Royal Navy Air Station Culdrose

Predannack Airspace Change Proposal Consultation Feedback

Date 13 August 2018

Airspace Consultation Response 700X NAS RNAS Culdrose TR 12 7RH

TABLE OF CONTENTS

List of abbreviations 2

1. Introduction 3 About the Proposal 3 Reasons for the Proposal 4 Aims of the ACP 5

2. Confidentiality 6

3. Consultation Process 7

4. Stakeholder Feedback Analysis 8 Focus Group 8 Stakeholder Meetings 8 Consultation Documentation 8 Response Rate 8 Consultation Feedback 10 Key Findings 15 Formal Proposal 15

5. What Next 16 Regulatory Decision 16 Implementation 16 Post Implementation 16 Anticipated Pathway for Implementation 17

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LIST OF ABBREVIATIONS

A-Weighting A frequency weighting that is applied to the electrical signal within a noise- measuring instrument as a way of simulating the way the human ear responds to a range of acoustic frequencies. ACP Airspace Change Proposal ASSI Area of Special Scientific Interest AARA Air to Air Refuelling Area AIAA Area of Intense Aviation Activity AIRAC Aeronautical Information Regulation and Control 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 DAATM Defence Airspace and Air Traffic Management dB Decibel units describing sound level or changes of sound level. dBA Units of sound level on the A-weighted scale. Flight Level FL Flexible Use of Airspace FUA Flag Officer Sea Training FOST LAeq Equivalent sound level of aircraft noise in dBA for the 16 hour annual day. This is based on the daily average movements that take place between 0700 and 2300 local time during the 92-day period 16 June to 15 September inclusive. Local Area Radar Service LARS Letter of Agreement LoA MATZ Military Air Traffic Zone NATS National Air Traffic Service NOTAM Notice to Airmen RN 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

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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 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 Visual Line of Sight (BVLOS) and to provide access to the Maritime environment. Current National

3 regulations mandate these UAS must be operated within ‘segregated airspace’. It is this creation of ‘segregated airspace’ that forms the basis of the ACP.

Reasons 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 be able to operate UAS from land and access the sea, 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, all flights are dependent upon that ships location and its ability to take part in exercises and training. This therefore severely limits our ability to;

1) Train individuals.

2) Allow UAS to be used by other ships which might not necessarily have their own UAS.

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 services provided by RNAS Culdrose.

c. Geographical location - 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 and take advantage of the existing airspace structures

5. Across the South Coast there already exists an extensive network of airspace that can be segregated which permit UAS operation. Crucially we currently use this airspace to provide a safe environment to train RN Ships; 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 UAS form a land based site to transit out and utilise the existing South Coast Danger Area complex. This permits the exploitation of existing infrastructure, airspace structures and available ATC services whilst ensuring minimal impact to other airspace users.

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Aims of the ACP

7. This proposal is designed to achieve the following:

a. Provides segregated airspace for UAS to operate within.

b. Minimises UAS flight time over land.

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

d. Minimise impact to effected stakeholders.

e. Ensure effective management processes of any established airspace to maximise airspace use.

f. Enable access to the South Coast Exercise Areas.

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2. CONFIDENTIALITY

8. All responses received during the consultation process are required to be included within the formal submission.

9. This enable the Safety Airspace and Regulation Group (SARG), a body within the Civilian Aviation Authority (CAA), to make an open and transparently accountable decision on whether to recommend the approval of the Airspace Change. SARG will scrutinise all the information received during the consultation phase and asses this against the regulatory requirements. This process is discussed in the sections below.

10. In addition to these consultation documents being included with the formal submission, in the spirit of transparency the CAA will publish all received documentation on their web pages. To that end, to the best of our ability we will ensure that all material published by the CAA associated with this consultation is depersonalised to the maximum effect.

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3. CONSULTATION PROCESS

Consultation Process

11. The makeup of UK airspace is regulated by the CAA, as such all proposed amendments are subject to their regulatory approval. In addition to our goal to minimise impact to stakeholders, we are therefore required to adhere to the process described by the CAA. The process itself is detailed within the Civilian Aeronautical Publication (CAP) 725. This explains the process that both Military and Civilian organisations must follow when submitting an ACP.

