to be Hawk) aircraft that are manufactured on site; Daily commercial passenger flying operations; Military and civilian transport operations; National Police Helicopter operations; and Flying training activity on civilian and military aircraft.
Warton ATC provides aerodrome control and approach control services to a wide range of commercial, general aviation and military aircraft in the airspace over the Irish Sea and overland near Warton. In addition to these routine air traffic control tasks, Warton ATC is responsible for providing LARS to a radius of 74 km (40 NM) from Warton and a dedicated specialist service to aircraft conducting test and development flights up to (and occasionally beyond) 370 km (200 NM) from Warton. Warton ATC operates under regulatory oversight of both the MAA and the CAA. The standard ATS, the LARS and the dedicated special task/test
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flying combine to support the required efficient and effective operations of a mix of aircraft in the local and extended operating areas.
3.3 Justification for the Airspace Change Proposal As outlined above, the effect of the Walney Extension on the Warton PSR, giving rise to false radar returns will have an effect on the provision of radar services in relation to the following three tasks:
Test flying control in the vicinity of the Walney Extension; Services to aircraft under the LARS scheme when aircraft are operating outside CAS; and Approach Control Service.
These areas of concern have led to the requirement to mitigate the effects of the Walney Extension WTGs. Figure 2 below shows the location of BAES Warton in relation to the proposed Walney TMZ, the Dark Blue (Walney Extension Offshore Wind Farm) and Red (WoDS) areas shows the theoretical extent of the related wind turbine generated clutter. The Yellow outline shows the Air-to-Air Refuelling Area (AARA) 13.
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Figure 2 Location of BAES Warton in relation to the proposed TMZ (Green boundary) and AARA 13 (Yellow boundary) depicting a 2NM buffer around the entire area occupied by the Morecambe Bay Offshore Wind Farms (various block colours). Reproduced from MoD AIDU digital map data © Crown copyright 2014. UK Mil AIP ENR
Further detail is provided in the following paragraphs.
3.3.1 Flight test operations in the vicinity of the proposed TMZ
Warton’s coastal location, adjacent to extensive uncontrolled airspace, makes it an ideal site for testing, research and development of complex military aircraft. The majority of these operations take place offshore over Morecambe Bay and Liverpool Bay. The MoD, in support of front line military aviation operations, and other export customers rely on this operation for the delivery of high specification military capability. The fast jet (FJ) military aircraft conducting test and development sorties operate in accordance with predetermined schedules to ensure that appropriate test data is gathered; the test and development aircrew involved rely on Warton ATC to provide a mixture of air traffic services. In support of this, three high-speed routes have been established under a Letter of Agreement with NATS, London Area Control Centre (LACC) and Scottish Area Control Centre (ScACC). The preferred route used by Warton ATC is one that has the least effect on civil ATC operations, and therefore requires less coordination with external agencies. However, this preferred route tracks directly over the proposed TMZ area.
Additionally, AARA 13 is within the vicinity of Walney as depicted at Figure 2, with Warton as one of the three possible controlling authorities, the other being LACC. This adds to the complexity of the airspace and re-enforces the requirement for the TMZ to ensure accurate traffic information and/or avoiding action on unknown aircraft can be passed to aircraft within the refuelling area when under the control of Warton.
The Warton Advisory Radio Area (ARA) incorporates the Morecambe and Liverpool Bay areas and is notified airspace extending from Flight Level (FL)95 (9,500 feet (ft)) to FL190 (19,000 ft). Within the Warton ARA all pilots are advised to make radio contact with Warton ATC in order to receive up to date information on other traffic, specifically test and evaluation aircraft, operating in the area. To support test-flying activities Warton ATC requires an unambiguous and uncluttered ‘air picture’ of its operational airspace, which allows efficient and flexible tactical freedom for aircraft manoeuvres close to Warton and in the airspace above the Morecambe Bay Offshore Wind Farms, the area of the proposed TMZ.
Class G airspace is uncontrolled in that any aircraft may use the airspace under the Air Navigation Order and the Regulations (ANO) CAP 393 [Reference 2] and although an ATS may be available, it is not mandated; Military and General Aviation use large portions of Class G airspace below FL195 (19,500 ft) extensively. The service provided by Warton controllers to test and evaluation pilots in Class G airspace, aimed at achieving notified deconfliction minima from other traffic in Class G airspace, is a Deconfliction Service (DS). In Class G airspace, the avoidance of other traffic is ultimately the pilot’s responsibility. However, under a DS the
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controller provides the pilot with specific surveillance-derived traffic information and issues advisory headings and/or levels aimed at achieving the required deconfliction minima. The deconfliction minima required against unknown or un-coordinated traffic, or unknown radar returns (like wind turbine generated returns) are:
9.27 km (5 NM) laterally (subject to surveillance capability and regulatory approval); or 3,000 ft vertically and, unless the SSR code indicates that the Mode C data has been verified, the surveillance returns, however presented, should not merge. (Note: Mode C can be assumed to have been verified if it is associated with a deemed validated Mode A code. The Mode C data of aircraft transponding code 0000 is not to be utilised in assessing deconfliction minima).
If the Warton radar clutter induced by the Walney Extension WTGs is not addressed, Warton ATC will be required to apply 9.27 km (5 NM) separation between any aircraft in receipt of a DS and any unknown or false returns from the wind turbines, which could significantly restrict Warton’s operations in this portion of airspace.
In summary, degradation of detection and tracking capabilities of the Warton radar in the area of the Walney Extension is of importance. Habitually reduced DS from Warton ATC in the area of the Walney Extension would effectively render a large volume of the Class G airspace above the Irish Sea unusable unless pilots agree to accept a ‘limited service’ or a downgrade in service. This may not be acceptable to the pilot and under such circumstance would represent a significant reduction in the size of the Warton ARA airspace available for critical flight test activities. Other airspace users requiring a service from Warton ATC may also experience disruption due to unnecessary route deviation.
3.3.2 LARS provision
Warton ATC provides a LARS for the purpose of ensuring participating pilots are aware of other nearby aircraft and/or flying activities, thereby enhancing flight safety in the area. This service is available to any aircraft operating outside CAS, up to and including FL 100 (approximately 10,000) ft, within a 40 NM radius of Warton. The Warton LARS is active between the hours of 07:30 and 19:00 (Mon-Thu), 07:30 and 17:00 (Fri).
