Royal Navy Air Station Culdrose Predannack Airspace Change

Royal Navy Air Station Culdrose

Predannack Airspace Change Proposal

Date 28 September 2018

TABLE OF CONTENTS

List of abbreviations 2

1. Introduction 3

2. Justification and Objectives 5 Justification for the Proposal 5 Principles 5 Previous Activation 6

3. Current Area 8 Airspace Description 8

4. Change Proposal 10 Overview 10 Activation/Deactivation 12 Emergency 13 Operational Impact 13 Infrastructure 13 Proposed Implementation Date 13

5. Consultation Overview 14 Validation of the Process. 14 Key Findings 14

6. Design Principles 16 Other Users 16 Environmental 17 Local Land Owners 17 Population 17

7. Draft AIP Amendments 19

LIST OF ABBREVIATIONS

ACP Airspace Change Proposal ASSI Area of Special Scientific Interest AARA Air to Air Refuelling Area AIAA Area of Intense Aviation Activity AONB Area of Outstanding Natural Beauty ATC Air Traffic Control ATZ Air Traffic Zone BVLOS Beyond Visual Line of Sight CAA Civil Aviation Authority CADS Centralised Aviation Data Service DACS Danger Area Crossing Service DAAIS Danger Area Activity Information Service DAM Defence Aerodrome Manual FL Flight Level FUA Flexible Use of Airsapce Flag Officer Sea Training FOST LARS Local Area Radar Service LoA Letter of Agreement MATZ Military Air Traffic Zone NATS National Air Traffic Service NOTAM Notice to Airmen RN Royal Navy RNAS Culdrose Royal Navy Air Station Culdrose SARG Safety and Airspace Regulation Group SAR Search and Rescue TDA Temporary Danger Area UAS Unmanned Air System

1. INTRODUCTION

About the Proposal

1. Predannack Airfield is a satellite airfield of Royal Navy Air Station (RNAS) Culdrose and is routinely used by the helicopters stationed at RNAS Culdrose. RNAS Culdrose is the Aerodrome Operator and responsible for actively managing and running the airfield. Predannack Airfield is situated on the Lizard Peninsula in Cornwall near to the village of Mullion, as can be seen in Figure 1 and 2 below. .

Figure 1- Local Area Map

Figure 2 - Google Image view

2. In addition to manned aircraft, there is a current and future intended requirement to operate Unmanned Air Systems (UAS) within the Royal Navy (RN). Specifically, to operate UAS Beyond 3

Visual Line of Sight (BVLOS) and to provide access to the Maritime environment. Current National regulations mandate these UAS must be operated within ‘Segregated Airspace’. It is this creation of ‘Segregated Airspace’ that forms the basis of the Airspace Change Proposal (ACP).

2. JUSTIFICATION AND OBJECTIVES

Justification for the Proposal

3. The UAS operated by the RN to date have typically been systems flown to and from ships. There is however a need to operate UAS from land and access the maritime environment, this will enable:

a. Training: Learning to fly a UAS usually requires a degree of classroom learning followed by some basic flights. This is often conducted in the land environment and has previously required training to be conducted overseas.

b. When operating from a ship only flights are dependent upon that ships location and its programme of operations i.e. ability to take part in exercises and training. This therefore severely limits our ability to;

1) Train individuals to learn to operate UAS within the maritime.

2) Allow UAS to be used by ships which do have their own UAS thereby enhancing wider RN training opportunities.

4. The location of Predannack offers several unique advantages including:

a. Suitable existing Infrastructure, including buildings and emergency cover.

b. Availability of Air Traffic Control (ATC) services provide by RNAS Culdrose.

c. Geographical location, providing a short flying distance to the sea.

d. Geographical location, allowing quick access to the South Coast Danger Areas to enable operations to be conducted with RN ships whilst taking advantage of the existing Danger Areas.

5. Across the south coast there already exists an extensive network of airspace which permit UAS operation. Crucially the RN uses this airspace to provide a safe environment to train RN ships. Therefore, access to this training environment is of paramount importance within this proposal.

6. By creating a series of Notice to Airmen (NOTAM) activated Danger Areas around Predannack it would be possible to launch a UAS form a land based site to transit out and access the South Coast Danger Area complex. This permits the exploitation of existing infrastructure, airspace structures and available ATC services whilst minimising impact to other airspace users.

