Safety and Airspace Regulation Group

REPLACEMENT OF CLASS F AIRSPACE IN UK FLIGHT INFORMATION REGIONS

CONSULTATION REPORT

Published by: Safety and Airspace Regulation Group Civil Aviation Authority CAA House 45 – 59 Kingsway London WC2B 6TE

Replacement of Class F Airspace in the UK FIRs - Consultation Report

Contents Page Number

INTRODUCTION 1 CONSULTATION Conduct of the Consultation 1 Options Presented 1 Consultation Response Analysis 2 Key Issues and Themes 4 Modification of CAA Proposals 7 Addendum Consultation 7 Final Proposals for Change 10 Disestablishment of W2D 12 What the Proposed Changes do not Include 12 The Need for Class E+TMZ CONOPS 13 CAA Safety Buffer Policy 15 Environmental Impacts 15 Legislative Change 15 Target Implementation Date 15 Aeronautical Information Change 16 Implementation Awareness Activities 16 Summary of Project Milestones 16 ANNEXES A - Class F Airspace Replacement - Stakeholders A-1 B - Class F Airspace Replacement – Consultation Comment and B-1 Responses C - Summary of CAA Final Proposals for the Replacement of Class F C-1 Airspace in the UK FIRs ENCLOSURE Summary of CAA Final Proposals for the Replacement of Class F

Airspace in the UK FIRs - map

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INTRODUCTION

1. On 8 April 2013, the Civil Aviation Authority (CAA) launched a consultation on its proposals for the regularisation of all Class F ADRs as Class E airways that would additionally be notified as Transponder Mandatory airspace by the end of 2014. Such Regularisation was required in response to the findings of the ICAO Universal Safety Oversight Audit Programme (USOAP) inspection of the UK conducted during February 2009 and consideration of the requirements of the Standardised European Rules of the Air.

2. As part of its consultation the CAA presented five options for the replacement of Class F airspace and presented a number of issues for consideration by stakeholders and invited comment on these.

3. The consultation was originally due to end on 12 July 2013, however this was extended to 26 July 2013 to allow stakeholders additional time to consider supplementary consultation material provided by the CAA. Comments from the consultation were examined in detail by CAA staff, which led the CAA to refine its proposals prior to notifying industry of its preferred way forward.

4. A supplementary consultation was undertaken between 8 October 2013 and 4 November 2013. This was necessary in order to take account of the need for additional Class E ‘fillets’ in the vicinity of the Aberdeen Control Zone/Control Area which had not been foreseen in the original consultation.

5. Comments from the supplementary consultation have also been considered in detail by CAA staff; these too led to further refinement of the proposed changes. Together these have informed the development of the CONOPS which will form the basis of operations within the subject airspace.

6. The purpose of this report is to inform industry of the outcomes of the consultations and of the proposed way forward with the replacement of Class F airspace in the UK FIRs.

CONSULTATION

Conduct of the Consultation

7. NATMAC members plus selected additional stakeholders were directly consulted. In addition, general public consultation was undertaken by means of publishing the consultation material on the CAA website; this approach applied to both initial and addendum consultations and attracted a number of unsolicited responses. In support of the addendum consultation, NATS Aberdeen undertook to brief affected local airspace users and service providers. A list of identified stakeholders is at Annex A (individual members of the public who submitted unsolicited comments are not listed, however their comments are incorporated into the collation of consultation comments and CAA responses at Annex B).

8. The purpose of the consultation was to seek industry comment on the CAA’s proposals and to refine these accordingly prior to their implementation. Such refinement would result in the disestablishment of certain ADRs or their reclassification to a more appropriate classification of airspace.

Options Presented

9. Five options for the replacement of Class F airspace were presented to stakeholders in the initial consultation:

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a. Option 1 - Do Nothing.

b. Option 2 - Replacement of all existing Class F airspace by controlled airspace (CAS), i.e. Classes A-E.

c. Option 3 - Replacement of all existing Class F airspace by Class G airspace.

d. Option 4 - Replacement of all existing Class F airspace by CAS and Class G on a case by case basis.

e. Option 5 - Replacement of all existing Class F airspace by Class E airspace designated Transponder Mandatory airspace in accordance with CAA Directorate of Airspace Policy (DAP) policy for Transponder Mandatory Zones (TMZs), without increase to the lateral or vertical dimensions of current ADRs. Where justified, and in exceptional circumstances, reduce vertical limits, disestablish specific ADRs or reclassify ADRs to a more restrictive classification.

10. Option 5 was the CAA’s preferred option; however the CAA acknowledged that consultation could identify circumstances that would dictate either the removal of specific routes (primarily on exceptionally low utilisation grounds), reductions to the vertical limits of particular routes, or reclassification to a classification more restrictive than Class E (primarily on high utilisation grounds).

11. Launched on 8 April 2013, the consultation was originally due to end on 12 July 2013, however this was extended to 26 July 2013 to allow stakeholders additional time to consider supplementary consultation material provided by the CAA. Comments from the consultation were examined in detail by CAA staff, which led the CAA to refine its proposals prior to notifying industry of its preferred way forward.

Consultation Response Analysis

12. 37 organisations or individuals responded either directly or indirectly1,2,3 to the initial consultation. A breakdown of the nature of respondents is at Figure 1. As shown in Figure 2, 22% of responses were assessed as being supportive or broadly supportive of the CAA’s preferred option, while 76% opposed it. Response by stakeholder group is at Figure 3. Note that all opposition by individuals is attributable to members of the paragliding/hang gliding sector.

13. 75% of respondents advocated the replacement of all existing Class F airspace by Class E airways with Transponder Mandatory status or Class G on a case by case basis and/or by reducing the lateral and vertical limits particular routes for which there was a case for retention as a Class E airway as proposed (Figures 4 and 5). These responses were considered to demonstrate broad support for the principles of Option 4, whilst also validating the CAA’s recognition that consultation could identify cases for both within the context of Option 5. All respondents supported the CAA’s proposal to disestablish W2D, and none advocated the application of Class A to D airspace in lieu of Class F.

1 The General Aviation Alliance represented: British Balloon and Airship Club, British Hang Gliding and Paragliding Association, British Gliding Association, British Microlight Aircraft Association, British Parachute Association, Helicopter Club of Great Britain, Light Aircraft Association and PPL/IR. 2 The Defence Airspace Group represented: Director Army Aviation, Military Aviation Authority, Ministry of Defence (MOD) Defence Equipment and Support, and 3rd Air Force-Directorate of Flying. 3 NATS En Route Ltd represented NATS Services Ltd in their response

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1 2 NATMAC member organisations

airspace user companies or 8 groups 18 airspace user individuals

ATS providers

airport operators 8

Figure 1: Initial consultation respondents by group

14%

support 8% 3% broadly supportive 0% neutral broadly unsupportive 76% oppose

Figure 2: Response to Option 5

14 support broadly supportive 12 neutral 10 broadly unsupportive 8 oppose 6 4 2 0 NATMAC airspace user airspace user ATS providers airport operators others member companies or individuals organisations groups

Figure 3: Response to Option 5 by stakeholder group

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14. Opposition from individual airspace users centred upon the vertical limits of the resultant airspace were Option 5 implemented, and/or on the implications of Transponder Mandatory status upon paragliding and hang gliding activity. Half of individual airspace users who opposed Option 5 advocated limiting Transponder Mandatory status to FL100 and above.

22% 24% support 0% 3% broadly supportive neutral broadly unsupportive oppose 51%

Figure 4: Support for the Principles of Option 4.

16 support broadly supportive 14 neutral 12 broadly unsupportive 10 oppose 8 6 4 2 0 NATMAC airspace user airspace user ATS providers airport operators others member companies or individuals organisations groups

Figure 5: Support for the Principles of Option 4 by stakeholder group

Key Issues and Themes

15. The CAA sought stakeholder comment on a number of key issues; in addition, consultation presented a number of additional themes. These are summarised as follows:

a. Volume of Proposed Controlled Airspace. The most commonly expressed concern was related to the impacts of the volume of the proposed Class E+TMZ upon military and recreational General Aviation sectors. Whilst the need to replace Class F was acknowledged by almost all stakeholders, the impacts associated with the original proposals were unacceptable to many, the principle issues being the lack of suitable transponders and radios for gliders, paragliders and hang gliders. Most stakeholders suggested alleviation of these impacts through general increases in base levels to

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allow non-transponder and non-radio flight beneath the resultant airways. A small number submitted detailed suggestions for change according to route (see next section); the remainder advocated replacement of ADRs solely through reversion to Class G. The input afforded the CAA the opportunity to reconsider and refine its proposals.

b. VFR Access to Class E+TMZ. A number of stakeholders sought clarification of the status of VFR traffic within the replacement airspace, whether the need for ATS would be mandatory, and what level of ATS would be provided. CAA analysis of ICAO, CAP493 MATS Part 1, CAP774 UK Flight Information Services and the UK AIP revealed minor inconsistencies in the manner in which Class E is explained in the AIP; these have subsequently been corrected. CONOPS appropriate to the replacement airspace have been developed – these are highlighted later in this document (see page 13).

c. Blanket Replacement of Class F by Class E+TMZ. A small number of stakeholders queried the appropriateness of replacing Class F with a single airspace classification, while others challenged the CAA’s conclusion that it represented the minimum level of impact upon airspace users. The CAA had originally considered the need for a route-by-route airspace change, however over time it proved necessary to rethink its approach, such that the replacement of Class F by a single classification was considered the most appropriate route to take. In terms of the impacts of the proposed way forward, the CAA concluded that the overall impact of Class E + TMZ as proposed represented the minimum impact upon airspace users generally.

d. ADR Utilisation Levels. It was considered appropriate to provide outline information regarding ADR utilisation in the original consultation material (but was not necessary for the addendum consultation). The value of this information was questioned by some stakeholders – the data was intended to provide a snapshot of utilisation and not detailed analysis.

e. ATS Delegation. Inverness Radar provides a radar service for traffic to and from Inverness via N560D and W6D during the promulgated hours of Inverness Radar as published in UK AIP AD 2-EGPE-2.18 (and as amended by NOTAM). The impacts of reclassification of these routes upon the ATS provision arrangements (both in terms of reclassification and changes to longitudinal and vertical limits) will need to be considered by the affected stakeholders.

f. Conditional Routes (CDRs). Consultation responses did not identify any requirements for CDR status. However the requirement for one CDR was subsequently identified and agreed to.

g. Costs/Route Charges. Service provider stakeholders acknowledged that implementation costs – mostly training-related - would be incurred, but that these could not be quantified until the CAA’s decision to replace Class F had been announced. The MOD and NATS additionally indicated that documentation change and systems adaptation costs would arise. Recreational aviation stakeholders stated that the cost of transponder and radio equipage would be prohibitive but no quantification was provided. Aberdeen International Airport’s indications of the costs to the airport and the local economy of not introducing the ‘Aberdeen fillets’ informed the CAA’s decision to proceed with the addendum consultation. Finally, stakeholders did not identify any service-related cost recovery issues in consultation responses.

h. CNS and Other Resource Impacts. It was assumed that there would be no changes to current CNS coverage. The CAA’s final proposals take into account those

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put forward by NATS in response to consultation and are deemed to comply with CNS requirements in CAP670 ‘Air Traffic Services Safety Requirements’. i. CAA Airspace Safety Buffer Policy. See paragraphs 36-38 below.

j. Divisional Flight Level (DFL). The regularisation proposals do not impact upon the DFL, and none of the ADRs will be reclassified Class A-D. NATS are pursuing a separate ‘Class C Stubs’ airspace change proposal for specified portions of airspace above FL195 in order to provide route connectivity to upper air routes.

k. Flexible Use of Airspace (FUA). As stated above, no requirements for CDR status were identified during consultation, although the need for one CDR was subsequently identified and agreed to. This will be available only during major military exercises, and promulgated as active as part of the exercise notification process. One of the proposed ‘Aberdeen fillets’ overlaps part of EGD613A; compliance with CAA buffer policy requirements was necessary – further details can be found at paragraphs 36-38. Stakeholders may wish to consider FUA solutions to mitigate the impacts of regularising Class F ADRs to transponder-mandatory Class E airways.

l. Flight Planning. No flight planning issues arising from the establishment of Class E+TMZ airways have been identified. Where routes are to be disestablished and the airspace reclassified as Class G it remains possible to file IFR or VFR Flight Plans based upon established waypoints where these remain in place. It would also be possible to file ‘DCT’, with associated routeing advice appearing in individual aerodrome AD2 entries. Amendments to the Route Availability Document will be required to allow operators to plan specific DCT routes through Class G airspace where ADRs have been disestablished.

m. Impacts On/Relationships With Adjacent Airspace Structures. Stakeholders were asked to consider the impacts of any change to ADRs associated with extant airspace structures including SIDs, Standard Arrivals, airspace restrictions and interfaces with adjacent FIRs. The CAA’s proposals will impact upon one Glasgow SID. Several ADRs interface with the Brest, Shannon or Stavanger FIRs; no indications of adverse impacts were received regarding these.

n. Northern Periphery Programme 2007-2013. This European Union (EU) programme aims to help peripheral and remote communities on the northern margins of Europe to develop their economic, social and environmental potential. No comments were received regarding the impacts the change proposals would have upon this Programme.

o. Public Service Obligation (PSO). Routes to the Scottish Highlands and Islands are examples of air transport PSOs currently in operation in Europe and any proposals to disestablish routes along which such services are currently operated must consider the possible impact upon PSO operations. Stakeholder comment was invited; two comments were elicited. GATCO stated that disestablishment of Class F routes utilised by PSO flights would be contrary to the spirit of EU transportation law, whereas reclassification to Class E would be compliant. The MOD stated that the ADRs serving PSOs could be reclassified as Class G routes and still meet this intent thorough the provision of UK FIS. Neither comment was considered conclusive, as a number of Scottish air transport PSO routes are already undertaken in Class G, and some would be served by Class E+TMZ airways following reclassification.

p. RNP/RNAV Type. No changes to RNP/RNAV type as currently stated in AIP ENR 3.1 are envisaged. In line VOR navigation beyond SUM VOR 50D to PETOX may not comply with RNP 5.

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q. Safety Occurrences. It was considered necessary to undertake a detailed study of safety occurrences to identify the need to replace Class F airspace by a classification other than Class E. In the event no such requirement emerged.

r. Scottish TMA. No related issues arose in the course of consultation.

s. Service Provision. Were ADRs to be replaced by Class A-D airspace it would have been necessary to assess the consequences to service provision and controller licensing. In the event no such requirement emerged.

t. VFR Flight Along the Axis of Class E Airways. Rule 19 of Rules of the Air 2007 states that an aircraft flying in VMC along a Class C airway at any level shall, unless complying in accordance with an authorisation from the CAA, be flown as if the flight were an IFR flight. There is no such provision for flight along Class D or E airways; stakeholders were invited to comment on the need for an equivalent provision, noting that no such provision appears in ICAO Annex 2, Annex 11 or SERA. No stakeholder comment was received regarding this issue, which will not be pursued further.

Modification of CAA Proposals

16. Consultation responses prompted the CAA to reconsider its original proposals. Detailed consultation responses advocating combinations of whole or partial route replacement (i.e. raised base levels and/or route truncation) and complete disestablishment of ADRs had been submitted by several stakeholders4. In addition, although the Ministry of Defence (MOD) advocated the disestablishment of all ADRs, it did acknowledge that there could be possible justification for the retention of certain routes as Class E transponder mandatory airways. In its analysis of consultation responses, the CAA compared these suggestions and noted significant similarities amongst them.

17. The CAA subsequently met with these key stakeholders plus Highlands & Islands Airports Ltd and Loganair to discuss and progress their suggestions towards consensus on the way forward. Were consensus not possible, then the closest possible alignment of proposals would be sought in order to progress the CAAs plans for the replacement of Class F airspace.

18. Further progress was made in understanding airspace user group and service provider requirements, including the requirement for additional ‘fillets’ that would abut the Aberdeen CTR/CTA (see ‘Addendum Consultation’ below). While consensus was not achieved, greater alignment of opinion was and both the CAA and the participating stakeholders gained further understanding of each other’s airspace requirements and operating constraints.

19. The CAA’s proposals were subsequently further refined to those summarised in Annex C and illustrated in the Enclosure. It is these refined proposals that will now be proposed for implementation (see also paragraph 38).

Addendum Consultation

20 The CAA’s original consultation highlighted the fact that reclassification of each of the ADRs converging over the ADN VOR as originally proposed would place considerable constraints upon Aberdeen ATC as they would be required to comply with the Manual of Air

4 BAE Systems, NATS, the Scottish Hang Gliding & Paragliding Federation, the British Hang Gliding & Paragliding Association and the General Aviation Alliance

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Traffic Services Part 1 (MATS Part 1) requirement for air traffic control (ATC) not to vector aircraft outside the horizontal or vertical limits of controlled airspace (CAS) unless an aircraft has planned to leave it. This would result in a significant amount of traffic being funnelled into the specific parts of the Aberdeen Control Zone/Control Area (CTR/CTA), and thus a reduction in current ATM and airspace efficiency in the vicinity of Aberdeen. It would also increase controller workload and potentially reduce safety. It would additionally impact the CAA’s aspiration that ‘There are no plans to change where aircraft physically fly as a result of the proposed regularisation’ and generate adverse environmental impacts.