LARS is regarded as a very important scheme, which is sponsored by the Department for Transport (DfT) and is determined by the CAA Safety and Airspace Regulation Group (SARG) as key to enhancing the effectiveness, efficiency and safety of the airspace in an area that can be busy with a mixture of aviation activities.
A recent LARS review by DfT recognised Warton’s key role as a provider of LARS in the North West of England. The service would necessarily be reduced, limited or downgraded near the Morecambe Bay Offshore Wind Farms if the radar returns from the turbines were not mitigated.
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3.3.3 Approach Control Service
The airspace around Warton is considered to be of medium complexity6 (Reference 3) in that it is surrounded by areas of open (Class G) airspace, particularly to the west and northwest, but is bounded closely by CAS to the south and east. Warton ATC is responsible for providing services to aircraft arriving at and departing from Warton, as well as local air traffic and military aircraft involved in complex test and development flights. Warton ATC in accordance with CAP 393 [Reference 2] provides an approach control service. Warton is also the approach control unit for Barrow/Walney Island Aerodrome.
6 Can be characterised by the operation of a few CAT movements per hour and a number of flights in the airspace operating under Visual Flight Rules (VFR); the most prevalent being survey and offshore resource recovery operations and the Military.
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4 Proposed Design
Warton’s preferred solution is to establish a TMZ around the Morecambe Bay Offshore Wind Farms with associated PSR suppression of returns around the Walney Extension and WoDS Offshore Wind Farms up to FL 100 within the Warton LARS provision times.
4.1 Overview DONG Energy has considered a variety of design options in its aim to provide sufficient mitigation, whilst meeting the needs of Warton and all other aviation and non-aviation stakeholders.
The following mitigation design options were considered:
Do nothing; Implement a PSR solution; Implement a Radio Mandatory Zone (RMZ); Conduct SSR only operations; Implement PSR blanking or a Non-Automatic Initiation Zone (NAIZ) only; or Implement a TMZ with associated SSR-only operations and PSR suppression of returns.
This section provides details of the design options considered, along with results of the extensive evaluation of each.
4.2 Option 0 – Do nothing If no mitigating actions were taken for the impact of the Walney Extension Offshore Wind Farm WTGs on the Warton PSR, air traffic services provided by Warton ATC utilising the PSR would be impacted.
WTGs located within PSR coverage can reduce the ability of the radar to detect aircraft, and ATC to differentiate between a WTG return and a radar return from an aircraft. The effects are well documented and are detailed within CAP 764 (CAA Policy and Guidelines on Wind Turbines) [Reference 4].
4.3 Option 1 – A PSR solution Warton operates a Selex ES ATCR-44 ATC PSR, which is complimented by a co-mounted Mode S Monopulse SSR (MSSR), SSR and PSR data from NATS radars at Clee Hill, Great Dun Fell and Lowther Hill.
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DONG Energy and Warton have held discussions with Selex ES, the PSR Design Authority, to investigate if there are approved methods in which the PSR could be modified to enable Warton to continue to provide an ATS using the PSR in the region of the Walney Extension Offshore Wind Farm WTGs.
As yet there is no radar mitigation solution that eliminates clutter generated by WTGs, without removing PSR aircraft returns, that provides a high degree of confidence of success in every case. There are several technologies in an advanced stage of development, but yet to achieve regulatory approval. DONG Energy, Warton and the Defence Infrastructure Organisation (DIO) who safeguard operations at BAES Warton require a high degree of certainty of a successful mitigation, which is not currently available for a technical PSR solution.
4.4 Option 2 – A Radio Mandatory Zone (RMZ) A Radio Mandatory Zone (RMZ) over the Morecombe Bay WTGs would require aircraft to be in two-way communication with ATC and provide information pertinent to the flight prior to entering the designated airspace.
Although ATC would be able to provide some level of service to traffic in the area, it would not prevent WTG-generated radar returns from being displayed on the radar display, with the effect of limiting service provision as outlined previously and requiring the re-routing of aircraft under a DS around the clutter. An RMZ also permits access to aircraft that are not transponder equipped; this makes it difficult to identify them and maintain track identity for the purposes of providing traffic information and separation.
Warton has rejected this option as it provides insufficient mitigation.
4.5 Option 3 – A Secondary Surveillance Radar (SSR)-only Service The sole reliance and use of this surveillance technique, without appropriate airspace use rules in place, is not approved in the UK due to busy approach environments. However, due to the ‘small’ area of the Walney Offshore Wind Farms, it may be justifiable to use SSR-only to maintain the identity of an aircraft as it transits through the WTG development.
Warton has rejected this option alone as it does not solve the problem of being able to distinguish between primary radar returns created by the turbines and those created by non- transponding aircraft. Simply providing a service using SSR only does not prevent non- transponder equipped aircraft from entering the airspace and therefore safety could be compromised as a result of the inability to identify, track and provide separation from those aircraft.
4.6 Option 4 – Primary Surveillance Radar (PSR) blanking or Non-Auto Initiation Zone (NAIZ) only PSR blanking involves the deliberate masking of fixed areas on the radar display. This ensures that clutter caused by a WTG development is not presented to the controller. The potential
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drawback of this option is that in addition to WTG clutter, primary radar returns from legitimate aircraft are also blanked and therefore not presented to the air traffic controller.
Clutter effects can be limited by establishing NAIZ in which new tracks are prevented from initiating, whilst mature tracks are maintained and updated. A NAIZ placed over the location of a WTG development ensures that turbine blades do not create false tracks, but established aircraft tracks entering the location continue to be updated. Despite WTG returns being inhibited, there is potential for the PSR processing to confuse the two returns, and switch the association of the established aircraft track from its real radar response to that of the WTG response. Switching of track association presents false information to the air traffic controller and may cause risk to flight safety. Moreover, a NAIZ cannot identify the source of new potential tracks within the zone, and so will not enable initiation of a track on a radar response caused by an actual aircraft whose radar responses have only just begun to be received by the radar (i.e. climbing out of low level) before it enters the Wind Farm.
Warton has rejected this option as it provides insufficient mitigation.
4.7 Option 5 – A Radio Mandatory Zone (RMZ) with associated PSR Suppression Techniques A Radio Mandatory Zone (RMZ) over the Morecombe Bay WTGs would require aircraft to be in two-way communication with ATC and provide information pertinent to the flight prior to entering the designated airspace.