12. In accordance with this process a consultation period was conducted. This consultation period began 0800 18 December 2017 and closed at 2300 on Monday 26 March 2018, this allowed approximate 3 months and 9 days for stakeholders to respond. It was of importance that during the process all potential stakeholders where consulted to ensure their concerns were understood thus helping to develop a pragmatic ACP.

13. This consultation process utilised three methods, focus groups, stakeholder meetings and the production of a formal consultation document. This formal consultation document was sent to a wide range of stakeholders, ranging from airspace users, to local parishes and Environmental Organisations. Figure 1 below outlines the breakdown of organisations contacted. Furthermore, it was sent to the CAA and published on their website to ensure maximum visibility to any interested parties.

Local Parishes, 6 Military Organisations, 3

Other Predannack users, 2

Environmental Organisations, 5

Airspace Organisations, 40

Local Parishes Other Predannack users Environmental Organisations Airspace Organisations Military Organisations

Figure 3. Consultation Breakdown

14 The feedback was then collated and analysed to identify any issues presented to determine the causal factor. This was then comparted against the initial preferred solution presented within the consultation document, to create the formal ACP submission.

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4. STAEKHOLDER FEEDBACK ANALYSIS

Focus Group

14. A Focus Group was conducted on the 14 November 2017 at Predannack Airfield. This meeting was part of the termly Predannack Stakeholder meeting. This meeting is regularly conducted and brings together existing interested parties to discuss any issues surrounding the use of Predannack. Representatives included local farmers, residents, Natural England Cornwall Wildlife Trust and Bristows Group whom operate the local Search and Rescue (SAR) helicopters from Newquay. The information gathered from this specific Focus Group was used to influence the production of the consultation document and develop the preferred solution.

Stakeholder Meetings

15. A stakeholder meeting was conducted with Grade Ruan Parish Council at their request on the 15 March 2018. This meeting was designed to increase understanding of the proposal and determine its potential impact.

Consultation Documentation

16. The consultation document outlined the case for the ACP and included the various solutions considered along with the preferred solution. This document was distributed as follows:

a. The consultation document was sent out to all those stakeholders listed within Annex A of the original consultation document. This was a list of entities which could have an interest with the ACPs.

b. The consultation document was submitted to the CAA and in accordance with their procedures was published on their website to ensure maximum visibility. Enabling stakeholders outside of those listed within Annex A the opportunity to comment on the ACP.

Response Rate

17. Fourteen responses were received during the consultation period. This relatively low response rate is deemed due to the nature of the proposal coupled with the fact most of the entities identified within Annex A of the Consultation Document are not directly impacted by this proposal.

18. To ensure the consultation process was sufficiently robust, the following entities where identified as requiring responses. These entities where identified due to their potential direct interaction with the proposal:

a. Bristows Group – This entity was identified requiring as an essential response as they provide the Search and Rescue operations for the surrounding area.

b. Cornwall Area of Outstanding Natural Beauty – This entity was identified as requiring an essential response as they have the responsibility to manage the Cornish AONB and partners the Environmental Organisations listed within Annex A in achieving this.

c. Cornwall Newquay international Airport – This entity was identified as requiring an essential response as they are the significant non-military airspace user within the surrounding area.

d. Defence Airspace and Air Traffic Management (DAATM) – This entity was identified as requiring an essential response to ensure wider Defence concerns would be considered.

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e. National Air Traffic Service (NATS) – This entity was identified as requiring an essential response due to the nature of NATS role and their requirements.

f. Flight Safety Committee – This entity was identified as requiring an essential response due to the role of the Flight Safety Committee and the intention to operate UAS BVLOS.

19. During the consultation period, responses were received from a variety of entities, comments raised are discussed below. This response rare demonstrates a sufficiently broad number of entities were identified above any beyond those with a direct interest with the ACP; this therefore ensured maximum exposure and promoted an inclusive process. The response rate from the required entities was 100% this is therefore deemed to validate the findings of this consultation.

