Royal Navy Air Station Culdrose Predannack Airspace Change Proposal Consultation Feedback
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Royal Navy Air Station Culdrose Predannack Airspace Change Proposal Consultation Feedback Date 13 August 2018 Airspace Consultation Response 700X NAS RNAS Culdrose Cornwall 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 1 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 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 2 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 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. 4 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. 5 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. 6 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. 7 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.