21. It was therefore necessary to consider the establishment of additional Class E airspace in the vicinity of the Aberdeen CTR/CTA to avoid the realisation of these impacts. The CAA’s proposals for such additional airspace resulted in an addendum consultation that presented three options to stakeholders:

a. Option 1 - Do Nothing.

b. Option 2 - Establish additional fillets of Class A-D airspace between W4D, W5D and P600D and abutting the current Aberdeen CTR/CTA.

c. Option 3 – Establish additional fillets of Class E airspace between W4D, W5D and P600D and abutting the current Aberdeen CTR/CTA with the airspace additionally designated Transponder Mandatory airspace in accordance with current CAA policy for Transponder Mandatory Zones (TMZs).

Option 3 was the CAA’s preferred option.

NATMAC member organisations 2 airspace user companies or 2 groups airspace user individuals

ATS providers 4 13 airport operators

others

Figure 6: Addendum consultation respondents by group 22. Some 21 organisations or individuals responded either directly or indirectly to the addendum consultation. A breakdown of the nature of respondents is at Figure 6. As shown in Figure 7, 95% of responses were assessed as being supportive of the CAA’s preferred option, while 5% (one response) neither supported nor opposed it. It should be noted that the MOD supported the CAA’s addendum proposal without prejudice to their response to the initial proposals, while the General Aviation Alliance’s support was conditional on the ADRs in the vicinity of the Aberdeen CTR/CTA being retained as Class E airways with Transponder Mandatory status. No statement of opposition to the addendum proposals were received by the CAA. Response by stakeholder group is at Figure 8.

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5%

support broadly supportive neutral broadly unsupportive oppose

95%

Figure 7: Response to addendum consultation proposals

14 support broadly supportive 12 neutral 10 broadly unsupportive 8 oppose 6 4 2 0 NATMAC airspace user airspace user ATS providers airport operators others member companies or individuals organisations groups

Figure 8: Response to Addendum Consultation by stakeholder group

23. The fillets as originally proposed had bases of either 4500 ft amsl or FL75. Simulations undertaken by NATS in February 2014 led NATS to conclude that, while the proposed fillets with FL75 bases provide sufficient airspace to vector aircraft laterally, vertically the airspace is not always sufficient to separate IFR aircraft and facilitate multiple Continuous Descent Approach (CDAs). When multiple aircraft are being vectored and separated, the vertical lack of airspace increases the complexity of operations. It also presents the disadvantage of causing departures to remain under the control of Aberdeen ATC for longer before being transferred to the Moray Sector at Prestwick Centre. This increases workload for both Aberdeen and Moray controllers.

24. Inbound aircraft from the east and north would be held higher than desirable, resulting in an inability to comply with CDA descent profiles whilst remaining inside Class E airspace. This decreases the efficiency of aircraft operations and has workload implications for controllers. The problems are exacerbated when Aberdeen RWY16 is in use. Were the higher base to be retained, these deficiencies are likely to result in aircraft having to be taken out of controlled airspace to achieve descent profiles. This contradicts the requirements of CAP493 (Manual of Air Traffic Services Part 1) Section 1 Chapter 6: ATS Surveillance Systems ‘Vectoring’, which states that unless an aircraft has planned to leave controlled airspace, it is not to be vectored outside the horizontal or vertical limits, except:

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a. When an emergency situation arises requiring the aircraft to be vectored outside controlled airspace;

b. When avoiding severe weather; the circumstances must be explained to the pilot before the aircraft leaves controlled airspace;

c. When specifically requested by the pilot.

Not lowering the bases of the proposed FL75 fillets would also negate the rationale for the fillets, however operations at Aberdeen would be significantly impacted without them.

25. In the light of the consultation findings a common base of 4500 ft amsl is proposed for the fillets. One advantage of this is that it reduces airspace complexity and eases AIP and VFR chart depiction.

Final Proposals for Change

26. Recommended proposals for change are summarised at Annex C and depicted in the Enclosure. Of the ADRs currently established:

a. Disestablishment of A1D, N160D, N552D, N553D and W928D in toto is recommended due to low utilisation and/or partially insufficient CNS coverage. Disestablishment in toto of W2D is addressed in paragraph 23 above

b. Partial replacement of N560D by a Class E+TMZ airway between GOW and KOKAL is recommended. This is due to due to reduced levels of utilisation towards its northern limit (i.e. KOKAL-SUM) and/or partially insufficient CNS coverage. This route links Kirkwall to Central Lowland Scotland and beyond; it is acknowledged that redesignation of the route as a Class E+TMZ airway presents impacts upon sporting and recreational flying in Scotland. Such impacts are mitigated to the greatest possible extent through variable base levels as follows:

i. GOW-ERSON FL195/FL55. The current base of 6000 ft/FL60 is considered inappropriate in that is does not follow the global convention of containing airways within controlled airspace such that the minimum level is determined by a Minimum Obstacle Clearance (MOC) of 1000 feet, with a base of half MOC (i.e. 500 ft beneath it. In this instance a base of FL65 is not feasible because:

aa. The Glasgow FOYLE SID would not connect to N560. Approximately half a dozen movements use this procedure, made up of scheduled, charter and ad hoc operations (and while the former are predictable, the remaining two types of operation are not). Aircraft operating on the SID (and subsequent ADRs) range from relatively low-performing PA38s, through TBM700s, twin light turboprop types to turboprop regional airliners and jet airliners. Regular users include Dornier 328s, Saab 340s, Beech 200s and Boeing 757s. The proposed disestablishment A1D and anticipated (by Highlands and Islands Airports Limited) increases in oil exploration-related fixed-wing operations at Inverness and Wick are likely to result in greater utilisation of this procedure in the future.

bb. A six-month sample of Glasgow traffic revealed that the levels achieved by FOYLE departures as they leave the Scottish TMA range from a minimum of 6000 ft to a maximum of 11000 feet; the mean was 6450 feet.

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cc. A similar sample of Glasgow traffic revealed that the levels flown by arrivals via FOYLE as they approach the Scottish TMA range from a minimum of 6018 feet to a maximum of 19000 feet; the mean was 10500 feet.

dd. On occasions where the inbound Minimum Stack Level was FL60, aircraft would have to operate below the base of controlled airspace.

ii. ERSON-GUSSI FL195/FL105. The base has been raised to facilitate recreational and military operations beneath the airway. Further scope exists for local operating agreements to allow for enhanced access to the airspace in specified circumstances and in accordance with specified conditions.

iii. GUSSI-INS-BONBY FL195/FL95. This section requires a higher base level of FL95 because of insufficient communication and surveillance coverage between GUSSI and INS. There is also insufficient navigation coverage below 6,000ft 48nm north of GOW for about 25nm

iv. BONBY-WIK-KOKAL FL195/FL75. The base of this portion of N560D is increases from FL50 and (in the Kirkwall area) 3000 feet amsl.

b. Partial replacement of N562D is recommended due to low utilisation and/or partially insufficient CNS coverage. That part between TRN and MAC between FL105 and FL195 to be retained as a Class E+TMZ CDR2, available only during notified military exercise periods.

c. Partial replacement of N580D is recommended due to low utilisation and/or partially insufficient CNS coverage. That part between GOW and TIR to be retained as a Class E+TMZ with a base of 5500 ft amsl between GOW and BRUCE, thereafter increased to FL115. The route retains connectivity to NAT and becomes a main flight plannable arrival route into the Scottish TMA.

d. Replacement of P600D by a Class E+TMZ airway is recommended between ADN and BUDON. Disestablishment of P600D beyond BUDON is recommended due to insufficient CNS coverage below FL195. A base altitude of 4500 ft amsl to be established over the sea to 14 nautical miles north east of Aberdeen, thereafter the base rises to Fl75 to 24 nautical miles thence FL105 to BUDON. Additional fillets in the vicinity of the Aberdeen CTR/CTA are required to maintain safe and efficient air traffic management as described in paragraphs 20-22 above.

e. Replacement of W4D by a Class E+TMZ airway is recommended. A reduced upper level is proposed from 17nm north of ADN to permit greater flexibility for local military users to fly over and under the airway. The base between ADN to 17 nautical miles beyond ADN to be increased to 4500 ft amsl, thereafter to FL75. Additional fillets in the vicinity of the Aberdeen CTR/CTA are required to maintain safe and efficient air traffic management as described in paragraphs 20-22 above. Traffic levels in the WIK area are expected to be maintained or increase as a result of oil-related traffic operating to and from the Shetland Basin.

f. Replacement of W5D by a Class E+TMZ airway is recommended with an increase in base altitude from 4000 ft amsl to 4500 ft amsl to a range of 14 nautical miles, thereafter FL75 or above (increased from FL70) to 23 nautical miles south of SUM, at which point the base returns to 4500 ft amsl to SUM. It should be noted that most of the latter portion lies within the Class D Sumburgh CTR/CTA. Additional fillets

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in the vicinity of the Aberdeen CTR/CTA are required to maintain safe and efficient air traffic management as described in paragraphs 20-22 above.

g. Replacement of W6D by a Class E+TMZ airway (with an increase in base altitude to FL95 from INS to ULLAP, thereafter 5500 ft amsl to STN) is recommended.

i. Partial replacement of W911D is recommended, insufficient utilisation to justify full retention. That part between IOM and BOYNE to be retained as a Class E+TMZ airway affording en-route connectivity between the Isle of Man and Dublin with a base of 5500 ft amsl between GOW and BRUCE, thereafter increased to FL115. This will reduce the impact of reclassification upon BAE Systems operations out of Warton.

j. Partial replacement of W958D is recommended due to low utilisation and/or partially insufficient CNS coverage. That part between BRUCE and a point 37.8 nm north west of BRUCE to be retained as a Class E+TMZ airway with a base of FL115. . This is based upon the descent profiles and general performance levels of modern aircraft. The route retains connectivity to NAT and becomes a main flight plannable arrival route into the Scottish TMA.

27. These proposals are summarised at Annex C and depicted in the Enclosure.

Disestablishment of W2D

28. None of the stakeholders who submitted detailed responses advocating the modification or disestablishment of specific routes opposed the CAA’s proposed disestablishment of W2D. Although the consultation document stated that disestablishment of W2D could be anticipated before March 2014 (the consultation document additionally stating that the definitive date would be included in the Consultation Report), modification to the CAA’s change proposals combined with the need for the addendum consultation and delays to the completion of the CAA’s consultation report render this option impractical. Disestablishment as part of the overall change is now proposed.

What the Proposed Changes Do Not include

29. Other than the Aberdeen fillets, the proposed changes do not seek to establish CAS around aerodromes served by the current ADR structure, nor do they seek to establish connectivity between and en-route airspace where extant CTRs/CTAs are not currently connected to it. These are separate issues for aerodromes to consider as independent airspace change proposals.

30. In 2009, NATS consulted on proposals to modify certain en-route structures above FL195 (so-called ‘Class C stubs’). Development of this proposal was suspended pending the outcomes of the Class F replacement project so as to ensure the closest possible alignment with the post-ADR route structure. NATS has recently re-launched its ‘Class C stubs’ airspace change proposal, details of which can be found on the NATS website.

31. In developing the CONOPS to be applied within the routes replacing ADRs, the CAA has questioned the appropriateness of providing Deconfliction Service to both IFR and VFR traffic in Class G airspace. Proposals to amend the UK Flight Information Services (as detailed in CAP774) to limit the provision of Deconfliction Service to only IFR traffic in Class G airspace have been the subject of a separate consultation.

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The need for Class E+TMZ CONOPS

32. ICAO Annex 11 Chapter 2 states that IFR and VFR flights are permitted in Class E; IFR flights are provided with air traffic control service and are separated from other IFR flights. All flights receive traffic information as far as is practical. In service provision terms, the change from Class F to Class E will guarantee the provision of ‘air traffic control service’ to IFR traffic. With this comes greater clarity on services to IFR traffic, and a greater consistency of service than could be the case in Class G.

33. With regards to service provision to VFR traffic, stakeholders were invited to comment on current UK service provision arrangements within Class E – specifically the merits (or otherwise) of providing Air Traffic Control Service to communicating flights, and whether or not such provision is to be limited to the designated airspace controlling authority. Limited feedback was received, but nevertheless this informed the post-consultation development of the CONOPS.

34. The draft CONOPS can be summarised as follows:

a. Class E airspace is controlled airspace in which IFR and VFR flights are permitted, but only IFR flights are subject to ATC clearance.

b. VFR pilots in Class E airspace must be aware of the Class E airspace VMC and the need for separation based on the ‘see and avoid’ principle.

c. IFR pilots in Class E airspace need to be aware that despite being in receipt of an ATC clearance, they may be required to manoeuvre in order to comply with Rules of the Air Regulations 2007 Rule 8, and shall advise ATC whenever this is necessary.

d. ATCOs need to understand that pilots of IFR flights may need to vary from their clearance in order to comply with Rules of the Air.

e. VFR aircraft within Class E airspace that is also notified as a TMZ shall carry and operate a Mode S SSR transponder.5

f. VFR aircraft operating without a functioning Mode S SSR transponder shall obtain approval to enter the airspace from the notified airspace controlling authority. Such aircraft are required to be either in radio contact with the controlling authority (but would not require a clearance to cross), or to operate in accordance with agreed procedures. Appropriate arrangements for non-radio access by aircraft without an appropriate or functioning transponder may be developed at local level. However, CAA will develop proposed standardised approvals for consideration by airspace controlling authorities. CAA will also develop guidance and RT phraseology for controllers in tactically applying such approvals.

g. All IFR flights shall be subject to an ATC clearance and require continuous two- way communications.

h. VFR flights do not require ATC clearance and, subject to compliance with the notified TMZ requirements, do not require two-way communications.

5 The requirements for the carriage of Secondary Surveillance Radar (SSR) transponder equipment are contained in Article 39, article 40 and Schedule 5 to the Air Navigation Order 2009. Replacement of Class F Airspace in the UK FIRs - Consultation Report 17 April 2014 Page 13 of 16 Replacement of Class F Airspace in the UK FIRs - Consultation Report

i. VFR flights not complying with the notified TMZ SSR requirements require approval to enter the airspace.

j. ATS provision in Class E airspace is determined by the flight rules that the aircraft is operating under.

k. An Air Traffic Control Service (Radar Control Service where surveillance is utilised) shall be provided to IFR aircraft.

l. ATC shall separate IFR aircraft from other IFR aircraft.

m. IFR aircraft shall be provided with traffic information, as far as is practical, on VFR aircraft. The controller shall update the traffic information if it continues to constitute a definite hazard, or if requested by the pilot.

n. IFR flights shall be provided with avoiding action when requested by the pilot. If the pilot reports that he has the unknown aircraft in sight further controller action may then be limited to passing traffic information. Provision of collision avoidance advice to IFR flights is considered to be addressed through extant ‘duty of care’ and does not need to be explicitly prescribed with regard to Class E airspace.

o. VFR flights are not separated.

p. VFR flights that request an ATS shall be provided with traffic information as far as practical. This shall be achieved through the provision of a UK Flight Information Service as requested by the pilot, subject to ATS unit capability to provide the requested service.

q. IFR flights transitioning from Class G to Class E airspace and vice-versa will be advised of ATS changes as per normal ATC procedures for entering and leaving controlled airspace.

r. VFR flights in receipt of an ATS and identified using surveillance systems transitioning from Class G to Class E airspace will be advised that they are entering Class E airspace and to maintain VMC.

s. VFR flights in receipt of an ATS and identified using surveillance systems transitioning from Class E to Class G airspace will be advised that they are leaving Class E airspace.

t. VFR Flights that have not been identified using surveillance systems may be instructed to report entering/leaving Class E airspace. Established reporting points and geographical points may also be employed as necessary.

u. IFR and VFR flights transitioning from Class A/C/D airspace into Class E airspace shall be advised by ATC that they are entering Class E airspace.

v. IFR flights transitioning from Class E airspace into Class A/C/D airspace shall be advised of the change in airspace classification.

w. VFR flights in receipt of an ATS in Class E airspace and transitioning into Class C-D airspace must request a clearance, and subject to such a clearance, they will be advised of ATS changes as per current procedures.

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x. If a pilot of a VFR aircraft reports that they are unable to maintain VMC and are able to continue flight under IFR, ATC shall provide Radar Control (if in contact with a unit authorised to provide such service) and separate aircraft as soon as practical. Reduced vertical separation may be applied as necessary until standard separation is able to be applied. Essential traffic information shall be provided.

y. ATC units may need to develop proposals for CAA approval to provide SSR only services, as currently provided in Class F airspace, for its direct replacement as Class E.

35. The CONOPS do not capture any local operating agreements that are intended to facilitate airspace access under FUA arrangements, nor are they intended to.

CAA Safety Buffer Policy

36. CAA safety buffer policy requirements have been mostly answered as there are no changes to the lateral limits of the proposed replacement airways where these abut airspace restrictions, nor are there changes to the airspace restrictions themselves. Therefore the stipulated criteria are not required to be applied retrospectively where existing airspace arrangements have been proved safe through operational use.

37. One of the proposed ‘Aberdeen fillets’ overlaps part of EGD613A, therefore Flexible Use of Airspace principles must apply in this case. CAA Safety Buffer policy paragraph 2.4 states that ‘ [the CAA] will give careful consideration to a request for a policy dispensation, provided full details of the associated hazard mitigation to justify policy deviation are provided.....occasional activities and/or a airspace sharing arrangements under approved MoU/LoA may also provide suitable mitigation.’ Compliance with CAA Safety Buffer Policy requirements could therefore be achieved through positive ATC management of potentially hazardous activities, dynamic ATM procedures, and use of internal safety buffers for occasional activities, airspace sharing arrangements under approved MoU/LoA, any combination of these, or indeed any other agreed solutions.