Principles

7. This ACP is designed to achieve the following:

a. Provides segregated airspace for UAS to safely operate within.

b. Minimises UAS flight time over land.

c. Use the minimum amount of airspace to permit UAS operation.

d. In the event of an inadvertent airspace penetration, provide sufficient space to manoeuvre within whilst remaining within segregated airspace.

e. Ensure effective management processes of any established airspace to maximise airspace use and ensure clarity is maintained over the status of the airspace.

f. Enable access to the South Coast Danger Area complex.

Previous Activation

8. Temporary Segregated Airspace was established at Predannack between the period 5 September 2016 to 4 December 2016. This airspace was established to enable UAS operations on a trial basis. The lessons identified during this establishment have been fed into this proposal. Figure 3 and 4 detail the previous temporarily established airspace. In addition, a Letter of Agreement (LoA) was established for this period between RNAS Culdrose and Flag Officer Sea Training (FOST) to manage the associated interactions. This previous LoA will be used to support the update of future LoAs associated with the ACP.

Dimensions:

D089A – A circle 3nm in radius based at the centre of Predannack from Surface to 6000ft

D089B - A rectangle 6nm in width transiting to the South East from Surface to 6000ft

D006 – Existing portion of airspace from surface to 1500ft

D089C and D089D two portions of airspace that sit direct on top of D006 from 1500ft to 6000ft See Diagram below

D089C D089D Surface to Surface to 6000ft 6000ft

Figure 3 – Temporary Danger Area (TDA)

D006 Surface to 1500ft

Surface of the Sea

Figure 4 – Representation of D089C&D

3. CURRENT AREA

Airspace Description

9. Predannack airfield is primarily utilised for the training of helicopter crews from squadrons based at RNAS Culdrose. Predannack has 8 runways of varied lengths, several winching ‘spots’ and multiple taxiways in and around the airfield. The airfield also has an Air Traffic Control Tower and crash response vehicles.

10. Predannack is in the South West peninsula situated within Class G airspace, it has an associated Air Traffic Zone (ATZ) and is part of the RNAS Culdrose combined Military Air Traffic Zone (MATZ). The airfield itself sits within an Area of Intense Aviation Activity (AIAA) associated with operations from RNAS Culdrose.

11. Within the surrounding area there are the following airspace constructs:

a. North:

1) Cornwall Newquay International Airport approx. 30 miles to the North.

2) RNAS Culdrose – Predannack Aerodrome Operators.

3) Air to Air Refuelling Area (AARA) 10 –Flight Level (FL) 80 - FL260.

b. West: Lands End Transit Corridor Surface to FL 40.

c. South: Nil significant structures.

d. East: South Coast Danger Areas, these are managed by the RN. The nearest Danger Area is D006 and forms part of this ACP.

Figure 3- Predannack airspace

12. Surrounding the Lands End peninsula, due to its location and existing airspace constructs, there is a small amount of General Air Traffic (GAT) and Gliding Activity; also due to the nature of the coast line Search and Rescue operations do occur within this area. Most of the aviation activity conducted within this area is however military flying from RNAS Culdrose.

13. A Local Area Radar Service (LARS) is provided by RNAS Culdrose during specified operating hours.

4. CHANGE PROPOSAL

Overview

14. This ACP is for the establishment of two new Danger Areas and the amendment of one existing Danger Area. The existing classification of the airspace will be retained, i.e Class G.

a. The establishment of two new Danger Areas:

1) One with a centre point - Predannack: Shape - Circle Centre Point - 500007N 0051354W Radius - 3nm Level - Surface to 8000ft

2) One a rectangle orientated NW-SE connecting the Danger Area above to the amended D006 as discussed below:

Shape - Rectangle Coordinates - 500237N 0051636W, 495818N 0052242W, 495124N 0051200W, 495629N 0050728W, 500237N 0051636W Level - Surface to 8000ft

b. The amendment of the existing danger area D006:

1) Split D006 into two distinct Danger Areas - The line of the split will be a parallel line 3nm offset to the South from the of the extended centre line for the approach to Runway 30 at RNAS Culdrose. Figure7 is a guide only demonstrating the split within D006. Figure 8 illustrates the proposed change where the blue areas reflect the newly split D006 and red the new areas proposed. Figure 9 outlines the coordinates of the newly amended D006.

2) Increase the level of both new Danger Areas from 1500ft to 8000ft to provide a contiguous corridor with the Danger Areas proposed above.