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Consultation Feedback

20. The following table is a precis of the feedback received where points requiring response have been made:

Consultation Organisation Issue Identified Response Number 1 NATS 1. No issues with the ACP in principle were 1. Close liaison will occur with the nominated NATS individual to raised. They noted however that no proposed ensure sufficient time is permitted to enable this to occur; from implementation date was included within the submission of the ACP, approximately 10 months has been consultation document. Therefore, NATS allowed for this to occur. highlighted that sufficient time needed to be allowed for incorporation of any ACP into the 2. Any additional clarification of information required by SARG NATS Swanwick Radar Data Processing during the ACP would delay a Regulatory Decision. Therefore, systems. exact timings for implementation will be clarified post the Regulatory Decision being made.

3. Exact implementation date post the Regulatory Decision will be contingent on the timelines established through liaison with the nominated NATS representative. Regardless this will not be less than 2 AIRAC cycle periods post the Regulatory Decision.

2. UK Flight 1. No issues with the ACP in principle were 1. This clarification is deemed not required. The subject of this Safety raised. They suggested however that ‘Danger ACP is the establishment of Danger Areas to facilitate the use of Committee Area activation may not be required if a UAS UAS, not a request to operate UAS. has an approved Detect and Avoid capability’. 2. Where a system has an approved Detect/Sense and Avoid capability this may subject to future approvals be permitted to operate outside of segregated airspace. In this case Danger Areas would not be required in the first instance, therefor this falls out with of this ACP.

3. Furthermore, there may be instances where even with the presence of an approved Detect/Sense and Avoid capability there would be a requirement to operate within Segregated Airspace due to the nature of operations.

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3. Bristow 1. The following is an extract of the Bristow 1. Due to the nature of both the lost Link/loss of GPS procedures Search and response, highlighting the two specific issues: of some UAS there is a requirement to ensure a contiguous Rescue portion of airspace from the surface to the upper limit of the 2. “While I understand the need for segregated proposed Danger Areas. Therefore, a raised corridor would not airspace in order to facilitate the transit of be appropriate. drones to the Danger Areas, I am not sure why it is necessary for D089b to have its base at 2. The importance of this type of transit is fully understood and the surface.” therefore the management of the airspace is of vital importance to ensure SAR operations are unaffected. The following has 3. “One of the options that the Newquay SAR been included within the ACP to address this issue. helicopter uses when returning from the West to Treliske Hospital in Truro in poor visibility 3. UAS operations are contingent on RNAS Culdrose ATC passes between the current Danger areas and providing a Danger Area Crossing Service (DACS) and therefore the Lizard in order to make a visual approach able to approve safe transit through the established area. UAS up Carrick roads.” operations will not be permitted if a DACS is not available.

4. The areas will be activated by NOTAM and will therefore not remain permanently active. This will routinely provide a minimum of 24 hours’ notice of activation to enable effective planning to be conducted.

5.The Danger Areas will be deactivated as soon as operations have been completed.

6. The Danger Areas have been designed to more readily enable the management of the position of the UAS to facilitate the provision of the DACS. This has been done through both the size of the Danger Areas and the decision to utilise 4 distinct Areas.

7. Where operations have been completed a Danger Area Activity Information Service (DAAIS) will be available from Swanwick Military through London Information. This mirrors the established procedures for the existing Danger Areas within the surrounding airspace.

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8. A new 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.

4. Local Resident 1. Concerns raised from residents include the 1. This ACP is not a precursor to a planned increase of following: infrastructure within Predannack. This ACP is not based upon the requirement for an increase of ground infrastructure and 2. Concern regarding the Infrastructure of the facilities. It is intended to utilise the existing infrastructure. Any surrounding road network particularly due to changes to this would go through the standard planning increasing tourist use within the area coupled processes which would cover the concerns raised. with the potential increased use of Predannack. 2. The provision of Segregated Airspace would permit either UAS to operate or Manned aircraft, there would therefore be no 3.Concern regarding the general increase in significant change in level of potential activity. infrastructure requirements at Predannack associated with this ACP. 3. The level of Emergency cover required would be proportionate to the type of Airsystem operating. In most cases this would be a 4.Concern regarding the increase in reduction from what is already required for Manned aircraft. requirements for Emergency vehicles to transit from RNAS Culdrose to Predannack. 4.This letter was forwarded to the Community Relations Officer to discuss further issues raised to provide mechanisms available to 5.Concern regarding the method of redress if highlight/redress concerns where required. noise, air turbulence or physical damage effects private dwellings. 5. DAATM DAATM supported the ACP but highlighted the 1. Airspace activation will be overseen by RNAS Culdrose Air following points for inclusion: Operations. Where Activation is required this will necessitate service to be provided by RNAS Culdrose, such as Emergency 1.Ensure Flexible Use of Airspace (FUA) Cover and DACS provision. Further UAS operations will affect principles are considered to ensure the RNAS Culdrose organic manned operations. Therefore, intended airspace is not activated unnecessarily. UAS operations will be included within the standard Air Station planning cycle. FUA principles will therefore be at the core of the 2. Ensure Effective Level 3 management use of these Areas. processes are established such that clarity is maintained regarding the status of the 2. The use of the Areas will be managed through RNAS Culdrose airspace, thus ensuring access can be Air Operations and utilise the existing system employed within D006. This will require an update of the LoA between FOST,