38. In this case, NATS will continue to apply current ATM techniques to aircraft operating within the proposed Class E+TMZ fillet in the vicinity of EGD613A (Central MDA). While Deconfliction Service is currently provided to affected aircraft in Class G airspace, following the establishment of the fillets it will be necessary for Radar Control to be provided. In short, MOD operations retain primacy when EGD613A is active and Aberdeen ATC will vector aircraft clear of military activity within EGD613A. NATS have stated that they will review their hazard analysis after a 12 month period to ensure continued assurance that safety is being maintained.

Environmental Impacts

39. The CAA’s proposals do not intend to significantly change where aircraft physically fly as a result of the proposed regularisation. The volume of aircraft flying along or adjacent to the affected airspace is variable, particularly in Class G airspace. Similarly, the nature of aircraft operations within Class G is variable, with aircraft numbers and where they operate when away from aerodromes is essentially unpredictable. Therefore any meaningful assessment of the environmental impacts of the change proposals is not possible, and therefore one has not been undertaken.

Legislative Change

40. There are no UK legislative changes associated with these proposals.

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Target Implementation Date

41. Class F airspace is to be replaced on an AIRAC date no later than 13 November 2014 (AIRAC 12/2014), the target implementation date being 18 September 2014 (AIRAC 10/2014). The actual implementation date will be confirmed in the CAA’s decision letter to industry.

Aeronautical Information Changes

42. Introduction of the new arrangements by means of a double AIRAC period of notification for AIP amendments (i.e. 56-days notice) is proposed. An assessment of the extent of textual and chart amendments to the AIP incurred by the change has been undertaken and will feature in the detailed proposals to be submitted for approval by Group Director SARG.

43. The revised arrangements will also incur numerous changes to 1:250k and 1:500k VFR charts. These follow a non-AIRAC publishing schedule that will demand careful management in order to capture all of the changes in a timely manner. Preliminary AIP and VFR chart amendment planning with NATS Ltd Aeronautical Information Service is under way. Early notification of the changes to the MOD’s Aeronautical Information Distribution Unit will be necessary to facilitate timely amendment of affected military documents and charts.

Implementation Awareness Activities

45. It will be necessary to pre-notify the resultant changes to industry. Use of Aeronautical Information Circulars, an AIP Supplement, CAA Information Notices and other media is anticipated. These will primarily be targeted at UK airspace users and are expected to involve CAA Corporate Communications Department.

Summary of Project Timescales

46. Project milestones are summarised as follows:

a. End April 2014 - CAA publishes consultation feedback report.

b. End April 2014 - Submission of final change proposals and submission to SARG AAA for approval.

c. May 2014 - CAA decision and notification to industry, adjacent States and ICAO of this.

d. 1 February-30 November 2014 - CAA undertakes pilot and aircraft operator awareness activities in advance of Class F replacement.

e. June-July 2014 - CAA prepares and submits Integrated Aeronautical Information Package (IAIP) amendments.

f. June-August 2014 - CAA prepares and introduces MATS Pt 1 change material to take effect on a date yet to be confirmed.

g. September-November 2014 - IAIP amendment published to take effect on an AIRAC date yet to be confirmed. Class F disestablished in the UK FIRs.

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Replacement of Class F Airspace in the UK FIRs - Consultation Report

Annex A

Class F Airspace Replacement - Consultees

NATMAC # NAME/ORGANISATION ORIGINAL ADDENDUM NATS CONSULTATION CONSULTATION ABERDEEN BRIEFING 1 Airport Operators Association X X 2 Aircraft Owners and Pilots Association X X 3 British Airways X X 4 BAA plc X X 5 BAE Systems (Warton) X X 6 British Airline Pilots Association X X 7 British Air Transport Association X X 8 British Balloon and Airship Club X X 9 British Gliding Association X X 10 British Helicopter Association X X 11 British Hang Gliding and Paragliding Association X X 12 British Microlight Aircraft Association X X 13 British Parachute Association X X 14 Guild of Air Pilots and Air Navigators X X 15 General Aviation Safety Council X X 16 Guild of Air Traffic Control Officers X X 17 Heavy Airlines X X 18 Helicopter Club of Great Britain X X 19 Light Airlines X X 20 Low Fares Airlines X X 21 NATS (NERL) X X 22 NATS (NSL) X X 23 Light Aircraft Association X X 24 PPL/IR X X 25 SRG (CAA) Safety Regulation Group, CAA X X 26 Unmanned Aerial Vehicle Systems Association X X 27 United Kingdom Airprox Board X X 28 United Kingdom Flight Safety Committee X X 29 Director Army Aviation X X 30 Military Aviation Authority X X 31 Defence Airspace Group X X (representing Director Army Aviation, Military Aviation Authority, MOD (Defence Equipment and Support, 3rd Air Force-Directorate of Flying) 32 MOD (Defence Equipment and Support) X X 33 USAFE (3rd Air Force-Directorate of Flying) X X 34 General Aviation Alliance X X (representing British Balloon and Airship Club, British Hang Gliding and Paragliding Association, British Gliding Association, British Microlight Aircraft Association, British Parachute Association, Helicopter Club of Great Britain, Light Aircraft Association, PPL/IR)

NON-NATMAC AND UNSOLICITED # NAME/ORGANISATION ORIGINAL ADDENDUM NATS CONSULTATION CONSULTATION ABERDEEN BRIEFING 35 Aberdeen International Airport X X 36 Blackpool International Airport X 37 Direction générale de l'aviation civile (CAA France) X 38 Eastern Airways X X 39 Edinburgh Airport X 40 FlyBe X X 41 Gama Group X X 42 Glasgow Airport X 43 Glasgow Prestwick Airport X

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Replacement of Class F Airspace in the UK FIRs - Consultation Report

44 Highland and Island Airports Ltd X 45 Irish Aviation Authority X 46 Isle of Man Airport X 47 Leeds/Bradford International Airport X 48 Loganair X X 49 Luftfartstilsynet (CAA Norway) X 50 Scottish Executive X X 51 Avinor X 52 bmi regional X 53 Sandair X 54 Mr Tim Pentreath X 55 Mr Andrew Craig X 56 Mr Iain Robertson X 57 Mr Alex Butler X 58 Lanark and Lothian Soaring Club X 59 Mr Ian Kennedy X 60 Scottish Hang Gliding Paragliding Federation X 61 Mr Anthony Shepherd X 62 Mr Mike Jardine X 63 Mr Stewart Reid X 64 Pennine Soaring Club X 65 Ozone Gliders Ltd X 66 Ms J White, ATC Instructor, NATS X 67 NATS Aberdeen X X 68 Aberdeen International Airport Consultative Committee X X 69 Aberdeen Light Aircraft Association X X 70 Bond Helicopters X X 71 Bristow Helicopters X X 72 Buchan Aero Club X X 73 Cabro Aviation X X 74 CHC Scotia Helicopters X X 75 Dyce Flying Club X X 76 Grampian Microlight Flying Club X X 77 Hatton aerodrome X X 78 HJS Helicopters Ltd X X 79 Longside Flying Club X X 80 Whiterashes aerodrome X X 81 M McDonald (MSP Aberdeen Donside) X 82 Nestrans (North east of Scotland Transport) X 83 RAF Boulmer X 84 RAF Lossiemouth X

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Annex B

CLASS F AIRSPACE REPLACEMENT - CONSULTATION COMMENTS AND RESPONSES

INITIAL CONSULTATION

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE 1. Para 1.1.1 Scottish Hang Gliding & The SHPF recognise that the CAA must reclassify current class F airspace to The SHPF’s recognition of the need to replace Class F airspace is welcomed by Paragliding Federation meet EU and ICAO requirements. However, given that the current class F the CAA. airspace has existed since the 1980s, it seems fair that all stakeholders wishes All responses to this consultation have been given due consideration and have are considered properly and appropriate time is given by the CAA to the needs informed the various changes the CAA has made to its original proposals. It is of all airspace members including SHPF members. not the intention of the CAA to discriminate against any affected airspace user. 2. Para 1.1.3 BAE Systems Warton It is questionable whether the CAA, in proposing to regularise all Class F ADRs The CAA is satisfied that it is meeting the requirements of the Airspace Change as Class E airways notified as Transponder Mandatory airspace, is complying Process. The proposal is in response to the 2009 ICAO USOAP inspection and fully with its own statutory obligations as outlined in CAP 725. In that document, as such represents not only an airspace change but a policy change. As the it states that “An airspace change is normally characterised by (one or more of proposal is intended to result in minimal change, and does not in itself propose the following Conditions) Changes to the International Civil Aviation Organization changes to published procedures, wider consultation with identified non-aviation (ICAO) airspace classification either through the creation of a higher consultees was not considered necessary. Also much of the subject airspace is classification than currently exists, or through the removal of existing controlled established over the sea or over remote areas of the UK. In any case, the airspace of Classes A, C, D or E”. The issuance of this consultation document consultation has been notified to the public by means of a CAA information does not contain all the information required by other Change Sponsors, such as Notice and a Press Release. consultation with local councils, provision of full usage data, environmental factors etc. Indeed, the list of consultees at Annex C, with the exception of the Scottish Executive, contains organisations that are all related to aviation. Moreover, it is not clear why a change to Class E does not require the full ACP process to be followed when a change to Class D, if considered necessary, does – both are changes to higher classifications of airspace. 3. Para 1.1.3 BHPA The basic principle that has to be applied to the airspace under consideration in Noted. All responses to this consultation have been given due consideration this proposal is contained within the CAA’s paper “Class G Airspace for the 21st and have informed refinement of the proposals. As a result, a significant Century: proportion of current Class F airspace is likely to revert to Class G. “It is only by the use of Class G airspace, and the application of other airspace classifications set out in the ICAO Airspace Classifications Policy Statement15, that the CAA, on behalf of the UK, can ensure that the requirements of owners and operators of all classes of aircraft are met. It is this principle that the least restrictive classification of airspace (Class G) should be the norm, with more restrictive classifications only being established where necessary, that is one of the key means by which the CAA meets its statutory obligations for the safe efficient use of airspace permitting the expeditious flow of all air traffic, whilst ensuring that all airspace users have reasonable and safe access to the national asset that is airspace.” Therefore the BHPA strongly disagrees with the statement in paragraph 1.1.3 of the consultation where it says, “The CAA proposes to regularise all Class F ADRs as Class E airways notified as Transponder Mandatory airspace ….. Exceptionally, and where justified in consultation responses, the CAA will consider either the disestablishment of certain ADRs ….” The BHPA does not accept that this should be “Exceptionally”, indeed we maintain that considerable portions of the existing ADR route structure is not needed and should be Class G, as per the CAA’s own statement on Class G being the norm. 4. Para 1.1.3 Pennine Soaring Club The current proposal would effectively ban hang gliding and paragliding activity The intention is not to close off any airspace to any airspace user and it is not in much of Scotland, as these aircraft will NOT be able to fly in the proposed the intention of the CAA to discriminate against any affected airspace user. All Class E airspace. responses to this consultation have been given due consideration and have