Shape - Two new areas within occupying same previous lateral dimensions of D006

Coordinates - Area 1: 495124N 0051200W, 495746N 0050585W, 495689N 0045697W, 495124N 0050000W, 495124N 0051200W

Areas 2: 495746N 0050585W, 500500N 0045948W, 500924N 0045430W, 500000N 0045430W, 495689N 0045697W, 495746N 0050585W

Level - Surface to 8000ft

3nm

Figure 7 – Demonstrating proposed spit within existing D006

Figure 8 - Proposed Danger Areas

Area 2

Area 1

Figure 9 – D006 Split

Activation/Deactivation

15. The new Danger Areas would not be active permanently but would instead be activated by NOTAM.

16. The Danger Areas would only be activated for the duration of the serials and would be deactivated as soon as practicable. In addition to NOTAM cancellation, relevant local agencies including Bristows Search and Rescue based at Newquay will be informed a minimum of one hour prior to activation and on completion of operations. This will be covered with a Letter of Agreement (LoA) and included within RNAS Culdrose ATC Orders and the RNAS Culdrose Defence Aerodrome Manual (DAM).

17. The Danger Areas would only be activated and remain active whilst RNAS Culdrose ATC is open and providing a Danger Area Crossing Service (DACS).

18. RNAS Culdrose would be responsible for the submission of the NOTAM and for any required deactivation.

19. FOST would be informed of all intended activation and subsequent deactivation to permit inclusion into the Weekly Planning Programme. The existing LoA will be updated to reflect this procedure.

20. When RNAS Culdrose ATC are not open the Danger Area Activity Information Service (DAIIS) would be managed utilising the same mechanism as exists for D006. The existing LoA will be updated to reflect this procedure to include the new Danger Areas

21. Due to the current requirement for the UAS to operate within segregated airspace, the separation of the new airspace into 4 defined areas increases the flexibility of RNAS Culdrose ATC to provide a DACS; the UAS will be required to seek positive approval to move from one Danger 12

Area into another. This will be included within RNAS Culdrose ATC Orders and the RNAS Culdrose DAM.

Emergency

22. In the event Emergency access was required into the Danger Areas by other manned aircraft this would be facilitated by RNAS Culdrose ATC. Exact procedures would be included within RNAS Culdrose ATC Orders and the RNAS Culdrose DAM.

Operational Impact

23. The activation of the Danger Areas is contingent upon a DACS being provided by RNAS Culdrose. The Danger Areas will not remain active permanently but instead will be NOTAM’d as active when required. This NOTAM activation will in general occur a minimum of 24 hours prior to use ensuring GAT users are aware and able to plan for the activation. This NOTAM process combined with the DACS service will limit the impact to GAT.

24. An LoA will be established within Bristow’s Search and Rescue to ensure they are made aware of any activations and deactivations. This combined with the NOTAM and provision of DACS will minimises any impact. This was a lesson identified during the initial Temporary Activation of airspace in 2016.

Infrastructure

25. The intended operation of UAS from Predannack does not involve a planned increase in existing infrastructure. Any future increase in infrastructure will consider the Environmental Order discussed within the Design Principles below.

Proposed Implementation Date

26. Proposed inclusion on the 23 May 19 Aeronautical Information Regulation and Control (AIRAC) cycle, this will therefore be enacted on the 20 Jun 19

27. Local stakeholder meetings will be held prior to 1 May 19 to further highlight the establishment of the airspace and ensure all interested parties are aware of the change.

28. NATS will be informed prior to Nov 18 immediately on completion of the Regulatory Decision to enable them to build the new Areas into their systems during one of their 3 scheduled re-builds (Dec 18, Feb 19, or May 19) prior to the implementation date.

5. COUNSULTATION OVERVIEW

Validation of the Process

29. Fourteen responses were received during the consultation period. This relatively low response rate is deemed due to the nature of the proposal coupled with most of the identified entities not being directly impacted by this ACP. To ensure the consultation period was sufficiently robust, six entities were identified as requiring responses.: Bristows Group, Cornwall Area of Outstanding Natural Beauty (AONB), Cornwall Newquay International Airport, Defence Airspace and Air Traffic Management (DAATM), National Air Traffic Services (NATS) and the United Kingdom Flight Safety Committee.

30. During the consultation period, responses were received from a variety of entities, thus demonstrating a sufficiently broad number of entities were identified thereby achieving maximum exposure and promoting an inclusive process. The response rate from the entities identified as being directly impacted by the ACP was 100%, therefore validating the findings of this consultation.