Although ATC would be able to provide some level of service to traffic in the area; all PSR returns would be reduced in intensity or removed. The potential drawback of this option is that in addition to WTG clutter the primary radar returns from legitimate aircraft are also not fully presented to the air traffic controller thus making it difficult to identify aircraft and maintain track identity for the purposes of providing TI and separation. Furthermore, a RMZ also permits access to aircraft that are not transponder equipped and would not provide the added advantage of situational awareness to other airspace operators, with collision avoidance mitigation, through the cooperative use of Airborne Collision Avoidance System (ACAS).
Warton discounted this option, it been little better than option 2 in that it provides insufficient mitigation.
4.8 Option 6 – A Transponder Mandatory Zone (TMZ) with associated PSR Suppression Techniques The proposed establishment of the TMZ is one element of a 3-part Mitigation Package aimed at negating the impact of the clutter from the Walney Extension Offshore Wind Farm WTGs upon the Warton PSR. The three parts are:
Element 1: Establishment of a TMZ; Element 2: Authorisation to control SSR-only and;
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Element 3: Suppression of PSR returns within the boundary of the Walney Extension and WoDs Wind Farms.
The proposed solution provides Warton ATC with assured positional identification and Commercial Air Traffic (CAT) operators with collision avoidance mitigation through the cooperative use of Airborne Collision Avoidance System (ACAS). It will also maintain current effectiveness and efficiency in the airspace while radar services are provided using SSR data- only in the area of the Morecambe Bay Offshore Wind Farms.
Figure 2 (section 3.3) illustrates the airspace above the Morecambe Bay Offshore Wind Farms which is Class G airspace up to FL 195.
The primary determining features for the TMZ would be:
The location of the current operational Walney 1 and 2 WTGs; The location of the planned Walney Extension Offshore WTGs; The location of the WoDS, Ormonde and Barrow WTGs; The tracking characteristics of the Warton PSR; The base of CAS above the Wind Farms or the FL above which transponder carriage is mandated in the UK; The presentation of the TMZ to Visual Flight Rules (VFR) pilots (i.e. how it is portrayed on the charts); Proximity to the coastline; and Proximity to Barrow/Walney Island Aerodrome.
4.9 The Proposed TMZ The overall aim of the Walney TMZ Airspace Change Proposal is to maintain airspace efficiency and effectiveness for all users and mitigate the impacts of the Walney Extension Offshore Wind Farm on Warton flying and ATS operations.
The CAA, in CAP 725 [Reference 1], lays down extensive regulatory requirements to be applied to the design of the airspace arrangements. However, most of these requirements, such as Instrument Flight Procedure (IFP) containment, are relevant to the development of CAS, which is not the case with this TMZ proposal. The significant regulatory requirements applicable to this proposal are that the:
Dimensions of the proposed airspace should be the minimum practicable to meet the safety and operational requirements; and Configuration of the airspace should be as simple as practicable.
Thus, the primary matters for consideration in the development of the proposed TMZ are the lateral and vertical dimensions, including alignment with other, pre-existing, airspace boundaries and the impact on:
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Those aircraft wishing to use the airspace which are not and/or cannot be equipped with a transponder; and The operational impact on adjacent Air Traffic Service Units (ATSU) who may not be SSR equipped.
The proposed solution provides Warton ATC with an informed traffic environment where each aircraft can be identified and monitored for the purpose of providing separation and traffic information. Any unknown targets that are presented without a corresponding SSR return can be assumed to be either spurious or created by the WTGs. This provides the assurance that any aircraft that are in receipt of a service within the TMZ can be positively identified and the appropriate separation can be provided between aircraft. This enhances safety since it removes any doubt that unknown primary only returns created by the turbines are assured to be turbine returns and not unknown aircraft.
Warton’s preferred solution is to establish a TMZ, with associated suppression of PSR returns within the boundary of the Walney and WoDS Offshore Wind Farms up to FL 100 within the Warton LARS provision times. The development of this option for the configuration of Transponder Mandatory Airspace is detailed in the subsequent paragraphs of this Section of the document.
4.9.1 TMZ horizontal buffer zone
In order to assure effective and expeditious ATS provision within and around the TMZ, it is considered that an additional lateral buffer, beyond the WTGs, for ATS purposes is necessary to mitigate any potential navigation error that could occur close to the area of PSR return suppression. Such a buffer zone would provide time for ATC to provide avoiding action to other aircraft close to the boundary of the TMZ, if required. Thus, it is concluded that an additional volume of airspace should be added to the surface footprint of the Wind Farms themselves to cater for TMZ infringements.
The Warton PSR requires 30 seconds to establish and display an aircraft track (6s per sweep with the track displayed on the 5th sweep). Considering the worst case scenario, where Class G General Air Traffic (GAT) can travel up to speeds of 250 knots (kts) (4 NM/min), the Warton radar would require 2 NM to create a coherent foreground track. It is therefore logical to implement a 2 NM lateral buffer zone to the footprint of the Wind Farms, in order to ensure that tracks are well initiated and known to ATC as they exit the lateral extent of the Wind Farms within the TMZ.
Due to the proximity of the existing Morecambe Bay Offshore Wind Farms to the Walney Extension, the TMZ would encompass all these wind farms. This would avoid issues with visual confusion from the air, difficulty in navigation chart interpretation and visual depiction on ATC video display screens.
Figure 3 below illustrates the airspace at Morecambe Bay, and the proposed TMZ, including a 2 NM buffer zone around each of the Morecambe Bay Offshore Wind Farms.
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Figure 3 Walney TMZ Proposal including the internal 2 NM Buffer Zone Reproduced from CAA digital map data © Crown copyright 2014. UK IAIP ENR
By way of comparison to other offshore wind farm mitigations, the TMZ around the London Array Offshore Wind Farm, administered by Southend ATC, also has a buffer zone of 2 NM beyond the lateral extent of the WTGs.
4.9.2 Vertical extent of the TMZ
It is proposed that the TMZ should extend from sea level up to FL 100 above the turbines, since transponder carriage within the airspace above is already required7.
7 Gliders have notified exemptions to this requirement.
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The co-ordinates for the fifteen corners of the proposed TMZ (with buffer zone) are given in Annex A3, together with the proximity of the TMZ to military and civilian aerodromes.