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE So the PSC wish to support the Scottish Hang Gliding & Paragliding Federations informed refinement of the proposals. (SHPF) response, objection and proposal. There is no reason for the PSC to repeat each comment made in the SHPF's response document. The PSC want to state that they agree with all the comments made by the SHPF 5. Para 1.1.3 Scottish Hang Gliding & Regularising all Class F to Class E+ will close this airspace to PG and HG traffic. The intention is not to close off any airspace to any airspace user and it is not Paragliding Federation The SHPF questions the need for certain ADRs based on extremely low traffic the intention of the CAA to discriminate against any affected airspace user. All levels. We understand the BHPA response will address this further. responses to this consultation have been given due consideration and have informed refinement of the proposals. 6. Para 2.2.3b MOD The TSG concluded in para 2.2.3b that “Appropriate access arrangements for This is intended to mean in exceptional circumstances and by prior arrangement non-Secondary Surveillance Radar (SSR) and non-radio aircraft would have to with the airspace controlling authority. Apologies for the misunderstanding. be developed.” Why is there a requirement for “non-radio aircraft” when there is Note that VFR traffic would be required to carry and operate a serviceable SSR no restriction on VFR and, “non-radio aircraft” under IFR should not be permitted transponder in accordance with the proposals, or establish communications with to enter Class E as separation could not be assured against other IFR? the airspace controlling authority prior to entering the subject airspace, again in accordance with the proposals 7. Para 2.2.3c Scottish Hang Gliding & The TSG, which did the initial options appraisal of the class F replacement, The CAA’s proposals were a progression of the TSG’s work. Paragliding Federation recognised the need to assess each ADR on a case by case basis. Option 5 as recommended by the CAA does not meet thiscriteria. 8. Para 2.2.4 MOD Could the UK not state that the 4 Dec 14 timeline could not be met as further No; the CAA undertook to put in place its plans to replace Class F by Spring analysis is required to establish which routes would require to be upgraded or 2013. The ICAO USOAP took place in 2009 and 5 years would have elapsed by reverted to Class G? the time Class F was replaced. Earlier replacement had been envisaged but due to circumstances beyond the CAA’s control this did not happen. In addition, the entry into law of SERA would require a UK derogation from SERA’s requirement to apply Air Traffic Advisory Service within Class F; given SERA development timescales it is unlikely that this would have been unacceptable to the EC or EASA. 9. Para 2.3 Scottish Hang Gliding & Option 4 is preferred by the SHPF as it appears to include some flexibility. All responses to this consultation have been given due consideration and have Paragliding Federation Attached to this submission is a spreadsheet [Appendix 1 to the SHPF response] informed refinement of the proposals. As a result, a significant proportion of which lists existing Scottish Class F airspace with HG/PG usage information and current Class F airspace is likely to revert to Class G. comments on the changes that the SHPF would like to propose be made to Class F airspace being reclassified Class E airspace. In general, for specific airways located in areas important to the HG/PG community, the SHPF favour Class F airspace being reclassified Class G and for other areas raising the lower Flight Level to accommodate the passage of PGs and HGs. The SHPF object to the preferred option, Option 5, as it appears to be inflexible and if all existing Scottish Class F airspace is reclassified Class E it will mean a loss of access to ADRs currently available to the HG/PG community. Appendix 2 and Appendix 3 [to the SHPF response] have further background on Scottish PG and HG flying in Scotland together with some examples of individual flights. 10. Para 2.3.1 BAE Systems Warton Having sat on the Class F TSG, I do not wholly agree with the options as BAE Systems Warton’s comments are noted, however it should be outlined in para 2.3.1. The TSG sat regularly until June of 2010, where 3 options acknowledged that the CAA’s view on how best to proceed with the replacement were proposed: of Class F airspace in the UK FIRs was modified over time, hence the revised . Option 1 – Replacement of all existing Class F airspace by controlled options as presented in the consultation package. airspace i.e. Classes A-E. . Option 2 – Replacement of all existing Class F by Class G airspace. . Option 3 – Replacement of all existing Class F airspace by Classes A-E and G on a case-by-case basis. In fact the TSG (June 2010) concluded that Option 3 was the most appropriate. It was not until the TSG meeting of 31st January 2013 that we were informed Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B2 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE “The CAA proposed a consultation to regularise all Class F ADRs as Class E airways notified as transponder mandatory airspace”. 11. Para 2.3.1a BHPA The BHPA understands why this is not an option. The CAA welcomes the BHPA’s view. 12. Para 2.3.1a MOD The MOD agrees that Option 1 is not viable. The CAA welcomes the MOD’s conclusion. 13. Para 2.3.1b BHPA The BHPA understands why this is not an option and agrees with this. The CAA welcomes the BHPA’s conclusion. 14. Para 2.3.1b MOD The MOD could not support Option 2. The CAA welcomes the MOD’s conclusion. 15. Para 2.3.1c BHPA The BHPA understands why this is not an option. The CAA welcomes the BHPA’s view. 16. Para 2.3.1c MOD The MOD preferred option is Option 3. The CAA acknowledges the MOD’s conclusion. 17. Para 2.3.1d BHPA The BHPA understands why this is not an option. However we feel that due to The CAA welcomes the BHPA’s view. Further consideration of route utilisation the low utilisation on some levels of some ADRs this is in effect what will be and a better understanding of airspace user group requirements borne out of the happening as a result of this Consultation, albeit with a fixed CAS option of initial conclusion has led to modification of the CAA’s change proposals. Class E+ The CAA lauds BHPA’s pragmatic contributions to this process. 18. Para 2.3.1d MOD As the MOD considers that in most instances the traffic levels utilising the ADRs The CAA acknowledges the MOD’s pragmatic conclusions. Further would not warrant CAS status, Option 3 would be the MOD’s preferred option. consideration of route utilisation and a better understanding of airspace user However, it is recognised that for social and commercial reasons there may be group requirements borne out of the initial conclusion has led to modification of grounds to argue for Class E status where a Class G route is deemed not the CAA’s change proposals. appropriate. As such, it is felt that consideration for a change to Class E CAS on a case-by-case basis would be appropriate including the requirement for a TMZ (subject to access by non-equipped aircraft with prior coordination). In acknowledging the merits of Option 4, it should be clear that this would only be on the grounds of a potential change to Class E, if justified from a safety perspective and through suitable statistical/operational evidence. 19. Para 2.3.1e BHPA The BHPA understands why this is the preferred option but cannot support it as The CAA acknowledges the BHPA’s conclusion. Further consideration of route it is written as there are a considerable number of levels on some ADRs with utilisation and a better understanding of airspace user group requirements borne little or no use – as shown by the usage data provided as part of the out of the initial conclusion has led to modification of the CAA’s change Consultation. Additionally the proposed Class E+ is of little use to BHPA aircraft: proposals. • Transponders are not an option because as has been acknowledged by the The CAA appreciates the BHPA’s pragmatic contributions to this process. CAA on many occasions that there are a considerable number of UK based aircraft (including all BHPA aircraft) for which there is no suitable transponder in terms of: o the physical ability to fit any of the currently available models, and/or o the available battery life through having no other suitable power source, and/or o the cost of the equipment and its fitting relative to the value of the aircraft, • There are a considerable number of UK based aircraft (including all BHPA aircraft) for which the only practical radio is a hand held unit. This is because of: o the physical ability to fit any of the currently available models, and/or o the available battery life through having no other suitable power source, and/or o the cost of the equipment and its fitting relative to the value of the aircraft, • Hand held radios have a number of issues that will or could render them inappropriate for use to access the Class E+ airspace as described: o They have a much more limited transmit range and will be of no use in some of the current ADR structure o Are not designed for use wearing the types of gloves essential in some Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B3 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE aircraft, so frequency changing is very difficult and if possible can be detrimental to aircraft handling, so compromising safety o Are not rugged enough for use in aircraft where the pilot is very open to the elements, and so are stowed in safe locations where frequency changing isn’t possible • In paragraph 2.2.3 the Consultation says, “Appropriate access arrangements for non-Secondary Surveillance Radar (SSR) and non-radio aircraft would have to be developed.“ Experience trying to establish such arrangements for soaring cross country aircraft in other airspace has proven to be virtually impossible and so the BHPA finds it difficult to see what arrangements could be possible. Should there be areas of Class E+ that present problems to us we would welcome the opportunity to enter into discussions and be proven wrong. • So as we currently see it Class E+ airspace will be effectively closed to all unpowered hang gliders and paragliders due to no transponder or radio facility and with soaring aircraft unable to predict their track with sufficient accuracy to be able to establish procedural access. • Through a possible pre-flight arrangement of some sort, other non- transponder aircraft with little or no radio capability may possibly be able to gain access. However in practice the airspace will effectively be closed to them as well. 20. Para 2.3.1e MOD Option 5 is deemed unacceptable as it implies that ALL existing Class F The CAA acknowledges the MOD’s conclusion. Further consideration of route airspace would be replaced with Class E and TMZ even though the utilisation utilisation and a better understanding of airspace user group requirements borne figures do not justify such a change in most cases. Whilst caveats are included out of the initial conclusion has led to modification of the CAA’s change it is considered that, as with Option 4, the option statement should clearly proposals. articulate that any change to Class E or if deemed suitable Class G would be The CAA appreciates the MOD’s pragmatic contributions to this process. assessed on a case-by-case basis. In effect, the MOD would expect suitable supporting arguments to be made rather than a blanket decision to implement Class E. 21. Para 2.3.2 MOD The MOD agrees with the supporting argument discounting Option 1. The CAA welcomes the MOD’s conclusion. 22. Para 2.3.3 MOD The MOD could not accept any speed restriction being imposed on its The CAA acknowledges the MOD’s conclusion. There is no suggestion that any operations. such limitation would apply to MOD aircraft operating as OAT. 23. Para 2.3.3c Loganair The preferred option for Loganair would be a reclassification to Class C The CAA acknowledges Loganair’s conclusion, however the case for airspace. As the paragraph states “Class C permits access by other airspace reclassification to anything other than Class E + TMZ (either generally or for users under conditions that will enable the safe and expeditious flow of traffic specific routes) was not presented in any of the consultation responses. and preserve the known environment” this would maintain the current safety It is understood that Loganair operates to a significant degree in Class G levels against military, IFR and VFR traffic. airspace and does not believe these to be inherently unsafe. 24. Para 2.3.3e MOD The statement fails to highlight that in Class E airspace there is no requirement The CAA did not think it necessary to provide a detailed description of this for radio contact for VFR aircraft. This is an important factor as the MOD would airspace classification, as it is adequately described in other regulatory material. oppose any move to implement additional restrictions through the use of RMZs, There is no suggestion that the CAA would propose RMZs in addition to TMZs as this could impact on the military’s ability to carry out its operational training. within its proposals. In particular, it should be noted that some military aircraft have restricted access CONOPS for the replacement airspace are being developed, and the CAA to radios and, as such, may not have the capacity to leave their operational welcomes the MOD’s contribution to this process. frequency when looking to cross or operate within Class E airspace, accepting that in IFR conditions they would need to be in receipt of a service preferably from a military unit and not the civil authority. Additionally, the introduction of an RMZ shifts the risk from Civil to Military ATC in terms of controller workload and distraction, caused by the requirement for aircraft under the control of military ATC to maintain two-way communication at all times. Such a risk would only mitigated for the Military by the introduction of additional tools so that the flight rules of such aircraft can be non-verbally communicated to other controllers thus Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B4 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE incurring additional cost for a technical solution. 25. Para 2.3.3e MOD The MOD is aware that additional ‘Bolt-On’ mitigations may also be suggested. This issue is being addressed through the development of CONOPS for the While the MOD could accept the requirements of a TMZ, subject to access by replacement airspace. The CAA welcomes the MOD’s contribution to this non-equipped aircraft with prior coordination, it could not accept the suggestion process. that all OAT aircraft should be treated as IFR when crossing Class E whilst in receipt of an ATS. It is of note that VFR aircraft that sought a service, would be more restricted than those that elected not to do so. Equally, whilst it would mitigate the risks of potential AIRPROX events between VFR and IFR aircraft, it would not remove the same risk in regards to aircraft that elected to continue without a service. It should be noted that if aircraft are restricted whilst under a service but VFR, they may elect to cancel the service and proceed autonomously thus reducing the level of safety that would be afforded had the aircraft continued under a service. 26. Para 2.3.3e MOD If the CAA were to consider accepting “additional Bolt-On mitigations” and Option 2 was not pursued, neither have potential additional bolt-ons. thereby impose greater restriction on VFR flight, then such proposals would need to be subjected to further consultation as they are not contained within the original Consultation Document. 27. Para 2.3.4 MOD From an operational training standpoint, Option 3 would be the preferred option The MOD’s statement is noted. of the MOD. Looking at the statistics provided, it is evident that for the majority of the routes there is no justification for CAS status. It is considered that for some routes these could be reverted to Class G; however, maintaining the ability to flight plan. It is accepted that the provision of ATSOCAS by a civil ANSP may be necessary to make this viable. The lack of ability to provide ATSOCAS should not be considered as suitable justification to implement CAS. 28. Para 2.3.4 Sandair For many operators a Deconfliction Service in Class G airspace provides an Sandair’s comment is noted. Following consultation feedback the CAA now appropriate balance between a direct routing and appropriate ATSOCAS. This is proposes the disestablishment of several ADRs (and partial replacement of the frequently used between KWL and ADN when D809 is inactive. remainder by Class E + TMZ airways. The provision of UK FIS by ATS units will remain an appropriate element of service provision following the removal of Class F airspace. 29. Para 2.3.5 BAE Systems Warton The CAA has dismissed Option 4 due to time constraints. Bearing in mind the BAE Systems Warton’s comments are noted, however it should be amount of time this project has been on-going, it is not considered a suitable acknowledged that the CAA’s view on how best to proceed with the replacement argument to dismiss an option when it is actually the preferred way forward. of Class F airspace in the UK FIRs was modified over time, hence the revised Indeed, NATS and the CAA failed to produce a suitable outcome when the options as presented in the consultation package. Service Provision Task Force was looking at this situation several years ago, the The CAA does not challenge the historical information provided by BAE proposal being at that time for Class G routes or CAS on a case by case basis. It Systems, but does point out that circumstances do change over time and that th should be noted that the DAP Policy Statement dated 19 November 2012 “The plans to undertake certain courses of action may be required to change to suit Future Application of Class F airspace in the UK FIR” reports “Option 3 – evolving circumstances. replacement of all existing Class F airspace by Classes A-E and G on a case-by- Following consultation feedback the CAA now proposes the disestablishment of case basis is considered to be the most appropriate as it will lead to the several ADRs (and partial replacement of the remainder by Class E + TMZ identification and application of the most appropriate airspace classifications th airways. This falls between Options 4 and 5, and was foreseen in the initial best suited to the needs of all airspace users.” This letter, dated 19 November consultation document. 2012, was actually already drafted and attached to the TSG minutes of 27th June 2010. 30. Para 2.3.5 MOD If Option 3 is discounted, following consultation, then a change to Class E CAS Following consultation feedback the CAA now proposes the disestablishment of under Option 4 would be more palatable to the MOD if the routes in question several ADRs (and partial replacement of the remainder by Class E + TMZ were fully assessed, on a case-by-case basis, and the evidence related to traffic airways. This falls between Options 4 and 5, and was foreseen in the initial use and aircraft safety justified the upgrade in airspace classification. If Option 4 consultation document. was restricted to a change to Class E airspace, with a TMZ option, then it would be more appropriate than Option 5. It is assumed that this option is only discounted on the grounds that there is insufficient time to conduct detailed analysis and safety work to assess other CAS options. Notwithstanding the

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE Northern Periphery Programme and Public Service Obligation requirements mentioned in Para 3.12 and 3.13, it is clear that there are several routes which could easily revert to Class G with minimal impact to users and still comply with these initiatives. The TSG concluded that an assessment should be made on a case-by-case basis (see para 2.2.3c). It is considered that the CAA’s preferred option ignores this conclusion. 31. Para 2.3.5 Scottish Hang Gliding & The traffic data presented as part of this consultation already shows that many Following consultation feedback the CAA now proposes the disestablishment of Paragliding Federation class F ADRs have minimal traffic. Applying Class E+ to these areas is not several ADRs (and partial replacement of the remainder by Class E + TMZ justified and unlikely to be operationally or economically effective. airways. This falls between Options 4 and 5, and was foreseen in the initial consultation document. Input from the SHPF and the BHPA has helped the CAA to shape its modified proposals, and the pragmatic contributions of each to this process have been welcomed by the CAA. 32. Para 2.4.1 BAE Systems Warton How has the CAA determined that Class E with TMZ is “best suited to the needs The CAA’s conclusion was made at a generic level, rather than specific case of all airspace users…”? In the case of Warton, the establishment of an airway levels. Overall, the CAA remains of the view that the overall impact of Class E + across the middle of its test area does not suit our requirements, regardless of TMZ as proposed represented the minimum impact upon airspace users the Class of airspace. Any class of CAS requires Radar Control Service to be generally. The CAA has, in the light of consultation responses, modified its provided, and that requires 5nm lateral and 5000ft vertical separation from other proposals, and as a result further reduced the impacts of these. aircraft. It would not be acceptable from a safety perspective to terminate the service of crossing aircraft to allow them to transit the airspace VFR, as permitted by the regulations. 33. Para 2.4.1 GAA The blanket proposal to change UK Class F to Class E+ involves very large The CAA welcomes the GAA’s appreciation of the CAA’s position. volumes of airspace. If the proposal were to be implemented as written it would, In proposing Option 5 as its preferred option, the CAA concluded that the overall at a stroke, create some four thousand cubic nautical miles of new airspace and impact of Class E + TMZ as proposed represented the minimum impact upon go down in history as the UK’s single largest creation of controlled airspace ever airspace users generally. The CAA has, in the light of consultation responses, imposed. modified its proposals, and as a result further reduced the impacts of its We do however understand that the consultation has been designed in a proposal, and considerably reduced the volume of controlled airspace as a simplistic “all Class F becomes Class E+” manner for a reason, and that there is consequence. a widespread expectation that many of the routes will be returned to Class G in accordance with CAA stated policy (see important points of principle in Appendix 2 [of the GAA response] below). 34. Para 2.4.1 Loganair Would the Mandatory Transponder be mode C? Associated Transponder Mandatory requirements assume the availability and Mode C is required for TCAS to function correctly and give the correct use of Mode C. although it is accepted that this function may not be available or instructions unserviceable. Transponder carriage requirements will be in accordance with the requirements stipulated in Article 39(2) and Schedule 5 to the Air Navigation Order 2009 and AIP GEN 1.5, and the operating requirements at AIP ENR 1.6. 35. Para 2.4.1 MOD The statement that this option (Option 5) “is best suited to the needs of ALL The CAA’s conclusion was made at a generic level, rather than specific case airspace users” cannot be justified. It may be perceived that this option better levels. Overall, the CAA remains of the view that the overall impact of Class E + serves the en-route element of airspace users but this is far from ALL airspace TMZ as proposed represented the minimum impact upon airspace users users in particular when route utilisation is taken into consideration. The MOD’s generally. The CAA has, in the light of consultation responses, modified its stance regarding Option 4 being more favourable than Option 5 providing CAS proposals, and as a result further reduced the impacts of these. refers to Class E is based on the omission of clearly articulated option statement that acknowledges that the ADRs should be assessed on a case-by-case basis. 36. Para 2.4.2a BAE Systems Warton We do not agree that there will be minimal impact. Presently, test flights are In proposing Option 5 as its preferred option, the CAA concluded that the overall provided, in the main, with Traffic Service – there is no obligation to avoid other impact of Class E + TMZ as proposed represented the minimum impact upon traffic and therefore time-limited, complex test sorties are achieved. The airspace users generally. The CAA has, in the light of consultation responses, introduction of an airway across the test area, regardless of classification, modified its proposals, and as a result further reduced the impacts of its introduces greater restrictions. Indeed, it may well lead those aircraft routing proposal, and considerably reduced the volume of controlled airspace as a along the airway into a false sense of security as they may well believe they are consequence. ‘protected’ from other aircraft. By allowing ‘other’ aircraft to transit VFR, having The CAA concedes that paragraph 2.4.2a is inadequately written. By stating Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B6 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE terminated the service first, without calling the controlling authority, it is believed “whilst creating a ‘known’ traffic environment for IFR traffic”, what is meant is that that this will introduce risk. IFR traffic is known to each other. VFR traffic would be the subject of traffic It is also questionable to state “whilst creating a ‘known’ traffic environment for information. The paragraph should have made this clearer. IFR traffic” when in para 2.3.3e you have cited the opposite “VFR flight in Class E airspace is not subject to a clearance to operate within it and does not constitute a known traffic environment”. 37. Para 2.4.2a MOD The MOD has no objection to TMZ status being applied where Class E status is The CAA notes the MOD’s conclusion. Arrangements for non-squawking aircraft deemed necessary subject to coordinated access for non-equipped aircraft or will be developed. aircraft whose transponder fails in flight. This is equally, and preferably, applicable to Option 4. 38. Para 2.4.2b BAE Systems Warton How easily recognisable is Class E with the bolt on of TMZ to non-regular and Class E is an ICAO airspace classification that is supported in EU law foreign airspace users? (Implementing Regulation (EU) No 923/2012 (Standardised European Rules of the Air (SERA)). Transponder Mandatory Zones are a permissible ‘tool’ within the SERA IR. 39. Para 2.4.2b MOD This is a correct statement, as long as additional requirements are not mandated The CAA welcomes the MOD’s conclusion. to the Class E operation, such as inability to file a VFR flight plan along a Class E route. 40. Para 2.4.2c BAE Systems Warton The statement “Autonomous access to VFR aircraft is permissible and therefore BAE System’s view is acknowledged, however the two Class E environments offers operational flexibility” is not considered suitable safety mitigation. Indeed, are not alike. The Glasgow CTA was originally Class E, whilst the proposed the CAA recognised this by removing Class E from the Glasgow CTA following replacement for Class F is Class E with Transponder Mandatory status, thus an AIRPROX. Whilst it is recognised that Class E with supporting TMZ might affording greater conspicuity of VFR traffic. have prevented the AIRPROX, by fast-tracking the airspace to Class D, rather than Class E with TMZ, the CAA has recognised that Class E is not appropriate. It does not offer operational flexibility to VFR aircraft not equipped with a transponder. 41. Para 2.4.2c MOD This statement would be essential to any agreement by the MOD as any The CAA notes the MOD’s conclusion. restriction against autonomous VFR access would have significant impact on operational training. 42. Para 2.4.2c Scottish Hang Gliding & HGs and PGs do not have the ability to carry a transponder. It is recognised by The CAA acknowledges the SHPF’s concerns. Modifications to CAA proposals Paragliding Federation the CAA that no transponder suitable for HGs and PGs is available on the that reduces the volume of Class E +TMZ that will replace Class F airspace (in market. In addition, use of handheld Airband radios with gloved hands is not particular in the vertical plane) will serve to reduce the impacts upon hang gliding practicable and handheld radios do not always have the required range to and paragliding activities. communicate over the required distances. HGs and PGs do not have either personal or equipment airband licenses or own airband radios. The sum of these facts means that E+ is closed to HG and PG traffic. 43. Para 2.4.2e MOD The MOD would require the ability to close routes during major exercises in The CAA notes the MOD’s statement ad does not believe CAA’s proposals order to provide sufficient airspace to conduct training and to reduce the inhibit this option under Flexible Use of Airspace principles. complexity of the airspace to exercise participants, especially foreign aircrew. Failure to do so could have safety implications. 44. Para 2.4.2f MOD The MOD would expect to retain its current ability to provide a control service The CAA notes the MOD’s conclusion. The issue is being addressed through within CAS without any need to agree MOUs or coordinate access with the the development of appropriate CONOPS. MOD is a key player in this process. controlling authority prior to entry. Additionally, there may be a requirement for some aerodromes to be given approval to enter Class E airspace, either through an MOU or granting of autonomous status, to enable efficient and flexible departures and recoveries to occur. If an LOA/MOU is required then the MOD would expect that the airspace operating authority would be obliged to agree access. 45. Para 2.4.2g BAE Systems Warton Warton test flights sometimes operate without transponder for test requirements. The CAA acknowledges BAE System’s concerns. Modifications to CAA It is not appropriate to mandate these flights contact the controlling authority for proposals reduces the volume of Class E +TMZ that will replace Class F Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B7 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE crossing clearance. Instead, it is expected they will remain under Warton’s airspace and thus the impacts upon BAE Systems’ activities. control but Class E with TMZ would preclude such flights, although it is BAE Systems’ acknowledgement that non-SSR operations are few in number is recognised that these are few in number. noted. 46. Para 2.4.2g GATCO It is essential that robust procedures are drawn up regarding access to Class E GATCOs’ comment is noted. airspace for Non-Radio aircraft to ensure the safety of all users. 47. Para 2.4.2g MOD The MOD agrees with this statement. The CAA welcomes the MOD’s position. 48. Para 2.4.2g Scottish Hang Gliding & The SHPF cannot support Option 5 while the “appropriate arrangements for non- The CAA acknowledges the SHPF’s concerns. Modifications to CAA proposals Paragliding Federation radio access” have not been described. that reduces the volume of Class E +TMZ that will replace Class F airspace (in particular in the vertical plane) will serve to reduce the impacts upon hang gliding and paragliding activities. 49. Para 2.4.3 BAE Systems Warton If there were no ADRs and we were starting from a clean sheet, it is doubtful that The CAA acknowledges BAE System’s views. the CAA would approve the establishment of an airway along the route of Modifications to CAA proposals reduce the volume of Class E +TMZ that will W911D, Class E or otherwise, based on the utilisation statistics alone. Whilst it replace Class F airspace and thus the impacts upon BAE Systems’ activities. is recognised that certain passenger flights require some form of separation from In addition, the CAA is considering the appropriateness of providing DS to VFR other flights, Class F and associated ATSOCAS was deemed sufficient for many traffic in Class G and will staff any resultant changes to the UK FIS as a years. Therefore, it is our opinion that routing in Class G with ATSOCAS is a separate project. suitable option. Indeed, as controllers are not required to separate IFR from CONOPS appropriate to Class E + TMZ where this replaces Class F airspace VFR in Class E, only calling VFR to IFR, it is considered a less safe method of will serve to address crossing VFR traffic. operation than a Deconfliction Service in Class G.