Key Findings

31. The following are the key outputs from the analysis which have influenced the development of the ACP from its original design. Those points identified through the consultation period but not included in the list below are elements that are already present within this ACP.

a. Liaison will occur with the nominated NATS individual to ensure sufficient time is permitted for incorporation of any Airspace Change into the NATS Swanwick Radar Data Processing systems. At present 10 months’ post submission of the ACP has been allowed for this to occur. Subject to any additional clarification of information required by SARG this may delay a Regulatory Decision. Therefore, exact timings for implementation will be clarified post the Regulatory Decision being made. Exact implementation date post the Regulatory Decision will be contingent on the timelines established through liaison with the nominated NATS representative.

b. A procedure will be established to inform Bristow SAR at Newquay 1 hour prior to launch of the UAS and to inform them immediately on recovery of the UAS. This will include notifying Bristow immediately if UAS operations have been cancelled.

c. Predannack is subject to an Environmental Order therefore requires ongoing consideration and monitoring of issues effecting the Environment. Regular Predannack Stakeholder meetings are already conducted to asset with this process, where AONB are represented. UAS use will be included as a standing agenda item in future stakeholder meetings to ensure its any effects on the Environment are monitored.

d. A further stakeholder meeting will be conducted with Ruan Council post the Regulatory Decision and prior to Implementation. This meeting will be principally aimed at keeping Grade Ruan council informed of the Implementation progress and was agreed to take place during the initial stakeholder meeting.

e. Grade Ruan is within the 3nm radius of the proposed Danger Area around Predannack Therefore the council will be invited to the standard Predannack stakeholders meeting to enable early identification of any issues experienced by the parishioners and to maintain good lines of communication

f. There will be a requirement to update the LoA between FOST, RNAS Culdrose and Royal Air Force (RAF) Swanwick. To ensure clarity and to account for any changes that may occur during the Regulatory Decision phase the LoAs will be formally updated post the Regulatory Decision and prior to Implementation. A previous LoA was established between 14

FOST and RNAS Culdrose during a previous activation of Temporary Airspace in 2016. This LoA will be used to assist with current LoA amendments to ensure they are completed prior to Implementation. Implementation is contingent upon the updated LoAs being in place.

6. DESIGN PRINCIPLIES

Safety.

32. RNAS Culdrose will provide a DACS and DAIIS for any period of activation. When not activated a DAAIS will be provided by Swanwick military through London Information in accordance with existing process. This process will ensure clarity is maintained over the status of the airspace whilst the provision of the DACS and NOTAM process will maximise the use of the airspace.

Other Users

33. General Air Traffic (GAT). The geographical location of Predannack along with the existing ATZ around both RNAS Culdrose and Predannack and location of the South Coast Danger Areas limits the amount of GAT. This does not however discount that GAT would want to operate within this area. The ACP has been designed to maximise the use of this airspace through:

a. Individual Danger Areas will only be activated as required and only for the intended periods of operation.

b. Danger Areas will only be activated whilst RNAS Culdrose are providing a DACS and DAAIS.

c. Danger Areas will be activated via NOTAM and deactivated as soon as practicable.

d. Where practicable UAS flights will utilise the Centralised Aviation Data Service (CADS) planning tool.

e. The direction of the Danger Areas has been selected to minimise impact to other airspace users.

f. The separation into 4 distinct Danger Areas increases the ability to ‘manage’ the location of the UAS and thus enable other airspace users to utilise the airspace.

g. The new Danger Areas have been designed to provide sufficient space to manoeuvre within whilst remaining within segregated airspace.

34. Search and Rescue (SAR). In addition to the procedures stated above a LoA will be established with Bristow’s Search and Rescue to ensure they are aware of Activation and Deactivation times as soon as practicable.

35. Transit Corridor. To the North West of Predannack there is a regular route flown by aircraft along the Lands End Transit Corridor. The ACP has been designed to minimise impact to this route by providing approximately 10nm of separation between the edge of the new Danger Areas and the nearest point of confliction with the corridor.

36. Cornwall Newquay International Airport. The Danger Areas have been designed to the South of Predannack to minimise impact to Cornwall Newquay International Airport. During the formal consultation phase Cornwall International Airport stated ‘they strongly support this initiative’ and raised no objections.