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approved for other airspace users when safe to RNAS Culdrose and RAF(U) Swanwick. To ensure clarity and to do so. account for any changes that may occur during the Regulatory Decision phase the LoAs will be updated post the Regulatory 3. Approved LoAs are updated with FOST, Decision and prior to Implementation. RNAS Culdrose and RAF(U) Swanwick. 3. A LoA was established between FOST and RNAS Culdrose during a previous activation of Temporary Airspace 2016. This LoA will be use to assist with current LoA amendments to ensure they are completed prior to Implementation. 6. Cornwall Area 1. No Issue with the ACP in principle were 1. The ACP has been designed to be the minimum amount of Outstanding raised. They noted however it is important that required to permit safe operation and therefore limit impact to the Natural Beauty consideration is given to the sensitivities of the surrounding area. Lizard Peninsula and its importance as an Area of Outstanding Natural Beauty (AONB). 2. The ACP design minimises flight overland to provide access to the South Coast Danger Areas. These two elements are key to the acceptance of Cornwall AONBs acceptance of this ACP.

3. Predannack itself 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 any effects on the Environment are monitored.

4. Furthermore there is a single point of contact nominated at Predannack , (Predannack Liaison Officer) that has regular contact with the Environmental agencies, this will ensure any issues are addressed at the earliest opportunity. 10. Grade Ruan 1.The council raised the following concerns: 1. A further stakeholder meeting will be conducted post the Council Regulatory Decision and prior to Implementation, in accordance 2. Any ACP should be considered in the with the actions agreed during the stakeholder consultation context of current helicopter flight patterns. meeting. This meeting will be principally aimed at keeping Ruan council informed of the Implementation process. 3.The potential for cumulative impact should be considered. 2. All UAS flights will remain within the segregated airspace and will therefore not operate above 8000ft or beyond the lateral

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4.Timings, flight paths and heights of drones dimensions specified within the ACP. Each UAS will be operated should be clarified with written assurances and in accordance with its own Release to Service documentation or the opportunity for future consultation and equivalent. This documentation places specific limitations on the regulation. method of operation, including flight over built up areas and issues not already covered by the Air Navigation Order. 5.All flights should give due consideration to Holly Sites. 3. Due to the nature of UAS it is likely noise levels will be less than that caused by manned aviation. Further the intent is 6. All flights should give due consideration to primarily to enable UAS to access the South Coast Danger schools. Areas. The ACP has been designed to launch the UAS directly to the South West away from built up areas, thus reducing 7. All flights should give due consideration to potential exposure. residential areas. 4. Garde Ruan is within the 3nm radius of the proposed Danger 8. All flights should give due consideration to Area around Predannack therefore the council will be invited to AONB. the standard Predannack stakeholders meeting to enable early identification of any issues experienced by the parishioners and 9. All flights should give due consideration to to maintain good lines of communication. Tourism and economic drivers. 5. In addition to the standing meeting RNAS Culdrose has a Community Relations Officer who can be contacted if any issues arise that require immediate resolution.