4.9.3 Hours of operation of the TMZ
Under normal UK Integrated Aeronautical Information Package (IAIP) arrangements, the operating hours of a particular airspace segment established for ATS purposes are linked to the operating hours of the associated ATS Unit. Hence, DONG Energy and Warton propose that Warton ATC is the TMZ Control Authority and TMZ activation coincides with the Warton LARS hours (Mon-Thu 0730-1900; Fri 0730-1700 Local Time). The information will be captured within the UK IAIP and Mil AIP, noting the LARS frequency and timings as well as the boundary of the TMZ, and associated CAA VFR Charts. Warton propose that exceptions to this are promulgated by Notices to Airmen (NOTAM).
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5 Impact of the Proposed TMZ
The overall aim of the Walney Airspace Change Proposal is to maintain airspace efficiency and effectiveness for all users whilst mitigating the impacts of the Walney Extension Offshore Wind Farm on Warton flying and ATS operations.
5.1 Overview A potential drawback of establishing a TMZ is that non-transponding aircraft may choose to take an alternative route in order to ‘bypass’ the TMZ, resulting in a change in traffic patterns and ATC workload in this area. This would only reasonably occur when aircraft have been unable to establish two-way radio communications with Warton ATC, the TMZ Controlling Authority.
5.2 Impact of the TMZ on military operations No impact on military operations has been identified since the majority of UK and European- based military aircraft carry and operate SSR transponders, and in most cases, these are Mode S compatible. The only UK military aircraft types that are not transponder equipped are gliders. It is considered that military gliders are unlikely to operate as far offshore as the Morecambe Bay Offshore Wind Farms and so would be unaffected by the TMZ requirements.
5.3 Impact of the TMZ on light GA operations All aircraft operating on Public Transport flights within UK airspace are required to be equipped with, as a minimum, Mode S Elementary transponders. It can be assumed that the majority of General Aviation (GA) aircraft over 5,700 kg Maximum Total Weight Authorised (MTWA) are likely to be transponder equipped: such aircraft types, which can be used for public transport operations, are likely to operate from time to time within Class A, C or D CAS, where carriage of transponders is beneficial.
Whilst not prohibited from operating over water, the majority of pilots of light aircraft (sports and recreation) prefer to minimise their over-water flight time by using routes that route predominantly overland and require them to be over water for as short a period as practicable. Warton and Barrow/Walney Island ATC note that the majority of GA working around the periphery of Morecambe Bay operate SSR transponders and follow the coastlines applying the
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Right-Hand Traffic Rule 198 (this is confirmed by a survey9 of traffic behaviour near the Walney Extension). A pilot following a line feature (a railway, road, river or coastline etc.) must fly so that the line feature is on his LEFT, unless the aircraft is flying in CAS and has been instructed otherwise by an Air Traffic Control Unit. This rule ensures separation between two aircraft following the same line feature but flying in opposite directions as both aircraft will be flying to the right of the line feature.
Notwithstanding the transponder mandate within a TMZ, provision exists within the TMZ Rules for conditional access by non-equipped aircraft by prior arrangement, establishing two-way radio contact, with the appropriate ATSU (Controlling Authority), in this case Warton ATC (and via Barrow/Walney Island ATC).
The recent traffic surveys, each of one month’s duration, undertaken at Warton of movements in and around the area of the proposed TMZ demonstrate that the large majority10 of GA (sports and recreational) aircraft were transponder equipped. Conditional access to the TMZ airspace by non-transponder equipped aircraft is available by radio and it is anticipated that the impact of a TMZ on light GA operations, including glider, microlight and balloon operations, would be minimal as these types are unlikely to be operating as far offshore. Any refusal for access, issued by Warton ATC, will only occur when a particularly complex trial or evaluation mission is reaching completion near or within the geographical confines of the proposed TMZ.
5.4 Impact of the TMZ on offshore helicopter operations As outlined in Section 5.3 above, aircraft likely to be affected by the proposed TMZ are those with an MTWA of less than 5,700 kg, as above this weight the aircraft are likely to be used for public transport operations and therefore transponder equipped.
Offshore helicopter types are categorised into the following MTWA groups:
Extra Heavy Twin >20,000 kg (e.g. Chinook); Heavy Twin >5,700 kg (e.g. Bell 214ST, Super Puma, EC225, S61 and S92); Medium Twin 2,730 to 5,700 kg (e.g. Dauphin, EC155, S75 and AW139); and Light Twin <2,730 kg (e.g. Bo105).
The helicopters operated by Bond Offshore Helicopters in the Walney area are Medium Twin aircraft equipped with a transponder.
Light Twin helicopters are unlikely to operate with regularity in the area of the Wind Farms. There is a regular, daily return air taxi flight by a light helicopter (captured in the air traffic
8 CAP 393 [Ref 2]. Air Navigation: The Order and the Regulations (ANO). 9 Confirmed by the Warton air traffic surveys. 10 Only one aircraft movement of over 200 in the proposed TMZ area was not transponder equipped.
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survey) between Andreas Aerodrome (on the north of the Isle of Man) and Chorley, Lancashire that transits close to the Walney area. This flight will be unaffected as it carries both a transponder and radio.
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6 Environmental and Economic Considerations of a TMZ
Overall, it is anticipated that the environmental impact of the Walney TMZ will be neutral within the three major categories of noise, fuel burn and local air quality.
6.1 Overview This section discusses the effects of the proposed airspace change on the environment in terms of noise pollution, fuel burn and local air quality. In any airspace decision-making, the CAA must consider the environmental impact of aviation and the disturbance caused to the public.
The airspace within which the introduction of a TMZ is proposed lies offshore, is in Class G airspace, and lies greater than 5.7 km (3 NM) from the Cumbria coastlines.
Notwithstanding that the proposed TMZ airspace is not CAS, and no aircraft operations are excluded from it, it is possible nonetheless that some GA operators might elect to route on or closer to shore to avoid the TMZ requirements rather than routing offshore through the TMZ.
Airspace activity in Class G airspace is not routinely monitored. However, the two individual surveys of one month duration each confirmed that the large majority of transit GA (Sports and Recreation included) in the Morecambe Bay Offshore Wind Farms area remain close (within 1.9 km (1 NM)) to the coastlines. Furthermore, observed traffic farther offshore is transponder equipped and usually in two-way radio contact with BAES Warton or Barrow/Walney Island ATC. Therefore, it is anticipated that there will be little, if any, traffic displacement due to the proposed Walney TMZ inhibiting GA flight operations.
6.2 Impact of noise It is expected that the noise impact after TMZ implementation is insignificant due to the offshore location of the proposed TMZ and the little, if any, traffic displacement different from the pre- implementation situation.