50. Para 2.4.3 BALPA BALPA understands that there may be communication/radar coverage issues on BALPAs’ position is acknowledged. The CAA’s final proposals take NATS’ parts of the Class F network on conversion to Class E. However we would prefer suggestions for change into account; these in turn have been based upon the that the provision of new equipment and/or the use of existing third party actual CNS capabilities of equipment NATS uses. facilities, e.g. Inverness radar, are considered ahead of the disestablishment of Where ADRs are not replaced by Class E + TMZ airways, UK FIS may be existing ADRs (including the raising of base levels), particularly where such requested by transit aircraft operating both IFR and VFR. routes are used by rotary and unpressurised fixed wing aircraft. Aircraft flying beneath the replacement structures may indeed encounter non- In icing conditions, a choice of levels is important for safe flight. Also aircraft participating, non-squawking traffic but that situation occurs under current forced to fly below the raised base of a Class E airway for any reason (e.g. arrangements within Class F and G airspace. performance or weather) are likely to meet non-participating tangential traffic Current ATS delegation arrangements concerning Inverness are noted; these avoiding CAS in Class G airspace where transponders are not mandated, will require modification to reflect future service provision arrangements. Indeed, negating ACAS. such delegation may not be required in the future: progression of the Inverness airspace change proposal will inform the way forward. 51. Para 2.4.3 MOD This contradicts the CAA’s preferred option (Option 5) as it implies that the The CAA does not believe there is any contradiction. Distinct Options were change process would be taken on a case-by-case basis. As stated for Option presented, however were a stakeholder to identify a need for a more restrictive 4, the MOD considers that any change, even to Class E, should be made on a airspace classification, the onus would have been on them to generate an case-by-case basis. Any increase classification above Class E must be subject airspace change proposal, not the CAA. to full ACP action. 52. Para 2.4.4 g Loganair Surely any aircraft crossing the ADR must be in contact with the correct It is not clear whether Loganair is referring to current or future operations. controlling authority. An aircraft not transponding or communicating would pose a significant flight safety hazard to IFR traffic. 53. Para 2.5 BAE Systems Warton W911D is not a heavily utilised route. Furthermore, the data provided as part of The CAA acknowledges BAE System’s concerns. Modifications to the CAA the consultation was not current (only included up to 2011) and a further request proposals reduce the volume of Class E +TMZ that will replace Class F airspace to NATS for more specific utilisation was limited in its utility. That said, the latter and thus the impacts upon BAE Systems’ activities. information did reinforce the limited use of W911D. BAE Systems’ acknowledgement that non-SSR operations are few in number is In an effort to analyse typical airline usage of W911D, data was provided by noted. NATS in pictorial form indicating cumulative aircraft tracks in 7 level bands between FL55 and FL195. Using this evidence as a guide, we estimate W911D weekly usage between DCS and IOM to be in the order of the following: . FL55 – FL75: <5 flights per week . FL75 – FL95: <5 flights per week Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B8 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE . FL95 – FL115: Nil . FL115 - FL135: <15 flights per week . FL135 – FL155: <5 flights per week . FL155 – FL175: Nil . FL175 – FL195: Nil On this evidence, we conclude that up to 30 flights will use W911D during a “typical” full week (these flights include those outside normal working hours [0900-1800 Mon – Friday] and at weekends). During our analysis, we have considered scheduled airline usage of W911D during normal working hours (0900 – 1800) between the following airports: . Isle of Man - Edinburgh - Isle of Man . Isle of Man - Newcastle - Isle of Man . Edinburgh - Dublin - Edinburgh . Newcastle - Dublin . Newcastle - Cork Isle of Man - Edinburgh - Isle of Man Forming the “bulk” of W911D tracks, there are currently up to 10 flights per working week scheduled on this route (a maximum of only one scheduled return flight each day) routing EDN-DCS-W911D-IOM or vice versa. If W911D was no longer available, these flights could use W928D and P600 with a minimal 6nm additional track miles. That said, as Loganair are to stop flights between Scotland and the Isle of Man, almost all of these flights would disappear. Isle of Man - Newcastle - Isle of Man According to the Isle of Man Airport Summer Schedule 2013, there are no more than 3 scheduled return flights per working week utilising this route. Furthermore, these aircraft already route outside CAS from Newcastle to DCS in order to start the route. W911D current usage = 6 flights per Mon-Fri week. Edinburgh – Dublin According to the Edinburgh Airport Destinations website, Ryanair and Aer Lingus are the only airlines that fly between these destinations. Anecdotal observation of tracks by Warton controllers suggests these airlines route along P600 rather than W911D. W911D current usage = 0 flights per Mon-Fri week. Newcastle - Dublin and Newcastle - Cork According to Newcastle Airports Destinations website, Ryanair (EGNT – EIDW) and Jet2 (EGNT-EICK) are the only scheduled airlines that fly these routes. Anecdotal observation of tracks by Warton Controllers suggests that neither Ryanair nor Jet2 use W911D for these flights. W911D current usage = 0 flights per Mon-Fri week. Conclusion Our limited analysis suggests that between 0900hrs and 1800hrs Monday to Friday, no more than 20 aircraft currently utilise ADR W911D. We conclude that this figure does not justify the establishment of a Class E airway which would have a significant nugatory impact on BAE Systems Warton operations in the Irish Sea. We believe that the majority of flights currently routing along W911D are those between EGPH and EGNS and that rerouting these flights via P600/W928D would have little impact on track mileage whilst providing additional protection within the confines of Class A airspace than is currently the case. Moreover, with the withdrawal of services by Loganair, the number of flights will reduce further. The subsequent reduction in traffic levels along W911D would, in our

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE opinion, justify the disestablishment of W911D. We accept that services between EGNS and EGNT would be affected by this action. However, Warton is currently a LARS unit and also provides ATSOCAS to aircraft flying within the Warton Advisory Radio Area (WARA); we believe this could be extended to include affected services (i.e. to those aircraft that cannot utilise the existing route structure) flying outside CAS between IOM and DCS if necessary. However, the CAA should recognise Warton’s value as an ATSOCAS service provider when considering its future as a LARS service provider as part of the current LARS review. Providing Warton remains within the scheme, it would be willing to consider providing services to such aircraft with the concurrent financial reward. 54. Para 2.5 NATS With respect to the CAA’s proposal that all Class F ADRs are replaced with The CAA welcomes the NATS response and has modified its change proposals Class E+ Airways, NATS’s position is that this is not currently technically feasible in the light of the information provided. As a consequence a number of ADRs in all areas and at all levels due to a shortfall in En-route communication, will be disestablished, with the remaining routes modified to reflect CNS navigation and surveillance (CNS) coverage to support ATS in controlled coverage as determined by the ANSP. airspace (CAS). To enhance the CNS infrastructure in these areas would require The impacts of the CAA’s proposals upon Aberdeen operations have also been significant un-planned investment (both in RP1 & RP2) which, in any case, presented by Aberdeen International Airport, its Airport Consultative Committee, would unlikely to be realised by the required deadline for Class F the Scottish Executive and local politicians. As a result the CAA has undertaken disestablishment in December 2014. Details on which ADRs can or cannot be addendum consultation on proposals to establish Class E + TMZ ‘fillets’ in the supported as a Class E+TMZ Airways with respect to existing CNS coverage vicinity of the Aberdeen CTR/CTA. The proposals have not been opposed. can be found in Appendix A [to the NATS response]. Coverage diagrams are available on request. Even those ADRs for which there is suitable CNS coverage, NATS has assessed current user demand and operational capability and has concluded that Class E+TMZ Airways as a like-for-like replacement may not be suitable in all instances. Appendix B details NATS’ proposals for alternative solutions for each ADR and these range from disestablishment of Class F, to Class E+TMZ Airways with revised dimensions that more accurately reflect user profiles. In some instances small Class E+TMZ filets and extensions to the Class C stubs above FL195 are proposed to enable safe and efficient ATM. NATS wishes to keep the establishment of new CAS to a minimum as required by the needs of the airspace users and other affected stakeholders in the region. The CAA’s proposals impact the Aberdeen operation around the Control Zone/Control Area (CTR/CTA) boundary to a marked degree and the NATS’ proposals in Appendix B [to the NATS response] include the introduction of Class E+TMZ fillets at the Airway/CTA interface. A description of the Aberdeen impact is included in Appendix C [to the NATS response]. NATS undertook a series of activities to establish the proposals in Appendix B. These included; • Operational & Safety impact assessments and review workshops to assess the impact upon NATS Airport and En-route operations of the CAA’s proposals. Details on these assessments are available on request. • Review of the current network design for connectivity between Scottish airfields, the Scottish TMA, Upper Air Routes and the North Atlantic region (NAT). • Engagement with military ATS providers at Prestwick Centre in a Joint and Integrated manner, to understand the impact of NATS’ proposals at the interface of our operations. • Engagement with the BGA at their request to identify solutions and processes that would maintain safety assurances without unduly constraining glider operations in the region.

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE • Engagement with BALPA at their request. As part of the assessment of the proposals, NATS made the following assumptions: • All new Class E+TMZ Airways would have an upper limit of FL195, with the exception of W4D as described in Appendix B. • For ATS outside Class E+TMZ Airways, the provision of an Air Traffic Service Outside Controlled Airspace (ATSOCAS) will be provided as it is now. • Removal of the ADRs will require some internal technical changes. • Controllers from several NATS units will need to be trained/familiarised to operate a Class E+TMZ Airway. • The Consultation has indicated that the connectivity to the existing Class C stubs be considered in the light of the proposals. NATS’ proposals indicate that these Class C stubs be revised to better accommodate user profiles and as such the associated Temporary Reserved Airspace (TRA) boundaries may need to be revised. • A Mode S transponder will be mandated for any TMZ established and any exemptions approved will be limited to where this can be justified by the users concerned. • To mitigate identified hazards, a Radio Mandatory Zone (RMZ) may be established where appropriate, in line with current CAA Policy. 55. Para 2.5.1 MOD The MOD believes that Option 4, with TMZ, could have been used to achieve The MOD’s position is acknowledged. this aim. However, the MOD position remains in support of Option 3. 56. Para 2.5.1 MOD While the MOD position is in support of Option 3, should this standpoint not be The MOD’s conclusions are acknowledged by the CAA. accepted by the CAA then the MOD considers that the only Class F routes with Modifications to the CAA’s proposals (disestablishment of a number of routes, sufficient traffic levels to warrant consideration of Class E replacement would be reductions in the sizes of the remainder (with one assuming CDR2 status)) will as follows: reduce the impact of Class E +TMZ where established. However it is • N560D/Ex W3D from GOW-INS acknowledged that affected user groups will need to establish local operating • W5D agreements to facilitate flexible use of airspace in specific areas. • W4D The impacts of the Aberdeen fillets and EGD613A upon each other are acknowledged, and the CAA is of the view that EGD613A should not be reduced • W6D in size and accepts that activity may take place up to its lateral limits. Therefore • N580D (Ex N573D) Flexible Use of Airspace principles must apply in the context of the proposed It is of note that the updated statistics did not differentiate between N560D north Aberdeen fillets. To that end the CAA believes that, when activated, EGD613A of Inverness and that to the south, despite the fact that there was a significant will take primacy over that overlapping Aberdeen fillet. When EGD613A is not difference in traffic use. Unless it can be shown that the traffic use north of activated, the fillet will be used as anticipated. Inverness is significantly higher than that previously provided (Average Mean CAA Safety Buffer policy paragraph 2.4 states that ‘Due to the intensive 2011, 4.3) then we would expect the route to terminate at Inverness. utilisation of some areas of the UK FIRs/UIRs where it may not be possible to While traffic levels on N560D to the south of Inverness may signify that Class E meet the needs of all airspace user groups or when dual use (the release of status is necessary, it is vital to note that any such move would have a ordnance and unusual air activities) of segregated airspace is considered, it may significant impact on RAF Lossiemouth operations as detailed below. It is be appropriate to consider deviation from the above criteria. Where this is recommended that the CAA take this into consideration rather than purely necessary, DAP will give careful consideration to a request for a policy considering statistical evidence of traffic movements. dispensation, provided full details of the associated hazard mitigation to justify It should be recognised that the MOD does not necessarily support a change to policy deviation are provided with the ACP. Should a possible need for such a the above routes as the introduction of Class E status could have a significant policy deviation be identified during the airspace design phase, it is impact on the way that operational training is currently carried out in the vicinity recommended occasional activities and/or a airspace sharing arrangements of these routes. In particular, should there be a restriction in the military’s ability under approved MoU/LoA may also provide suitable mitigation. to work autonomously through Class E airspace then this could reduce the Therefore it is both necessary and essential that MOD and NATS work to freedom of movement that currently exists and is required for effective establish operating arrangements to ensure compliance with CAA Safety Buffer operational training. In addition, aircraft operations close to this airspace could Policy requirements, ideally through the identification of appropriate (and safe) be constrained. For RAF Lossiemouth, this could impact on the safe and Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B11 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE efficient departure and recovery procedures, should aircraft be forced to route mitigations that could include positive ATC management of potentially hazardous underneath CAS, and would also affect aircraft routing to/from their operating activities, dynamic ATM procedures, use of internal safety buffers for occasional areas. This could have a similar impact on procedures for entering or departing activities, airspace sharing arrangements under approved MoU/LoA, any the Air Weapon Ranges and other Danger Areas. In relation to RAF combination of these, or indeed any other agreed solutions. Lossiemouth, there are 4 key routes which lie within Lossiemouth ATC’s AOR – For example, this could be achieved by NATS ensuring that, by means of ATS W4D (ADN – WIK); N560D/W3D (GOW – INS); N560D (INS – SUM); W6D (INS surveillance in the affected airspace, that aircraft under their control remains – STN). Aircraft departing/recovering to Lossiemouth tend to fly in the vicinity of clear of the range boundary and from aircraft operating within the range. at least one of these routes, therefore any reclassification will affect operations. Any such agreement should be conditional upon MOD providing a clear Classification changes for W6D, A1D and W958D will have significant impact on understanding to NATS of the actual take-up of EGD613A, and for MOD to the ability to hold Exercises on the west coast of Scotland. Notably CQWI and ensure that robust booking, cancellation and promulgation procedures are EX JOINT WARRIOR regularly use the surrounding airspace for complex applied to the satisfaction of NATS. Similarly, MOD should provide NATS with exercises. Should a change in airspace classification result in the need to clarity on the nature and conduct of operations undertaken within EGD613A. relocate these exercises, then this could have significant operational and The CAA is willing to offer mediation/moderation in these deliberations if either financial implications. It would therefore be strongly recommended that during party consider it necessary. major exercises provision is made that would allow these routes to be closed, CONOPS applicable to Class E +TMZ where this replaces Class F are being with primacy of the airspace being allocated to the Exercise Planners. drafted with MOD support; these will provide guidance to all service providers There may also be an impact on RAF Lossiemouth’s ability to provide an ATS to regarding service provision to IFR and VFR traffic in the affected airspace. They aircraft operating within TRA008 and this needs to be considered. Depending serve to provide clarity on service provision requirements and to reduce the on the classification change, the dimensions of TRAs may need to be revised. changes impacts to airspace users and service providers alike. Air Defence training will be constrained as there will be a requirement for them to Consideration of consultation responses and CONOPS development has led the provide Radar Control as they cross Class E airspace rather than Deconfliction CAA to consult industry on the appropriateness of providing Deconfliction Service as they do now. This could mean that training intercepts that are Service to VFR traffic in Class G and will staff any resultant changes to the UK crossing Class E airspace are disrupted more often than currently experienced FIS as a separate project. with a consequential increase in training costs. The MOD does not believe that there is any justification to upgrade the following ADRs to Class E on the grounds that the traffic levels utilising the routes would be unlikely to attract CAS status if scrutinised individually under the normal ACP process: • N560D/W3D from INS-SUM • W911D • A1D • W958D • P600D • N552D • W928D • W2D (this is being removed by the CAA) • N160D (Ex G4D) • N553D • N562D As such, the MOD position would be that these routes should revert to Class G airspace. Aircraft would be able to operate along Class G routes in accordance with para 3.9. 57. Para 2.5.1 MOD The following comments are specific to Exercise Joint Warrior: The MOD’s comments are noted. W6D/A1D/W958D/N580D/N562D/N552D/N562D/W928D. All routes transit Modification of the CAA’s proposals in the light of consultation will reduce the areas in which aircraft conduct maritime support activity and thus Ex aircraft impacts the replacement arrangements will have upon the activities cited. would need full tactical freedom of manoeuvre. Specific arrangements to accommodate exercise traffic can, of course, be • N560D. Affect aircraft transiting between East and West Coast Exercise developed in accordance with Flexible Use of Airspace principles. Areas. • W958D/N580D. Routes transit across Fast Jet Area South.