6. Regarding AONB, Cornwall AONB have been contacted and responded separately.

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Key Findings

21. The following are the key outputs from the analysis which have influenced the development of the ACP from its original design. Those points listed above but not included in the list below are elements that are already present within the original design.

a. Liaison will occur with the nominated National Air Traffic Service (NATS) individual to ensure sufficient time is permitted for incorporation of any Airspace Change into the NATS Swanwick Radar Data Processing systems; 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. Regardless this will not be less than 2 AIRAC cycle periods post a successful Regulatory Decision.

b. A procedure will be established to inform Bristows 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 Cornwall 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 Ruan council informed of the Implementation progress and was agreed to take place during the initial stakeholder meeting

e. Garde 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 (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 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.

Formal Proposal

22. The formal proposal once submitted will be downloadable from the CAA website.

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5. WHAT NEXT

23. The formal ACP was developed in line with the lessons identified within the analysis above. The ACP is now ready for submission and will be submitted to the SARG by late Summer 2018.

Regulatory Decision

24. Following receipt of the document SARG will begin what is termed the Regulatory Decision stage, this itself is broken down into two stages:

a. Documentation Check: SARG will assess whether all the necessary sections of the proposal process have been conducted and the appropriate information has been received by the CAA. During this process, they may require clarification or demand further information is collected and analysed to ensure compliance with the Regulatory process.

b. Case Study: If successful within the Documentation Check a Case Study will be conducted to securitise the proposal and all the associated information, including stakeholder feedback. This again could lead to further clarification of the ACP being required to determine the exact nature of the ACP and its possible effects. A completed Case Study will then be presented to the SARG Group Director to make a Regulatory Decision to either approve or deny the ACP. Post the documentation check a Regulatory Decision will usually be made within 16 weeks.

25. Once a decision has been made by SARG this will determine the following steps, either an amendment will need to be made to the ACP to comply with the Regulatory requirements or if successful the ACP will move to the Implementation Phase.

Implementation

26. During the Implementation phase the ACP will be published using the established Aeronautical Information Regulation and Control (AIRAC) cycle. The AIRAC cycle is a widely-used system within aviation to inform airspace users of relevant changes. This process itself requires a minimum of 56 days to provide sufficient notice to other airspace users of any change.

27. Subject to a successful ACP Regulatory Decision, to ensure non-aviation users as identified during the process are informed of the decision, a further letter will be sent out to inform them of the SARGs decision. Furthermore stakeholder meetings will be held with the Ruan Minor Council and the standard Predannack Stakeholder meeting. These meetings will be conducted during the 56 day Implementation phase and prior to any activation.

Post Implementation

28. Once the ACP has been implemented the RN will actively monitor the ACP to ensure it is having the desired effect. This monitoring will be conducted through the following processes:

a. On-going Predannack stakeholder meetings. These meetings will be continued with UAS actively as a standing agenda item. This will allow the non-aviation stakeholders to engage with the monitoring process.

b. RNAS Culdrose Public Relations Officer. RNAS Culdrose employs a Community Public Relations Officer who has established good relations with the local community and surrounding parishes. This allows non-aviation stakeholders to engage with the monitoring process on a routine process outside of formal meetings.

c. Established Safety Management System. The RN has a robust Safety Management system that will actively monitor the use of the established airspace. Where an issue is

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identified, it is investigated. Any subsequent findings or suggestions generated are subject to both internal and external assurance processes to ensure the system is working effectively. This will ensure continuous improvement in the safe, efficient use of the airspace.

d. RNAS Culdrose Point of Contact. Contact details for RNAS Culdrose are included within the AIP, this will enable non-military airspace users who do not have an established relationship with RNAS Culdrose to engage with the monitoring process.

e. Letters of Agreement with aviation stakeholders are reviewed yearly. This will provide an opportunity to ensure enduring amendments as identified through any of the above mechanisms.

29. One year after implementation SARG will carry out a post implementation review to assess and validate the success of the ACP.

Anticipated Pathway for Implementation

Case Study and IMPLEMNTATION Intended date of Post ACP Submission Documentaiton Regulatory -, 1st AIRAC esablishment Implementation - Summer 18 Check - 4 weeks Deisicon - 16 release 9 May Ongoing weeks 2019 18 July 2019 monitoring

Figure 4 - Pathway for Implementation

30. This is the intended programme for implementation and assumes a successful Regulatory Decision. This will however be subject to change and could increase if clarification is required at any stage.

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