6.3 Anticipated level of fuel burn/CO2 emissions
It is recognised that aircraft contribute to carbon dioxide (CO2) emissions and this has an impact on climate change. Access to the activated TMZ airspace (Mon-Thu 0730-1900 Local; Fri 0730- 1700 Local Time) will be available wherever practicably possible, little, if any, traffic displacement or re-routing is anticipated and any re-route taken is likely to be insignificant. No re-routing will be required outside the TMZ activation times. This airspace proposal ensures sustainability of the efficient routing of aircraft.
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6.4 Anticipated effect on local air quality CAP 725 [Reference 1], Appendix B, Annex 8 identifies that local air quality at ground level remains largely unaffected by aircraft emissions that take place above 3,000 ft above ground level (agl) because dispersion reduces concentration levels for these emissions. It is understood that in the context of local air quality, the overall objective under CAP 725 is to determine whether the proposed airspace changes will exceed any statutory air quality standards, and if so, what contribution the airport operations make towards such departures.
The proposed TMZ lies offshore and it is not anticipated that Air Quality Standards will be breached.
6.5 Environmental implications Overall, it is anticipated that the environmental impact of a Walney TMZ will be neutral, or at worst insignificant, within the three major categories of noise, fuel burn and local air quality because of the proposed airspace change. It is not anticipated that the Walney TMZ will reduce the environmental impact of aviation in the subject airspace; however, it is reasonable to expect that the environmental impact of aviation in the subject airspace will not worsen because of the change. Both tranquillity and visual intrusion are unlikely to be impacted by any GA displacement and, in the worst case, the numbers of those negatively affected are not likely to increase significantly upon implementation.
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7 Consultation Response Analysis
The Walney TMZ consultation invitations were circulated to a total of 72 stakeholder consultee organisations or individuals, of which three emails were returned as undelivered. Of the ten responses received; two supported the proposal, six provided a neutral response and one objected to the proposal. One other consultee raised other comments relating to the presence of the Walney Extension Offshore Wind Farm and not to the development of the Walney TMZ.
7.1 Overview This section summarises the aim of the consultation exercise, describes the categories of consultee organisations and individuals that were consulted and provides a breakdown of the responses received. It also explores the support ratio of consultee responses received to give a general indication of stakeholder acceptance of this proposal.
7.2 Consultation summary The purpose of this consultation was to gather and analyse the views of the various stakeholders concerning a proposal to establish a TMZ over the existing Walney Offshore Wind Farm and the Walney Extension Offshore Wind Farm in the Liverpool Bay. Fundamentally, the consultation has enabled DONG Energy to obtain or confirm views and opinions about the impact of the proposed airspace change.
The proposed establishment of the TMZ is one element of a three-part Mitigation Package aimed at negating the impact of the clutter from the Walney Extension Offshore Wind Farm WTGs upon the Warton PSR. The three parts are:
Element 1: Establishment of a TMZ; Element 2: Authorisation to control SSR-only and; Element 3: Suppression of PSR returns within the boundary of the Wind Farms.
Such an airspace change is necessary in order to mitigate the effects of the wind turbines on the Warton PSR. This will ensure that a full suite of UK Flight Information Services (UK FIS) can continue to be provided, whilst maintaining the current levels of airspace effectiveness and efficiency in this area.
This aim of the consultation was not about facilitating a change in routine air traffic procedures at local aerodromes. The background to this consultation and the methodology used are detailed in Annex A4 to this document.
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7.3 Consultee organisations The Walney TMZ consultation invitations were circulated to a total of 7211 stakeholder consultee organisations or individuals; of these three emails were returned as undelivered. The consultee lists are detailed in Annex A5 and comprise:
39 Aviation “National Organisations” (CAA NATMAC list); 12 Local Aerodromes/Aviation Consultees; Five Members of Parliament; 11 Council Wards and Local Authorities; and Five Local/National Environmental Organisations.
The consultation document was distributed via a dedicated link on DONG Energy’s website and by email to all consultees.
Consultees broadly fall into two categories:
Aviation consultees; and Non-aviation consultees.
Aviation consultees included aviation parties such as the MoD, airlines, aircraft operators, adjacent aerodromes, all local airspace users and the national bodies representing all UK aviation interests that may be affected by the regulatory requirements within the TMZ. National bodies such as LAA, BALPA, AOA etc. are represented through the auspices of the National Air Traffic Management Advisory Committee (NATMAC), sponsored by the CAA. A number of military organisations are also members of the NATMAC.
Non-aviation stakeholders for consultation included environmental and heritage organisations, local planning authorities and the general public. Although the proposed change to the airspace lies offshore, and there are no changes to the way aircraft operate over land, the neighbouring coastal districts and parish councils were also consulted. The consultee groups are detailed in Figure 4 below.
11 It should be noted that NATMAC comprises a total of 39 organisations, represented by 45 individuals. The consultation document was circulated to each individual. However, this analysis reflects the views of the organisations as a whole and not of the individuals representing them. In some cases it was found that representation had changed from the list provided by the CAA.
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Figure 4 Distribution of Consultees
7.4 Response analysis A total of ten responses (approximately 15 % of consultees) to this consultation were received. A breakdown of these is provided in Table 1 and Figure 5 below.
Number Consultee Groups Responses % Consulted
1 NATMAC (Civil) 34 5 14.71
2 NATMAC (Military) 5 1 20.00
3 Local Aerodromes/Aviation Consultees 12 4 33.33
4 MPs 5 0 0
5 Council Wards & Local Authorities 9 0 0
6 Environmental Organisations 5 0 0
7 Individuals N/A 0 N/A
Totals 69 10 14.5 %
Table 1 Responses from Consultees
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Figure 5 Responses from Listed Consultees
It should be noted that “NATMAC (Civil)” and “NATMAC (Military)” comprise those organisations who are members of the CAA’s NATMAC. The NATMAC consultee list includes some CAA Departments who, for reasons of CAA impartiality, do not respond to consultations.
7.5 Meetings with Major Stakeholders Prior to the commencement of the consultation period, a number of meetings were held with some of the major stakeholders. Although most of these organisations had been contacted during the initial requirements capture phase, the purpose of these meetings was to present the detail that would be incorporated into the Consultation Document to ensure there were no surprises for stakeholders when it came to formal comment.