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE • N580D. Route transits J1 Maritime Firing Area. • N560D/W4D/W5D. Routes transit through Fast Jet Area North. A significant number of Exercise Joint Warrior training opportunities would be lost due to airspace restrictions in key training areas unless coordination agreements could be reached or route closures facilitated. 58. Para 2.5.1 MOD The following comments are specific to CQWI: The MOD’s comments are noted. It is felt that CQWI would be restricted to the use of the EGD 613 Complex and Modification of the CAA’s proposals in the light of consultation will reduce the Borders airspace unless the following routes were suppressed and a change to impacts the replacement arrangements will have upon the activities cited. the airspace classification to Class G during the Exercise flying window was Specific arrangements to accommodate exercise traffic can, of course, be promulgated by ACN: developed in accordance with Flexible Use of Airspace principles. • A1D The CAA acknowledges that the Aberdeen fillet/EGD613A overlap is required to • N560D comply with CAA Safety Buffer Policy requirements, or in accordance with • W6D Flexible Use of Airspace principles. • W4D The CAA is confident that an appropriate operating agreement can be reached between NATS and the MOD in order to maximum utilisation of the airspace by • W5D both parties. If the routes were not suppressed, CQWI training could be reduced by up to 100% as no alternate weather option would be available. 59. Para 2.5.1 MOD The MOD has the following specific comments against the Class F ADRs: Modification of the CAA’s proposals in the light of consultation will reduce the • N160D. Upgrade to Class E could impact on the use of D064A unless impacts the replacement arrangements will have upon the activities cited. activation times were limited to outside D064A booking times; The MOD For example, retention of A1D, N160D is no longer proposed, whilst the lateral would expect that the MDA would have primacy. From a Navy Command and/or vertical limits of the other cited routes have been reduced. perspective it would be untenable for N160D LEDGO-LND-LIZAD to be made either CAS or a TMZ due to the effect that it would have on EGD 008A. However, in view of the lack of traffic the MOD would strongly object to this route being upgraded to Class E. • A1D. Between Glasgow and Stornoway, A1D passes through the heart of a main ASACS operating area. Upgrade to Class E would therefore be extremely detrimental to the conduct of sorties and in view of the lack of traffic the MOD would strongly object to this route being upgraded to Class E. • N560D. North of Bonby, N560D runs through the heart of the Highlands, passing close to RAF Lossiemouth. However, in view of the lack of traffic the MOD would strongly object to this route being upgraded to Class E, as this would avoid complicating departures/recoveries from/to RAF Lossiemouth. • W4D. Whilst recognising that this route does attract en-route traffic, it should be noted that it could impact on RAF Lossiemouth operations as stated above. In combination with N560D this could severely constrain and complicate aircraft operations manoeuvring, departing or recovering in the vicinity of RAF Lossiemouth. • W3D/N560D. Of most concern is the potential reclassification of W3D/N560D to the south of Inverness as this would impact on the ability to recover multiple aircraft to RAF Lossiemouth from the south-west. This would exacerbate current deconfliction issues when Lossiemouth are recovering to RWY05 and Inverness Airport to RWY 23 as there is little space to manoeuvre between both radar patterns, high ground and wind farm primary contacts, which are to be avoided under a Deconfliction Service. • N580D. A number of High Seas Firing/Gunnery Areas to the south of EGD701 Hebrides Range may be affected by N580D. Although these Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B13 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE areas do not attract DA status and operate under clear range procedure, NATS currently endeavour to tactically divert traffic away from the areas to limit to need to Check Fire. A more formalised procedure would have to be put in place if a higher class route transited the area. Certainly a more significant restriction to military operating freedom would be seen in the Minch and Clyde Areas as aircraft tasked to support the considerable maritime activity here would be significantly constricted by the new routes. The airspace would either have to be closed during such activity or approval given to conduct clear range within the Class E. 60. Para 2.5.1 Scottish Hang Gliding & The SHPF agrees with the statement that this “consultation may identify The CAA acknowledges the SHPF’s concerns. Modifications to CAA proposals Paragliding Federation exceptional circumstances” in that our members will be barred from the preferred that reduces the volume of Class E +TMZ that will replace Class F airspace (in option of E+. particular in the vertical plane) will serve to reduce the impacts upon hang gliding The SHPF supports disestablishment of low usage ADRs. However, the SHPF and paragliding activities. considers that high usage Class E+ CAS should, in general, be above FL100 and class G established below that height to enable our current use of the airspace to continue. 61. Para 2.5.2 Loganair Loganair does not wish to see any of the ADRs disestablished. Loganair’s comment is noted. However, Class F must be replaced for the reasons stated in the consultation document. 62. Para 2.5.3 BALPA BALPA understands that there may be communication/radar coverage issues on BALPAs’ position is acknowledged. The CAA’s final proposals take NATS’ parts of the Class F network on conversion to Class E. However we would prefer suggestions for change into account; these in turn have been based upon the that the provision of new equipment and/or the use of existing third party actual CNS capabilities of equipment NATS uses. facilities, e.g. Inverness radar, are considered ahead of the disestablishment of Where ADRs are not replaced by Class E + TMZ airways, UK FIS may be existing ADRs (including the raising of base levels), particularly where such requested by transit aircraft operating both IFR and VFR. routes are used by rotary and unpressurised fixed wing aircraft. Aircraft flying beneath the replacement structures may indeed encounter non- In icing conditions, a choice of levels is important for safe flight. Also aircraft participating, non-squawking traffic but that situation occurs under current forced to fly below the raised base of a Class E airway for any reason (e.g. arrangements within Class F and G airspace. performance or weather) are likely to meet non-participating tangential traffic Current ATS delegation arrangements concerning Inverness are noted; these avoiding CAS in Class G airspace where transponders are not mandated, will require modification to reflect future service provision arrangements. Indeed, negating ACAS. such delegation may not be required in the future: progression of the Inverness airspace change proposal will inform the way forward. 63. Para 2.5.3 MOD The MOD would expect that the proposal by Aberdeen, or any other airport, to The Aberdeen requirement has been addressed through the CAA’s extend its CAS to provide containment within CAS for its procedures is subjected supplementary consultation. to the full ACP process in accordance with this para. 64. Para 2.5.4 Loganair Reclassification of the airspace to class C but with higher base levels would The CAA acknowledges Loganair’s conclusion, however the case for allow GA aircraft the ability to continue operating as they do currently. Military reclassification to anything other than Class E + TMZ (either generally or for traffic will continue to get a service from either military or civilian agencies. specific routes) was not presented in any of the consultation responses. It is understood that Loganair operates to a significant degree in Class G airspace and does not believe these to be inherently unsafe. 65. Para 2.5.4 MOD The MOD would expect that any proposal to increase classification above Class The MOD position is noted. That was the CAA’s expectation; in the event no E or to increase vertical or change lateral limits is subjected to the full ACP such proposals were presented during consultation. process in accordance with this para. 66. Para 2.5.4c Scottish Hang Gliding & The proposed changes will bar SHPF members from the ADRs this does not Following consultation feedback and further consideration of available route Paragliding Federation seem to fit with FUA. utilisation data the CAA now proposes the disestablishment of several ADRs (and partial replacement of the remainder by Class E + TMZ airways. This falls between Options 4 and 5, and was foreseen in the initial consultation document. Input from the SHPF and the BHPA has helped the CAA to shape its modified proposals, and the pragmatic contributions of each to this process have been welcomed by the CAA. 67. Para 2.6 BAE Systems Warton Whilst the change from Class F to Class E will guarantee the provision of air Modifications to CAA proposals reduce the volume of Class E +TMZ that will traffic control service to IFR traffic, it is questionable whether this provides a replace Class F airspace and thus the impacts upon BAE Systems’ activities. 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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE safer option than the provision of Deconfliction Service, particularly as there is In addition, the CAA is considering the appropriateness of providing DS to VFR no requirement to provide any form of separation between IFR and VFR flights traffic in Class G and will staff any resultant changes to the UK FIS as a inside Class E. separate project. Autonomous units with authority to provide services inside CAS should be CONOPS appropriate to Class E _+ TMZ where this replaces Class F airspace allowed to do so following any change from Class F to CAS. will serve to address crossing VFR traffic. 68. Para 2.6.2 MOD The MOD recognises that Radar Control or a Procedural Service could be Modifications to CAA proposals reduce the volume of Class E +TMZ that will provided to IFR traffic within or crossing Class E. ATSOCAS, by definition, is not replace Class F airspace and thus the impacts upon BAE Systems’ activities. applicable within CAS; therefore, clarification is sought as to what service could In addition, the CAA is considering the appropriateness of providing DS to VFR be provided to VFR traffic under the control of military controllers within Class E. traffic in Class G and will staff any resultant changes to the UK FIS as a The MOD would need to understand to what extent a FIS could be provided to separate project. ensure that aircraft under an ATS were provided with an appropriate level of CONOPS appropriate to Class E _+ TMZ where this replaces Class F airspace information to enable a safe transit of the airspace. Para 2.6.2 states that ICAO will serve to address crossing VFR traffic. MOD has been involved in the rules infer that FIS (i.e. ATSOCAS) can be applied to VFR flights within Class E; development of these CONOPS from the very beginning and has been party to it would be useful if this option could be investigated further. preliminary discussions concerning the appropriateness of Deconfliction Service provision to VFR traffic. 69. Para 2.6.3 GATCO There is a requirement for a 'training gap analysis' to be completed by ATC GATCO’s comment is noted. providers to give controllers adequate familiarisation with any changes to airspace classification. 70. Para 2.6.3 MOD The MOD recognises that Radar Control or a Procedural Service could be CONOPS appropriate to Class E _+ TMZ where this replaces Class F airspace provided to IFR traffic within or crossing Class E. ATSOCAS, by definition, is not will serve to address these issues. MOD has been involved in the development applicable within CAS; therefore, clarification is sought as to what service could of these CONOPS from the very beginning. be provided to VFR traffic under the control of military controllers within Class E. The MOD would need to understand to what extent a FIS could be provided to ensure that aircraft under an ATS were provided with an appropriate level of information to enable a safe transit of the airspace. Para 2.6.2 states that ICAO rules infer that FIS (i.e. ATSOCAS) can be applied to VFR flights within Class E; it would be useful if this option could be investigated further. 71. Para 2.6.4 MOD The MOD believes that the provision of service, to both IFR and VFR traffic, CONOPS appropriate to Class E _+ TMZ where this replaces Class F airspace should not be restricted to the controlling authority as this would reduce flexibility will serve to address these issues. MOD has been involved in the development and efficiency for crossing aircraft. VFR traffic not under an ATS will be able to of these CONOPS from the very beginning. enter Class E autonomously. However, the CAA may consider the following suggestion for aircraft crossing whilst in receipt of a service: - IFR traffic is provided with Radar Control or Procedural Service. - VFR traffic is provided with a FIS (this includes the UK’s ‘enhanced’ FIS options of a BS, TS and DS, where requested by aircraft operators). It should be noted that if aircraft are restricted whilst under a service but VFR, they may elect to cancel the service and proceed autonomously thus reducing the level of safety that would be afforded had the aircraft continued under a service. 72. Para 2.6.5 GATCO Only one body should be the nominated responsible controlling authority for an GATCO’s comment is noted. Service provision within the resultant airspace will airway within an FIR. This should be the civil ATC authority currently responsible follow current service provision practice. for controlling existing airways. 73. Para 2.6.5 Highlands and Islands Proposed re-classification for airspace is Class E (MATS Pt 1 Section 3, Chapter HIAL’s comments are noted. Airports Ltd (HIAL) 1, Para 1.1 “Class A-E (Controlled Airspace); Chapter 2, Para 2.2 Services UK FIS can continue to be provided outside the resultant Class E + TMZ “Within controlled airspace – Radar Control Service” airspace in accordance with unit approvals and ATS Staff licenses. Therefore, during the hours of provision of radar services at Inverness ATCU Current ATS delegation arrangements concerning Inverness are noted; these (currently 0845z-1630z) the only change involved would be the type of service will require modification to reflect future service provision arrangements. Indeed, being provided i.e. radar control service instead of de-confliction or traffic such delegation may not be required in the future: progression of the Inverness service. This practice is currently covered by the existing Letter of Agreement airspace change proposal will inform the way forward. between Scottish and Inverness ATSU whereby responsibility for portions of the

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE current ADR is delegated to Inverness Radar below a certain altitude in accordance with certain conditions e.g. radar serviceability etc. However, during periods of radar un-serviceability or outside the hours of radar service provision (currently 0130-0845z and 1630-2115z) the service provided by Inverness is a procedural service only. A procedural service cannot be provided within the airspace defined at Class E under the current definitions. This rule will apply to all other HIAL units for the duration of their operating hours whether they are providing a Procedural Service or an AFISO service. Therefore, the provision of air traffic service within Class E by procedure only ATSUs will have to be reviewed/confirmed by the CAA in order to establish if procedural units can provide procedural services within Class E. AFISOs cannot provide a FIS within controlled airspace, therefore consideration should be given to the likelihood that aircraft who want to avail of a FIS will need to be promptly transferred to FISO units once outside CAS. The base level of the existing ADRs overhead Wick and Kirkwall is a mere 3000ft. If the base height of the new Class E routes remains at 3000ft then it is likely to have a serious impact on the ATS operation at both airports in so far as it leaves very little vertical room within which these airports can manoeuvre traffic. Additionally, it will create a funnel effect between the top of the ATZ and 8the base of the new Class E routes. 74. Para 2.6.6 MOD It is the MOD’s view that N160D does not warrant reclassification to Class E as Disestablishment of N160D is proposed. the statistics related to aircraft movements do not justify this change. Should the route be removed, a DACS would continue to be provided within the operating hours of Plymouth Radar. Outside of these hours when the DA is active, a DACS would continue to be provided by London (Military). Should the route be reclassified as Class E, the MOD would expect primacy over the associated airspace during its promulgated hours and as notified. In these circumstances it would be expected that the route would be closed. Note that non-SSR operations regularly occur within this airspace. 75. Para 2.7 BAE Systems Warton Warton supports the removal of W2D. Moreover, a regular operator of the direct BAE Systems’ support for the CAA’s proposals regarding W2D are welcomed. route between Blackpool and Isle of Man, City Wing, are content to operate in Partial disestablishment of W911D (between DCS and IOM) is now proposed by Class G with ATSOCAS. As this airline is also one that operates regularly the CAA. between the Isle of Man and Newcastle (including that portion between DCS and Newcastle where there is no specified route), we presume that the airline would be content to operate along the line of W911D if it were also class G, as they do currently when W2D is not available. 76. Para 2.7 BHPA Due to its position overhead one of the North West’s premier soaring sites the BHPA support for the CAA’s proposal is welcomed. proposed disestablishment of this ADR is welcomed. 77. Para 2.7 GATCO GATCO agrees that the arguments for disestablishment of W2D are sound. GATCO support for the CAA’s proposal is welcomed. 78. Para 2.7 MOD The MOD has no objection and supports the disestablishment of W2D. MOD support for the CAA’s proposal is welcomed. 79. Para 2.7 Pennine Soaring Club The PSC support the current proposal to disestablish W2D. If the CAA's current Pennine Soaring Club’s support for the CAA’s proposal is welcomed. intentions for W2D were to change to reclassify as class E then the PSC would object as this would have a negative impact on hang gliding and paragliding in the area the PSC supports free flying in. 80. Para 2.7 Scottish Hang Gliding & The SHPF approves of disestablishment of W2D SHPF’s support for the CAA’s proposal is welcomed. Paragliding Federation 81. Para 2.8 BHPA Paragraph 2.8 of the Consultation states, “There are no plans to change where BPA’s comment is noted. It is accepted that some aircraft may be operated aircraft physically fly as a result of the proposed regularisation and therefore differently as a result of the proposed changes, although the nature, scale and analyses of noise impact, CO2 emissions, tranquillity, visual intrusion, and local pattern of change cannot be forecast. However the CAA did not intend to air quality have not been undertaken.” change such behaviours. This is especially true of aircraft flying along the