37. Air to Air Refuelling Area (AARA). The Danger Areas have been designed to the South of Predannack and do not interact with the AARA. Defence and Air Traffic Management (DAATM) were consulted during the designing of this airspace and formally during the consultation period. DAATM raised no concerns directly regarding the interaction of the AARA. There concerns were more broadly focused around the adherence to the principles of Flexible Use of Airspace. 16

38. Airspace activation will be overseen by RNAS Culdrose Air Operations. Where Activation is required this will necessitate services to be provided by RNAS Culdrose, such as Emergency Cover and DACS provision. Further UAS operations will affect RNAS Culdrose organic manned operations. Therefore, intended UAS operations will be included within the standard Air Station planning cycle. FUA principles will be at the core of the planning processes

Environmental

39. Predannack airfield is within an AONB and an Area Special Scientific Interest (ASSI), as such the area surrounding Predannack is subject to an Environmental Order.

40. Through consultation it was noted the requirement for RNAS Culdrose to continue to consider the sensitivities surrounding the local environment at Predannack. Cornwall AONB did not however oppose this ACP and were content for the use of UAS at Predannack and pose no objection to this ACP.

41. To effectively consider the ASSI and AONB requirements and to assist compliance with the associated Environment Order, regular Predannack stakeholder meetings are already held. These meetings will be continued. Future meetings will include UAS operations as an agenda item to ensure this issue is monitored and addressed were necessary to ensure compliance with the Environmental Order.

Local Land Owners

42. There are land owners and residents living within the area of the proposed Danger Areas. To allay concerns over the safety of the UAS the following steps have been taken:

a. The airspace has been designed to minimise flight over land.

b. All UAS operating BVLOS within the airspace will be certified for flight by the appropriate regulating authority and must satisfy those specific regulators design criteria’s.

c. The Danger Areas will require the production of a NOTAM to operate ensuring only those operations required are conducted.

d. Regular Predannack stakeholder meetings coupled with the established Community Relations Officer position will ensure issues are identified at the earliest opportunity.

Population

43. The LAeq 16 model provides a figure for the equivalent sound level of aircraft noise in dBA for the 16 hour annual day, specifically between 0700-2300 during the 92-day period 16 June to 15 September inclusive. Db represents ‘Decibels’ and are the units describing sound level or changes of sound level, dBA is the unit of sound level on the A-weighted scale. The A weighting scale itself is a frequency weighting that is applied to the electrical signal within the noise. Broadly speaking this is a standard method of simulating the way the human ear responds to a range of acoustic frequencies.

44. Predannack itself is a satellite airfield of RNAS Culdrose and only opened when required for Rotary Wing operations as such is not operated on a continual basis, and only for small periods within the 16 hour time frame. The intent of the ACP is to provide segregated airspace in which to operate UAS, this would therefore reduce the available use of Predannack for manned aircraft within the already limited available time. This will therefore likely reduce the current sound level experienced.

45. A freedom of information request was sent to Cornwall County Council 30 May 2018 to determine the population density surrounding Predannack. A response was provided on the 18 June 2018 indicating, although exact population records are not kept, the most recent electoral register data indicate approximately 5400 people reside within a 5 mile radius of Predannack. This therefore indicates it is likely substantially less than 10000 people reside within 5nm of Predannack. Therefore, the numbers effected by current activity would be considerably less than 10000.

46. Figure 10 displays the area covered within the 5nm radius from Predannack and includes an overlay of the intended size of the new Danger Areas which has a radius of 3nm. Due to the nature of the intended UAS operations this indicates fewer people still will be effected by any noise generated.

New Danger Area radius 3nm

Figure 10 – Circle 5 nm radius from Predannack with 3nm proposed Danger Area overlaid.

7. DRAFT AIP AMENDMENTS

47. ENR 5.1 Prohibited, Restricted and Danger Areas - Current

Identification and Name and Upper Limit Remarks (time of activity, type of Lateral Limits Lower Limit restriction, nature of hazard, risk of interception) EG D006 FALMOUTH BAY Upper limit: 1500 ft ALT Activity: Live Firing / Para Dropping / Target 500924N 0045430W - 500000N Lower limit: SFC Towing / Unmanned Aircraft System 0045430W - (VLOS/BVLOS) / Torpedo Dropping / 495124N 0050000W - 495124N Pilotless Target Aircraft. 0051200W – Hours: Mon-Thu 0800-2359 (0700-2300), Fri 0800-1600 (0700-1500); and as activated by NOTAM.

Service: DACS: Culdrose APP on 134.050 MHz when open; at other times DAAIS: London Information on 124.750 MHz.