Pre-consultation meetings were organised with the following stakeholders:
BAE Barrow/Walney Island; Cumbria Airspace Users Forum; Bond Helicopters; and Barrow/Walney Island Aerodrome.
7.5.1 Local International Airports
Liverpool John Lennon Airport (LJJLA) is supportive of the Walney TMZ proposal.
Blackpool International Airport (BIA) has no objection to the Walney TMZ proposal.
7.6 Consultation support ratio Of the ten responses received from the consultee organisations:
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Two consultees (20 %) supported the proposal to establish a TMZ over the Morecambe Bay Offshore Wind Farms; Six consultees (60 %) provided a neutral response, whereby the consultee did not object or provided no comments on the proposal; One consultee (10 %) objected to the proposal; and One consultee (10 %) raised other comments relating to the presence of the Walney Extension Offshore Wind Farm and not to the development of the Walney TMZ. Such comments have therefore not been included in the analysis.
Figure 6 Support Ration from Listed Consultees
7.7 Objection
7.7.1 British Handgliding and Paragliding Association The British Handgliding and Paragliding Association (BHPA) represents over 90% of some 7,000 hand glider, paraglider, powered hand glider and powered paragliders pilots flying in the UK. In response to the consultation, BHPA said that whilst it is extremely unlikely that any of their powered and unpowered pilots would be affected by the proposal, the BHPA object to the proposal because it fails to follow best practice. BHPA further pointed out that there are a number of aspects to the consultation that cause BHPA concern and would be of significantly higher importance should the same matters occur in a proposal for a TMZ in another location.
BHPA stated that the proposed TMZ is considerably larger than it needs to be and should only cover the turbines that cause an issue. BHPA further cast doubt on whether there is sufficient
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information within the proposal for consultees to be able to reach a meaningful decision with respect to whether the possible radar solutions have been appropriately assessed. BHPA believe that ANSPs should be getting their radar fixed, with it being paid for by the developer if necessary.
7.8 Isle of Man Airport PSR Concerns Isle of Man Airport (IoMA) expressed their concerns regarding technical omissions to the consultation document and technical effects on the IoMA PSR by offshore wind farms.
The issues raised above relate specifically to the presence of the Walney Extension Offshore Wind Farm and not to the proposed TMZ. Following a positive Secretary of State decision on 7th November, on a ‘consent’ for the Walney Extension Offshore Wind Farm, these issues, have therefore not been included in the this TMZ consultation analysis.
7.9 Confidentiality All the feedback from the consultation has made available to the CAA as part of the Airspace Change Proposal. This will allow the CAA to assess independently whether the appropriate conclusions have been drawn in the development of the proposed design. Responses will be treated with due care and sensitivity by DONG Energy, Osprey and by the CAA.
7.10 Publication Should the CAA, without the need for further design optimisation or analysis, accept the Airspace Change Proposal, DONG Energy suggest that the implementation of the TMZ would take place on a single date to coincide with the initial operational date of the Walney Extension Offshore Wind Farm expected to be in mid-2017.
DONG Energy proposes to detail the TMZ within the UK Mil AIP Warton AD2 entry, in UK IAIP ENR GEN 1.5 (Aircraft Instruments, Equipment and Flight Documents) and ENR 6.1 (Morecambe Bay/Liverpool Bay Gas Field Helicopter Support Flights). This would serve the purpose of formally notifying the TMZ; the AIRAC date is to be confirmed.
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8 References
Reference Name Origin
1 CAP 725 CAA Guidance on the Application of CAA the Airspace Change Process ISBN 978 0 11790 739 3 Third Edition (corrected) April 2007
2 CAP 393 Air Navigation: The Order and the CAA Regulations ISBN 978 0 11792 836 2 Fourth Edition, 10 January 2015
3 Low Density Low Complexity Airspace – A Helios Scoping Study P1725D001 Version 1.0, 17 December 2013
4 CAP 764 CAA Policy and Guidelines on Wind CAA Turbines ISBN 978 0 11792 835 0 Fifth Edition, June 2013
5 CAP 493 Manual of Air Traffic Services CAA (MATS) Part 1 ISBN 978 0 11792 873 2 Sixth Edition, 16 October 2014
Table 2 Table of References
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A1 Walney Extension Offshore Wind Farm Line of Sight Assessment
A1.1 Overview This Annex contains the results of the radar Line of Sight (LoS) assessment for the Walney Extension Offshore Wind Farm WTGs in respect of the PSR located at Warton Aerodrome (owned and operated by BAE Systems Ltd).
The analysis was carried out on representative points (labelled 1-10) on the Walney Extension Offshore Wind Farm boundary, provided at Table 3. An OS map showing the relative positions of these boundary points accompanies this assessment (Figure 7).
A1.2 Boundary Details
Boundary Point WGS84 Blade Tip Height (m) Latitude Longitude
Point 1 N54 08 01.9 W003 54 57.2 223
Point 2 N56 06 38.7 W003 54 55.2 223
Point 3 N54 04 01.1 W003 46 29.9 223
Point 4 N54 00 05.1 W003 33 53.2 223
Point 5 N54 00 35.7 W003 31 22.5 223
Point 6 N54 03 25.8 W003 38 23.9 223
Point 7 N54 05 27.3 W003 39 59.4 223
Point 8 N54 06 11.2 W003 39 09.7 223
Point 9 N54 09 22.2 W003 49 24.1 223
Point 10 N54 07 54.5 W003 53 34.2 223
Table 3 Summary of Turbine/Boundary Details
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A1.3 Boundary Graphic
Figure 7 Illustration of the Walney Extension Boundary Points
A1.4 LoS Assessment Methodology Over the distance between a PSR and a wind turbine, the radar signal will attenuate (lose power) and be refracted and diffracted (change direction). The likely radar performance characteristics for the assessed radar station were predicted in order to model the radar signal. The intervening terrain and signal path between the assessed radar and the Walney Extension Offshore Wind Farm development have been modelled using ATDI ICS LT. For LoS analysis, the terrain path has been assessed to determine whether the intervening terrain is likely to be significant enough to prevent the turbines/boundary points being detectable by radar. The direct LoS and the 1st Fresnel zone, an elliptical zone around the direct LoS where the radio waves remain strong, were assessed. Objects that infringe upon the Fresnel zone or the direct LoS will cause the signal to diffract and attenuate. The effect of diffraction means that the direct transmitted radio waves and those in the upper 1st Fresnel zone can still reach the turbine and be returned to the radar receiver, hence why it is not always obvious that terrain shielding is sufficient.