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE The BHPA does not believe this to be the case as there will be aircraft that will, subject routes, and some proportion (incalculable) of the aircraft crossing the for various reasons, not be able to use the Class E+ airspace. A significant routes. difference will be caused by how the military choose to treat this new The CAA’s original proposal of Class E + TMZ was intended to minimise the classification. If they decide to have a “keep out” policy then those aircraft will be operational and environmental impacts of the necessary; that modification of the displaced as well. original proposals results in a reduced volume of Class E will further minimise Therefore there will be changes where aircraft physically fly with the more the these impacts. Class E+ the greater the number of aircraft that will reroute. It should be acknowledged that a wholesale change to Class G would also influence where and how aircraft would be operated, but again the nature, scale and pattern of change could not be predicted. 82. Para 2.10.1 MOD The MOD would expect that the proposal by Aberdeen, or any other airport, to The ‘Aberdeen fillets’ have been addressed by the CAA’s addendum extend its CAS to provide containment within CAS for its procedures is subjected consultation. to the full ACP process in accordance with this para. 83. Para 2.10.2 MOD The MOD would expect that any proposal by NATS to consider the extension of ‘Class C stubs’ are the subject of a separate, NATS-sponsored, airspace change Class C airway ‘stubs’ is subjected to the full ACP process. Note that TRAs proposal. could be impacted by any change and the MOD would wish the opportunity to comment. 84. Para 3.1 Highlands and Islands Following the recent publication of more accurate and up to date aircraft usage HIAL’s comments are noted, however the proposed change to Class E + TMZ is Airports Ltd (HIAL) figures for the N560D on the GOW-INV route, we now feel the traffic levels as considered appropriate to N560D. No alternative airspace change proposal for a currently depicted justify the Para 2.3.2.c criteria i.e. “Class C airspace permits more restrictive classification such as Class C was presented by the controlling access by other airspace users under conditions that will enable the safe and authority of that route, nor was one presented by any other stakeholder. This expeditious flow of traffic and preserve the known environment that is important possibility was provided for within the consultation package. to CAT where the volume of traffic is at a level that requires the provision of a TSG’s 2010 recommendations regarding Class C are irrefutable, however these known environment”. anticipated a course of action that, in the event, did not materialise. In this regard we note the 2010 TSG recommendations which support Class C Circumstances have since changed, and the CAA’s approach to the replacement for the N560D on the GOW – INV route and question if the current proposed of Class F airspace has had to evolve accordingly. change to Class E rather than Class C was decided upon using incorrect data. There is no suggestion that incorrect data has influenced this change, nor indeed that any data was (or is) incorrect) 85. Para 3.1 MOD The MOD agrees that ADR utilisation should be considered before any ADR utilisation has been considered and has influenced the nature of the CAA’s reclassification. final proposals. 86. Para 3.1 Scottish Hang Gliding & The SHPF considers that ADR utilisation analysis is required prior to introducing ADR utilisation has been considered and has influenced the nature of the CAA’s Paragliding Federation Class E+ which will exclude our members. final proposals. 87. Para 3.2 Highlands and Islands A Training Needs Analysis for HIAL Class F to E/C will be required to be Current ATS delegation arrangements concerning Inverness are noted; these Airports Ltd (HIAL) conducted following confirmation of the classification of airspace along with will require modification to reflect future service provision arrangements. Indeed, delegated dimensions. such delegation may not be required in the future: progression of the Inverness The current Letter of Agreement between Scottish and Inverness ATCU and airspace change proposal will inform the way forward. specifically the delegation of portions of ADR to Inverness ATSU during periods of radar provision should remain. Refresher training shall be required to ensure Radar ATCO competence in the provision of radar control services. Provision of services within Class E requires confirmation as to whether or not a procedural service can be provided inside CAS. The current entries in MATS Part 1 are not clear. Does the statement “with or without surveillance equipment” refer to ADI provision in CAS and not procedural service provision without the use surveillance equipment? An issue of concern for the Wick-Kirkwall area is the current base of the ADRs being down to 3000’. As demonstrated by your radar coverage diagrams, full radar coverage is unlikely below approx. 6000’ in this area. Maintaining the current levels, and with the HRA R610 to the West, will cause a funnel around Wick for aircraft either unable or unwilling to enter CAS. This funnel may lead to aircraft transiting through the IAPs to the airport potentially increasing the risk from the current situation where they can fly above them. Obviously if the base

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE of CAS was to be raised from its current level, this will also be a reduction from the current protection provided by Class F. Consideration will also need to be made to integration of HMR X-ray And Yankee which will cross this airspace. 88. Para 3.2 MOD It is the MOD’s view that N160D does not warrant reclassification to Class E as Disestablishment of N160D is proposed as part of the CAA’s modified proposals. the statistics related to aircraft movements do not justify this change. Should the route be removed, a DACS would continue to be provided within the operating hours of Plymouth Radar. Outside of these hours when the DA is active, a DACS would continue to be provided by London (Military). Should the route be reclassified as Class E, the MOD would expect primacy over the associated airspace during its promulgated hours and as notified. In these circumstances it would be expected that the route would be closed. Note that non-SSR operations regularly occur within this airspace. 89. Para 3.2 NATS Inverness Radar services are noted. The decision on ADR replacement in the Current ATS delegation arrangements concerning Inverness will require Inverness area will need to take into account the Inverness CTR/CTA Airspace modification to reflect future service provision arrangements. Indeed, such Change Proposal, as submitted for consultation by Highlands & Islands Airports delegation may not be required in the future: progression of the Inverness (HIAL) on 22nd February 2013. Consequently NATS believes the issue of en- airspace change proposal will inform the way forward. route ATS provision around Inverness will require further discussions between NATS, CAA and HIAL to assure safety, regulatory and interface arrangements are satisfied. 90. Para 3.3 Highlands and Islands Many HIAL airports provide H24 on-call availability for ambulance and SAR HIAL’s comment is noted. One route - N562 TRN-MAC – will have CDR2 Airports Ltd (HIAL) flights. Whilst supportive of the flexibility CDRs provide in congested airspace status. we are not convinced that they would provide sufficient benefit to be useful in the North of Scotland. 91. Para 3.3 MOD Further investigation into the use of Conditional Routes for those which are not One Class E + TMZ route - N562 TRN-MAC – will have CDR2 status. utilised 24 hours to provide FUA for all users would be welcome. 92. Para 3.3 NATS Replacing ADRs with CDRs has not been fully assessed although it is clear that One route - N562 TRN-MAC – will have CDR2 status. to make effective use of these structures, the appropriate Airspace Management procedures and processes will need to put in place e.g. European Network Management changes and user access to CRAM/AUP notifications. The costs of establishing and maintaining these processes are unknown. 93. Para 3.4 GATCO Only one body should be the nominated responsible controlling authority for an GATCO’s comment is noted. Service provision within the resultant airspace will airway within an FIR. This should be the civil ATC authority currently responsible follow current service provision practice. for controlling existing airways. 94. Para 3.4 NATS Over 300 controllers from NATS Airports and the En-route Centres will require NATS’ indication of their training/familiarisation requirements is welcomed by the training/familiarisation and although the final cost can only be determined once CAA. the training requirement resulting from the airspace change has been confirmed, it can be expected to be substantial. There will also be costs from system adaptation and updating of documentation. In relation to ongoing service delivery costs and route charges, adoption of the NATS’ proposals in Appendix B [of the NATS response], it is not expected that there will be much material change. 95. Para 3.5 BALPA BALPA understands that there may be communication/radar coverage issues on BALPAs’ position is acknowledged. The CAA’s final proposals take NATS’ parts of the Class F network on conversion to Class E. However we would prefer suggestions for change into account; these in turn have been based upon the that the provision of new equipment and/or the use of existing third party actual CNS capabilities of equipment NATS uses. facilities, e.g. Inverness radar, are considered ahead of the disestablishment of Where ADRs are not replaced by Class E + TMZ airways, UK FIS may be existing ADRs (including the raising of base levels), particularly where such requested by transit aircraft operating both IFR and VFR. routes are used by rotary and unpressurised fixed wing aircraft. Aircraft flying beneath the replacement structures may indeed encounter non- In icing conditions, a choice of levels is important for safe flight. Also aircraft participating, non-squawking traffic but that situation occurs under current forced to fly below the raised base of a Class E airway for any reason (e.g. arrangements within Class F and G airspace. performance or weather) are likely to meet non-participating tangential traffic

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE avoiding CAS in Class G airspace where transponders are not mandated, negating ACAS. 96. Para 3.5 MOD It is understood that there will be base of surveillance coverage issues that do The CAA’s final proposals take NATS’ suggestions for change into account; not meet current legislative requirements for CAS. The military Area Radar these in turn have been based upon the actual CNS capabilities of equipment Units require the same level of CNS coverage in order to assure the safe NATS uses. operation. This issue is being discussed with NATS as the provider of the CNS. 97. Para 3.6 Highlands and Islands HIAL feel that the portion of the N560D that runs adjacent to the EG D703 (Tain Current ATS delegation arrangements concerning Inverness will require Airports Ltd (HIAL) Range) requires some review. The airspace is notified for flights that may be modification to reflect future service provision arrangements. Indeed, such unable to comply with Rules 8, 9, 10 and 11 (Rules of the Air Regulations 2007). delegation may not be required in the future: progression of the Inverness Fast moving military aircraft who by their nature are unable to comply with the airspace change proposal will inform the way forward. Rules of the Air when exiting the Danger Area without any prior notice. AIP ENR 1.1-28, Para 5.1.3.1 states “Pilots in the vicinity of these areas are strongly advised to make use of a Radar Service”; however a radar service is not always available. Therefore, HIAL suggests that a higher classification of airspace i.e. Class C can be justified for this section of the ADR. This would provide protection to all airspace users and negate the need for a buffer as a clearance to enter controlled airspace would have to be obtained by both VFR and IFR flights. Inverness ATC and Tain Range Management are currently engaged in dialogue concerning the development and implementation of an LOA. This LOA can quite easily be bolstered to using the Flexible Use of Airspace concept to ensure that there will be no unnecessary restrictions on military operations taking place in the EG703D. It is felt that this would greatly enhance the level of safety for all the stakeholders in this particular area. 98. Para 3.6 MOD The MOD agrees with the proposal for W958D, should it not revert to Class G; MOD’s comments are noted: W958D’s length will significantly reduced and its however, based on the usage statistics the MOD would recommend that it is base level raised. reverted to Class G. Note that the MOD would require the route to be notified as closed during major exercises. The MOD would also expect ‘Grandfather’ rights for effected DAs or for routes to be moved to provide the required buffer; any buffer would need to be outside of the boundaries of all affected DAs. 99. Para 3.6 NATS In addition to the example cited in the consultation document, the western edge Where Class E + TMZ airways replace ADRs these have been considered to be of W5D does not have the required buffer against the eastern edge of the D809 legacy structures where existing airspace arrangements have been proved safe North, Central & South, although this is accepted as an arrangement that existed through operational use. Therefore Safety Buffer requirements are not required before the publication of the CAA’s Buffer Policy. Under normal circumstances to be applied retrospectively, replacement of W5D with a new Class E+TMZ Airway would require compliance with the Policy so this will impact both the CAA’s and NATS’ proposals for this ADR. 100. Para 3.8 BHPA Where it is not possible to have the portions of ADRs identified in the attached The CAA anticipates the development of local operating agreements between table as being of interest to the BHPA reclassified as permanent Class G there affected parties where these are considered necessary by said parties. could well be possibilities for FUA arrangements, and the BHPA would welcome The CAA’s modified change proposals will reduce the impact of the planned discussions to explore the possibilities. reclassification upon all affected parties – this should reduce any need for local operating agreements. 101. Para 3.8 MOD The MOD would expect FUA principles to be applied to all airways that are The CAA supports the MODs expectation and anticipates the development of reclassified as Class E or above based on historical usage. local operating agreements between affected parties where these are considered necessary by said parties. 102. Para 3.8 NATS Although not strictly an FUA arrangement, NATS’ proposals for a limited set The NATS comments are welcomed by the CAA. Class E+TMZ Airways, with vertical dimensions which are appropriate for the The CAA anticipates the development of local operating agreements between users’ needs, are more ‘flexible’ than the consultation’s proposal in that they affected parties where these are considered necessary by said parties. address the need to establish CAS only where necessary, thus realising more The CAA’s modified change proposals will reduce the impact of the planned Class G airspace for other airspace users. This approach has been agreed with reclassification upon all affected parties – this should reduce any need for local the Scottish Military ATSP and the BGA to reach a solution which offers a safe operating agreements. and workable approach to service delivery within this airspace. 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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE 103. Para 3.9 Highlands and Islands Some changes to aircraft flight planning are anticipated, the positive benefits of HIAL’s comments are noted. Airports Ltd (HIAL) lower level CAS will facilitate the protection of flights until they pass FL195 and can then continue direct, e.g. INS-FINDO might change to INS-RANOK-FINDO. 104. Para 3.9 NATS With the proposed disestablishment of a number of ADRs, it is proposed that the The CAA’s modified proposals do not require the cancellation of any of the [Scottish] TMA boundary points are retained to accommodate flight planning. Scottish TMA boundary points serving Glasgow arrivals and departures as a number of these additionally serve extant airways and upper air routes. 105. Para 3.10 GATCO Only one body should be the nominated responsible controlling authority for an GATCO’s comment is noted. Service provision within the resultant airspace will airway within an FIR. This should be the civil ATC authority currently responsible follow current service provision practice. for controlling existing airways. 106. Para 3.10 MOD The MOD would expect ‘Grandfather’ rights for effected DAs or for routes to be Where Class E + TMZ airways replace ADRs these have been considered to be moved to provide the required buffer; any buffer would need to be outside of the legacy structures where existing airspace arrangements have been proved safe boundaries of all affected DAs. through operational use. Therefore Safety Buffer requirements are not required to be applied retrospectively, 107. Para 3.10 NATS Noting the TSG’s conclusion in 2.2.3 d) of the consultation document, it would be The CAA notes the recent launch of the NATS airspace change proposal envisaged that the standard routes between the NAT airspace and the Scottish concerning the ‘Class C stubs’. TMA airfields would be funnelled into the Class E+TMZ N580D Airway (portion Disestablishment of the LOMON SIDs would ordinarily lead to the cancellation of TIREE to GOW) via the associated Class C stub above it. LOMON, however the CAA is prepared to consider NATS’ justification for the Noting the TSG’s conclusion in 2.2.3 e) and the CAA’s comment in 2.10.2, position’s retention and invites NATS to submit this. NATS’ proposals also include changes to the existing class C stubs between FL195 and FL245, to provide better flight plan connectivity between the Class E+TMZ Airways and the Class C UARs; these better reflect the actual climb/descent profiles of modern aircraft. It is NATS’ understand that the Class C stubs have to mirror the Class E+TMZ Airway routes in order to provide continuity of ATS provision through active TRAs. NATS’ proposal for the disestablishment of A1D would enable the removal of the Glasgow LOMON SID however it is proposed that the LOMON waypoint is retained for flight planning purposes. 108. Para 3.10 Sandair The southern parts of W4D and W5D (South of SMOKI and PETOX) have low The CAA’s modified proposals introduce increases to the bases of W4D and bases which are not justified with the establishment of the Aberdeen CTA. The W5D in the vicinity of the Aberdeen CTR/CTA in excess of those suggested by northern border of the CTA lies 18nm from touchdown at RWY 16 EGPD and Sandair. therefore a lower limit of FL55 as opposed to FL 35 would do much to alleviate the impact of a change to Class E TMZ to general aviation in north east Scotland. 109. Para 3.11 GAA Almost all of the current Class F land areas are mountainous in character and The CAA acknowledges the GAA’s concerns and believes the modifications to generate considerable quantities of orographic and other cloud - rapidly, its proposals – borne out of consultation feedback that has resulted in increases unpredictably and at all levels. Mountain wave vertical velocities are known to to the base levels of the routes that will be retained and reclassified – answers reach 2,000 ft. per minute and in such conditions it can be imperative for power these concerns to a significant effect. as well as soaring pilots to fly in rising rather than sinking air. This in turn In addition, the CAA anticipates the development of operating agreements requires lateral positioning close to the upwind edge of lenticular clouds, and between affected airspace user groups and service providers that will facilitate above rather than below them to avoid serious rotor turbulence. the greatest possible access to the revised airspace arrangements. The proposed change from class F to Class E creates particular problems for Furthermore, CONOPS are being developed for the affected airspace to ensure many users. In a post SERA world we expect many GA pilots to have the clarity of service provision within it; these arrangements will further mitigate the requisite qualifications to fly in IMC; even if few wish to fly in cloud many will impacts of the changes. wish (or need) to fly laterally within 1500m of cloud to avoid serious downdrafts. Such needs can occur with little warning and yet in Class E the law requires ATC permission to be granted in this situation (technically IMC so IFR applies) (http://www.caa.co.uk/docs/64/200890108ATSAirspaceClassificationV3.pdf ). In effect this changes the intended nature of the new airspace from one most resembling the original Class F to one which for us has the same restrictions as