LoS diagrams have been produced illustrating the likely detectability of the Walney Extension Offshore Wind Farm development by the Warton PSR. Within the diagram
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(see Figure 8 below), the signal propagation is modelled from the radar (far most left) to the turbine blade tip (far most right). The black line in the diagram with area underneath filled in dark brown represents the terrain profile between the radar and the boundary point. The red line in the diagram represents the direct LoS between the two locations. The orange ellipse around the direct line of sight represents the 1st Fresnel zone. The light blue and magenta lines are not relevant to this assessment.
Although every care has been taken during the line of sight modelling and analysis process, modelling limitations and assumptions obviously lead conclusions to be based on theoretical results. The results are therefore indicative, and actual radar performance may differ from this analysis.
A1.5 LoS Assessment Results The LoS assessment has been carried out based on nine boundary locations and a tip altitude of 223 m above mean sea level (amsl). Osprey concludes one of four opinions following line of sight assessment on the potential detectability of a wind turbine/boundary point by radar:
Yes – the location is highly likely to be detected by the radar: direct line of sight exists between the radar and the wind turbine/boundary point; Likely – the location is likely to be detected by the radar at least intermittently: direct line of sight skims terrain/only a small part of the 1st Fresnel zone is blocked; Unlikely – the location is unlikely to be detected by the radar but cannot rule out occasional detection: around 60% or more of the 1st Fresnel zone upper limit is blocked; and No – the location is unlikely to be detected by the radar as significant intervening terrain exists: entire 1st Fresnel zone of signal is blocked.
As all the boundary points for Walney Extension produce the same result and all are highly likely to be detected by the Warton PSR, the image for Point 5 only will be shown in this section to provide an indicative result of Osprey’s findings for each point. A full set of LoS profiles for all the analysed points will be available on request.
Figure 8 shows the LoS profile between the Warton PSR and Point 5, the closest point to the Warton PSR. This result is indicative of that for all Points assessed; all locations are highly likely to be detected by the Warton PSR at an altitude of 223 m amsl. The assessment result is “Yes” for all Points.
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Figure 8 LoS Profile between Warton (PSR) and Point 5
A1.6 Conclusion In conclusion, with an assumed blade tip altitude of 223 m amsl, the boundary points for the Walney Extension are highly likely to be detected by the Warton PSR due to the lack of intervening terrain that exists between the radar and the proposed development.
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A2 West of Duddon Sands Line of Sight Assessment
A2.1 Overview This Annex contains the results of the radar LoS assessment for the West of Duddon Sands (WoDS) offshore wind farm in respect of the Warton PSR.
The analysis was carried out on specified points (labelled 1-5) on the fringes of the WoDS wind farm boundary. An OS map showing the relative positions of these boundary points is included in Figure 9 below.
A2.2 Boundary Details
Boundary Point WGS84 Blade Tip Height (m) Latitude Longitude
Point 1 N54 00 07.0 W003 33 25.6 175
Point 2 N53 56 40.9 W003 29 14.6 175
Point 3 N53 56 36.4 W003 25 17.2 175
Point 4 N53 58 18.6 W003 22 42.6 175
Point 5 N54 01 44.0 W003 26 34.3 175
Table 4 Summary of Turbine/Boundary Details for WoDS LoS Assessment
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A2.3 Boundary Graphic
Figure 9 Illustration of the WoDS Boundary Points
A2.4 LoS Assessment Methodology As previously explained in Annex A1 for the Walney WTG development, the same methodology was applied to an assessment on the wind turbine development at WoDS.
A2.5 LoS Assessment Results The LoS assessment has been carried out based on five boundary locations and a tip altitude of 175 m amsl.
Figure 10 below shows the LoS profile between the Warton PSR and Point 4, the closest point to the Warton PSR. This result is indicative of that for all Points assessed; all locations are highly likely to be detected by the Warton PSR at an altitude of 175 m amsl. The assessment result is “Yes” for all Points. A full set of LoS profiles is available on request.
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Figure 10 LoS Profile between Warton (PSR) and Point 4
A2.6 Conclusion In conclusion, with an assumed blade tip height of 175 m amsl, the boundary points, at altitude 175 m amsl, for the WoDS Wind Farm are highly likely to be detected by the PSR at Warton Aerodrome due to the lack of intervening terrain that exists between the radar and the proposed development.
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A3 Proposed TMZ Co-ordinates
The co-ordinates for the fifteen corners of the proposed Walney TMZ are given in Table 5. These co-ordinates provide for a TMZ directly above the Wind Farms and a 2 NM buffer surrounding the WTGs.
WGS84 Point Latitude Longitude
1 N54 05 35.1 W003 58 37.2
2 N53 58 27.1 W003 35 36.3
3 N53 54 45.2 W003 31 06.0
4 N53 54 37.4 W003 23 53.0
5 N53 57 07.7 W003 20 05.6
6 N53 55 27.2 W003 16 52.3
7 N53 59 24.3 W003 10 52.0
8 N54 04 57.5 W003 19 11.3
9 N54 09 21.2 W003 26 45.4
10 N54 06 43.2 W003 31 05.9
11 N54 10 30.0 W003 38 28.4
12 N54 08 58.7 W003 40 38.3
13 N54 11 56.2 W003 50 11.3
14 N54 10 05.1 W003 54 12.0
15 N54 10 42.7 W003 58 18.0
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Table 5 Proposed Walney TMZ Co-ordinates
The proximity of the proposed TMZ to local military and civilian aerodromes is provided in Table 6.
Aerodrome Proximity of TMZ (NM/km)
BAE Systems Barrow/Walney Island 4.4 NM / 8.1 km
Cark Aerodrome 14 NM / 26 km
Blackpool International Airport 14.5 NM / 26.8 km
BAE Systems Warton 19.3 NM / 35.8 km
IoMA 22 NM / 41 km
Table 6 Proximity of the Proposed TMZ to Local Military and Civilian Aerodromes
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A4 Consultation Background and Methodology
A4.1 Background to the Consultation DONG Energy, as the sponsor of the proposed airspace change, is required to submit a case to the Civil Aviation Authority (CAA) to justify the change in airspace over the Walney Offshore Wind Farms. In addition, as part of the CAA’s ACP, it is DONG Energy’s responsibility to consult with all relevant stakeholders who may be affected directly or indirectly by the proposal.
A4.2 Method of Consultation The Walney TMZ consultation was conducted in accordance with the principles set out in the Cabinet Office Code of Practice on Consultation12, as required by the CAA.
Osprey, on behalf of DONG Energy, prepared a comprehensive Consultation Document. Full details of the proposed change, including rationale, perceived impacts and the mitigation measures undertaken by DONG Energy and BAES Warton, were provided in the Consultation Document.
A link to the Consultation Document was made available on the DONG Energy website13. All consultees were notified by email detailing the consultation and how to access the Consultation Document.
Local aviation stakeholders were engaged at an early stage during the design process. Prior to the preparation of the Consultation Document, meetings were conducted with the following major stakeholders:
BIA;
Cumbria Airspace Users Forum;
Bond (helicopter operators to the Liverpool and Morecambe Bay gas fields and the Search and Rescue helicopter based at Caernarfon Aerodrome); and
Barrow/Walney Island Aerodrome.
12 https://www.gov.uk/government/publications/consultation-principles-guidance 13 http://www.walneyextension.co.uk/en/application-for-consents/consultation-for-transponder-mandatory-zone
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The primary purpose of these meetings was to present the detail that will be incorporated into the Consultation Document to ensure there are no surprises for stakeholders when it comes to formal comment.
Full consultation commenced with wide circulation of the electronic Consultation Document to all identified stakeholders on 10th October 2014 on completion of the design process and environmental studies. The consultation process was planned to run until 11th January 2015 - a period of 14 weeks. This allowed a minimum of twelve weeks required for formal consultation14, recognised the number of Public Holidays during the period and provided scope for any unforeseen delays at the start, or any significant issues that may arise during the process.
Consultees were asked to consider the proposal and submit a response to DONG Energy in writing or through a dedicated email address ([email protected]).
In order to promote maximum response, three email reminder emails were sent to those consultees who had not yet provided a response to date. The first reminder was sent on 20th November 2014 (more than one month before the end of the consultation period), a second reminder email on 22nd December 2014 and a third email reminder was sent to only the aviation stakeholders (NATMAC) who had not yet responded to date.
14 The Cabinet Office Code of Practice on Consultation and the CAA requirements specify a minimum period of 12 weeks for consultation.
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A5 Stakeholder / Consultee List
A5.1 Aviation Consultees National Organisations (NATMAC)
Consultation Also known As
Aircraft Owners and Pilots Association AOPA UK
Airport Operators Association AOA
Association of Remotely Piloted Aircraft Systems ARPAS
Aviation Division Navy Command Headquarters NCHQ
Aviation Environment Federation AEF
BAE Systems Warton BAES
British Air Transport Association BATA
British Airline Pilots’ Association BALPA
British Airports Association BAA
British Airways BA
British Association of Balloon Operators BABO
British Balloon and Airship Club BBAC
British Business and General Aviation Association BBGA
British Gliding Association BGA
British Hang Gliding and Paragliding Association BHPA
British Helicopter Association BHA
British Microlight Aircraft Association BMAA
British Model Flying Association BMFA
British Parachute Association BPA
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Consultation Also known As
Civil Aviation Authority CAA SRG
Defence Airspace and Air Traffic Management (incl. the Military User Advisory DAATM (MUACT) Consultative Team)
Euro UAV Systems Centre Ltd
European Low Fares Airline Association ELFAA
General Aviation Safety Council GASCo
Guild of Air Pilots and Air Navigators GAPAN
Guild of Air Traffic Control Officers GATCO
Headquarters Director Army Aviation HQ DAAvn
Heavy Airlines
Helicopter Club of Great Britain HCGB
Light Aircraft Association LAA
Light Airlines
Low Fares Airlines
Ministry of Defence MoD
MoD Flight Test Regulator
NATS (NSL) NSL
NATS En-Route Ltd NERL
PPL/IR Europe PPL/IR
Royal Air Force Safeguarding Team RAF ST
The British Business and General Aviation Association BBGA
UK Airprox Board UKAB
UK Flight Safety Committee UKFSC
3 AF-UK/A3
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A5.2 Aerodromes / Local Aviation Consultees
Consultee Also known As
Blackpool International Airport EGNH
Bond Offshore Helicopters
Caernarfon Aerodrome Bangor
Chester Hawarden EGNR
City (Barton) Heliport EGCB Manchester
Ince West Lancashire Microlight
Isle of Man Airport EGNS
Liverpool John Lennon Airport EGGP
Lleweni Parc Airfield Denbigh Gliding
RAF Woodvale EGOW
Barrow/Walney Island EGNL
Lakers Gliding Club
A5.3 Non-Aviation Consultees: National Bodies
Consultee
National Trust for England
English Natural Heritage
Friends of the Earth
Campaign to Protect Rural England
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Natural England
A5.4 Non-Aviation Consultees: Regional Council Authorities
Consultee
Barrow-In-Furness Council
Copeland Borough Council
Fleetwood Town Council
Lancaster City Council
South Lakeland Council
A5.5 Non-Aviation Consultees: Council Wards / Local Authorities Borough if Barrow-In-Furness
Consultee
Askam and Ireleth Parish Council
Walney North
Walney South
Roosecote
Copeland Borough Council
Consultee
Haverigg Ward
Millom
Fleetwood Town Council
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Consultee
Pharos Parish
Warren Parish
Rossall Parish
Lancaster City Council
Consultee
Bolton-Le-Sands
Carnforth Ward
Harbour Ward
Heysham North
Heysham Central
Heysham South
South Lakeland District Council
Consultee
Arnside and Beetham
Grange North
Grange South
Ulverston East
Ulverston South
A5.6 Information Organisations: Members of Parliament
Consultee Constituency
John Woodcock MP Barrow and Furness
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Jamie Reed MP Copeland
Eric Ollerenshaw MP Lancaster and Fleetwood
David Morris MP Morecambe and Lunesdale
Tim Farron MP Westmorland and Lonsdale
A5.7 Information Organisations: Civil Aviation Authority
Consultee Also known As
Safety and Airspace Regulation Group SARG
Safety and Airspace Regulation Group (Airspace ATM and Aerodromes) Head of Aerodrome & Air Traffic SARG (AAA) Manager Aerodromes Standards Division
Safety and Airspace Regulation Group Flight Ops SARG Flight Ops Division Division
Safety and Airspace Regulation (Airspace ATM and SARG (AAA) Manager Airspace Regulation Aerodromes) Head of Airspace Regulation
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