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE Class D. There are also well known problems with equipage of transponders or radios in large numbers of GA aircraft which effectively prohibit their access to Class E+ airspace (details in appendix 3 below). A nightmare scenario for us would therefore be the creation of Class E+ airspace (in effect Class D) where CAT does not routinely have to fly – the added legal requirement of avoiding cloud by specified distances, or being obliged to call for no-notice IFR clearance, would seriously reduce our flight safety and correspondingly improve no-one else’s. Even in windless conditions the terrain requires power pilots to fly prudently well above the 4,000ft granite and often above the cloud that envelops it. Engine failure (from icing or other factors) would otherwise leave little opportunity to reach survivable ground. When flying north of the Scottish TMA these factors are likely to dominate over airspace risk (collision) in any competent GA pilot’s assessment. The same conditions of mountain wave which can create problems are also the source of hugely important energy for gliding, hang gliding and paragliding. Scotland is today recognised as the prime European location for wave soaring and holds many records for speed and distance as a result. Any airspace which required permission to enter would simply destroy these possibilities. Gliders (who will inevitably concentrate themselves in areas of best rising air, often marked by the same cloud feature) would also be forced to leave their mutual information sharing radio frequency to call ATC, thereby diminishing their situational awareness and increasing the risk of glider-on-glider collision. Additionally, a need to fly in what is technically IMC (e.g. within 1500m of a lenticular cloud) would lead to requests for IFR clearances, reducing the capacity of the airspace and requiring IFR – IFR separation minima, and significantly increasing controller and pilot work load. Multiple wave soaring aircraft (even when known to each other and even in sight of each other) would create an almost impossible situation for controllers and pilots alike. A more detailed illustration of actual data from gliding activity is given in Appendix 1 below. Conclusion - it is of the utmost importance that class E+ airspace is only applied to areas and heights where significant densities of CAT traffic must exist. 110. Para 3.12 MOD The MOD believes that the ADRs serving these communities could be The MOD’s position is noted. The CAA’s modified proposals do not result in the reclassified as Class G routes and still meet this intent thorough the provision of wholesale reclassification to Class E +TMZ; a number of ADRs will be enhanced FIS. Reclassification to Class E is not justified based on statistics for disestablished, whilst the remainder are either reduced in length, or will have most ADRs. raised bases, or a combination of both. 111. Para 3.13 GATCO Disestablishment of Class F routes utilised by PSO flights would be contrary to GATCO’s comment is noted, however the CAA is of the view that UK FIS to the spirit of EU transportation law. Reclassification to Class E would be aircraft operating in Class G airspace also satisfies service provision compliant. requirements where reclassification to Class E + TMZ will not occur. 112. Para 3.13 MOD The MOD believes that the ADRs serving PSOs could be reclassified as Class G The MOD’s position is noted. The CAA’s modified proposals do not result in the routes and still meet this intent thorough the provision of enhanced FIS. wholesale reclassification to Class E +TMZ; a number of ADRs will be Reclassification to Class E is not justified based on statistics for most ADRs. disestablished, whilst the remainder are either reduced in length, or will have raised bases, or a combination of both. The CAA is of the view that UK FIS to aircraft operating in Class G airspace also satisfies service provision requirements where reclassification to Class E + TMZ will not occur. 113. Para 3.14 NATS NATS proposes that the base-level of W5D between PETOX and SUM is raised The CAA’s modified proposals include W5D from 3nm N of PETOX to 33nm S to FL105 so the service provision remains compliant. of SUM raised to FL105. 114. Para 3.16 GATCO Only one body should be the nominated responsible controlling authority for an GATCO’s comment is noted. Service provision within the resultant airspace will airway within an FIR. This should be the civil ATC authority currently responsible follow current service provision practice. for controlling existing airways.

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE 115. Para 3.16 GATCO There is a requirement for a 'training gap analysis' to be completed by ATC GATCO’s comment is noted. providers to give controllers adequate familiarisation with any changes to airspace classification. 116. Para 3.17 GATCO The derogation within Rule 19 of Rules of the Air 2007 that an aircraft flying in GATCO’s suggestion is noted, however the suggestion would require a change VMC along a Class C airway at any level shall, unless complying in accordance to UK legislation. Any such change is unlikely to occur before UK with an authorisation from the CAA, be flown as if the flight were an IFR flight implementation of SERA; any subsequent change is likely to be interpreted as should also be applied to Class E airways. being contrary to EU law. CONOPS for the proposed replacement Class E + TMZ airspace are under development; these will address management of IFR and VFR traffic in the replacement airspace. 117. Para 3.17 MOD The aim of SERA is to remove differences; additional restrictions or regulations The CAA agrees with the MOD’s position. should not be imposed. Rule 19 of Rules of the Air 2007 states that an aircraft flying in VMC along a Class C at any level shall, unless complying in accordance with an authorisation from the CAA, be flown as if the flight were an IFR flight. There is no such provision for flight along Class D or E airways; stakeholders are invited to comment on the need for an equivalent provision, noting that no such provision appears in ICAO Annex 2, Annex 11 or SERA. however the suggestion would require a change to UK legislation. Any such change is unlikely to occur before UK implementation of SERA; any subsequent change is likely to be interpreted as being contrary to EU law. CONOPS for the proposed replacement Class E + TMZ airspace are under development; these will address management of IFR and VFR traffic in the replacement airspace. 118. Para 3.17 NATS As part of the impact assessment NATS identified that VFR flight along the axis NATS’ suggestion is noted, however the suggestion would require a change to of a Class E+TMZ Airway constituted a hazard. We would propose that the CAA UK legislation. Any such change is unlikely to occur before UK implementation implements a statutory provision to prevent such flight within the new Rules of of SERA; any subsequent change is likely to be interpreted as being contrary to The Air 2014 as part of the SERA introduction. EU law. CONOPS for the proposed replacement Class E + TMZ airspace are under development; these will address management of IFR and VFR traffic in the replacement airspace. 119. Para 4 BHPA The creation of Class E+ airspace at too low levels will be detrimental to the The CAA acknowledges the BHPA’s concerns and believes the modifications to safety of those aircraft that are unable to enter it (for whatever reason) through its proposals – borne out of consultation feedback that has resulted in increases forcing them lower over the most hostile territory in the UK. to the base levels of the routes that will be retained and reclassified – answers The BHPA is concerned that the capacity of the Class E+ airspace will be these concerns to a significant effect. significantly reduced over the existing Class F through IFR separation minima In addition, the CAA anticipates the development of operating agreements and will significantly increase controller work load even where aircraft are clear between affected airspace user groups and service providers that will facilitate of cloud and visible to each other yet close enough to cloud to be IMC, and so the greatest possible access to the revised airspace arrangements. need an IFR clearance. Indeed for multiple wave soaring aircraft (even when Furthermore, CONOPS are being developed for the affected airspace to ensure known to each other and even in sight of each other) it would make it verging on clarity of service provision within it; these arrangements will further mitigate the impossible for both controller and pilots. Thus it is even more imperative that impacts of the changes. CAS is only established where it is essential.” The creation of CAS always creates choke points and without seeing the final version of what is to be Class E+ it isn’t possible to identify these. Were all existing ADRs to be converted to Class E+ there would be a significant number of new ones. With the low levels of use of the lower levels of most of the ADRs the BHPA does not believe that they will all be converted and so has not been able to justify the time to conduct such an analysis. However we do request that we are reconsulted once a plan is nearing finalisation as to where it is proposed the Class E+ will actually be so that we can conduct a choke point analysis with meaningful data.

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE 120. Para 4.2 Scottish Hang Gliding & The SHPF notes that the reason for reclassification of the Class F by the CAA is The CAA acknowledges the SHPF’s comments. Paragliding Federation for harmonisation with ICAO standards and not improved safety. The SHPF would like to point out that there are no existing safety issues with our members use of the current class F airspace. The assessment of the TSG does not apply to us. In addition, it is not clear how much additional safety E+ actually offers the whole aviation community as the safety assessment by the TSG was qualitative only (4.2.1.d). This appears to be weak grounds for reclassification. 121. Para 4.3.1a BAE Systems Warton The CAA seems to be changing its view from that outlined in its Policy BAE Systems Warton’s comment is noted, however it should be acknowledged Statement of September 2009. that the CAA’s view on how best to proceed with the replacement of Class F airspace in the UK FIRs has evolved over time, hence the revised options as presented in the consultation package. Following consultation feedback the CAA now proposes the disestablishment of several ADRs (and partial replacement of the remainder by Class E + TMZ airways. This falls between Options 4 and 5, and was foreseen in the initial consultation document. 122. Para 4.3.1b Highlands and Islands Will these benefits not be largely nulled by facilitating access to non-transponder Non-transponder aircraft will be required to establish radio contact with the Airports Ltd (HIAL) or non-radio aircraft (including gliders) Re para 2.4.2 g? appropriate airspace controlling authority in accordance with CONOPS that are currently being developed with assistance from industry (including HIAL). Therefore, while conspicuity may be diminished, contact with the appropriate controlling authority ensures the latter are aware of non-SSR traffic. In the specific case of gliders, appropriate operational agreements can be reached between airspace controlling authorities and the affected glider organisations to effect access in accordance with specific conditions. Similar arrangements can be made with other non-radio airspace users. 123. Para 4.3.1b Loganair Will mode C transponders be mandatory? Transponder carriage requirements will be in accordance with the requirements stipulated in Article 39(2) and Schedule 5 to the Air Navigation Order 2009 and AIP GEN 1.5, and the operating requirements at AIP ENR 1.6. 124. Para 4.3.1c BAE Systems Warton I would argue that service provision under ATSOCAS, particularly Deconfliction The provision of an air traffic control service to IFR traffic, plus the provision of Service, is better than Class E +TMZ which only provides traffic information to traffic information on other aircraft in a transponder mandatory environment is as IFR flights on VFR flights, rather than any form of separation. good as – if not better than - current ATSOCAS arrangements for Class F in the UK FIRs. The CAA is considering the appropriateness of providing DS to VFR traffic in Class G and will staff any resultant changes to the UK FIS as a separate project. 125. Para 4.3.1c BALPA The response to TSG only addresses the ATS aspect and not the preservation The provision of an air traffic control service to IFR traffic, plus the provision of of airspace protection, which is a pre-requisite. traffic information on other aircraft in a transponder mandatory environment is as good as – if not better than - current ATSOCAS arrangements for Class F in the UK FIRs. 126. Para 4.3.1c Loganair This statement is of the utmost importance to Loganair. The provision of an air traffic control service to IFR traffic, plus the provision of traffic information on other aircraft in a transponder mandatory environment is as good as – if not better than - current ATSOCAS arrangements for Class F in the UK FIRs. 127. Para 4.3.1c MOD It is stated that: The CAA notes MOD’s concerns; no additional bolt-ons have been proposed. “Provision of supporting justification that the introduction of Class E airspace with Transponder Mandatory status will directly reduce the safety risk, and/or contribute to the development of a fundamentally safer system, or at the very least maintain current levels of safety whilst delivering benefits in other areas.” The MOD has not conducted any specific safety analysis to either support or question this statement. It is understood that NATS has conducted such an assessment, with one MOD representative from ScATCC(Mil) in attendance, and Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B23 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE that it was assessed that Class G airspace with ATSOCAS was safer than Class E with TMZ. Whilst additional Bolt-Ons were proposed, these could not be supported by the MOD. In addition, should these Bolt-Ons be considered, it would be expected that no decision would be taken on these without further formal consultation. 128. Para 4.3.1d MOD The MOD would wish to analyse the safety work that led to this statement: “The The MOD’s comments are noted. The CAA considers the provision of an air selection of Class E minimises impacts upon all airspace users while at least traffic control service to IFR traffic, plus the provision of traffic information on maintaining current levels of safety”. Specific impacts on military operational other aircraft in a transponder mandatory environment to be as good as – if not training are highlighted throughout this response. better than - current ATSOCAS arrangements for Class F in the UK FIRs. The CAA is considering the appropriateness of providing DS to VFR traffic in Class G and will staff any resultant changes to the UK FIS as a separate project. 129. Para 4.3.1d Scottish Hang Gliding & The consultation states that the proposal “minimises impacts upon all airspace The SHPF’s concerns are noted. Paragliding Federation users while at least maintaining current levels of safety”. The SHPF objects to The CAA’s conclusion was made at a generic level, rather than specific case this statement the current proposal impacts severely on our members. levels. Overall, the CAA remains of the view that the overall impact of Class E + TMZ as proposed represented the minimum impact upon airspace users generally. The CAA has, in the light of consultation responses, modified its proposals, and as a result further reduced the impacts of these. 130. Para 4.3.1e BAE Systems Warton For Warton, replacing uncontrolled airspace with controlled airspace is not BAE Systems’ concerns are noted. The CAA’ revised proposals reduce the considered simple and nor is it considered consistent. It would greatly add to the amount of Class F that would otherwise have been replaced by Class E + TMZ. complexity of our operations in this airspace. 131. Para 4.3.1e Scottish Hang Gliding & The consultation states that the proposal “minimises impacts upon all airspace The SHPF’s concerns are noted. Paragliding Federation users while at least maintaining current levels of safety”. The SHPF objects to The CAA’s conclusion was made at a generic level, rather than specific case this statement the current proposal impacts severely on our members. levels. Overall, the CAA remains of the view that the overall impact of Class E + TMZ as proposed represented the minimum impact upon airspace users generally. The CAA has, in the light of consultation responses, modified its proposals, and as a result further reduced the impacts of these. 132. Para 4.3.1f Scottish Hang Gliding & The SHPF considers that in order to avoid excluding our members from the The SHPF’s concerns are noted. The CAA has revised its proposals in the light Paragliding Federation current class F, some complexity in the form of varying lower levels of E+ may of consultation feedback and as a result a number of ADRs will be be needed to ensure all users have fair access to airspace. disestablished. The remainder will be reduced in length and/or have their base levels increased, thus reducing the impacts of the change upon affected airspace users. 133. Para 4.3.1h Loganair The ability to extend class C either horizontally or vertically would maintain the The CAA acknowledges Loganair’s conclusion, however the case for safety of our operations. reclassification to anything other than Class E + TMZ (either generally or for specific routes) was not presented in any of the consultation responses. It is understood that Loganair operates to a significant degree in Class G airspace and does not believe these to be inherently unsafe. 134. Para 4.3.1i Loganair On some ADR’s the distance between established waypoints is greater than 50 It is understood that Loganair operates to a significant degree in Class G NM (egW958D between Bruce and the BEN) this would require a new waypoint airspace without reference to such waypoints (or indeed ADRs, preferring to to be established or rerouting of our aircraft at considerable cost in time and route direct to destinations, or accept vectors from ATC).. money. 135. Para 4.3.1i MOD The MOD notes that VFR flight plans along these routes would still be possible. The MOD comment is noted. 136. Para 4.3.1j Loganair The retention of the 5LNCs would ensure situational awareness. The stakeholder does not explain the benefits of either suggestion. As above the 50NM stipulation may adversely affect our operations. 137. Para 4.3.1l GATCO There is a requirement for a 'training gap analysis' to be completed by ATC The CAA agrees with GATCO’s assessment. providers to give controllers adequate familiarisation with any changes to airspace classification. 138. Para 4.3.1m GATCO There is a requirement for a 'training gap analysis' to be completed by ATC The CAA agrees with GATCO’s assessment. providers to give controllers adequate familiarisation with any changes to airspace classification. Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B24 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE 139. Para 4.3.1m Highlands and Islands The outcome of this consultation will lead to a decision being made on the HIAL’s comment is noted. Airports Ltd (HIAL) various aspects of the transition from Class F (ADRs) to the Class E/C with MTZ environment. At that stage HIAL will establish a working group and conduct a training needs analysis with a view to establishing the required training protocols. 140. Para 4.3.1m MOD There will be an increased training burden with associated costs, in particular The MOD’s concerns are noted, however the statement within the consultation from an ATM and Air Defence controller perspective. In addition, the MOD document is concerned principally with ATCO skill levels and not unit capacity. assumes that NATS will continue to provide services to GAT that currently It is accepted that there is a direct relationship between the two. operate within Class F airspace, following any change to airspace classification either by re-designation to CAS or reversion to Class G. It should not be assumed that the military will be able to accommodate an extension in its provision of service under the auspices of ‘irreducible spare capacity’ without significantly more cost analysis in terms of both increases to controller numbers and workstations. It is of note that there is a savings measure for the reduction of controller numbers; this would need to be re-examined and the console numbers set out in the MOD/NATS roadmap to be reviewed. 141. Para 4.3.1n GATCO There is a requirement for a 'training gap analysis' to be completed by ATC The CAA agrees with GATCO’s assessment. providers to give controllers adequate familiarisation with any changes to airspace classification. 142. Para 4.3.1n Loganair GA pilots flying low level must be aware of the need to keep RT to a minimum. Loganair’s comment is noted. The use of Scottish Info (119.875) should continue to be encouraged. 143. Para 4.3.1n MOD While they are not explicitly mentioned, the MOD would object to any move to RMZs are not proposed. impose an RMZ without further consultation. 144. Para 4.3.1o BALPA There may have to be changes to CNS coverage on parts of the network in BALPAs’ comment is noted. The CAA’s final proposals take NATS’ suggestions order to provide the ATS service. The response is not reassuring. for change into account; these in turn have been based upon the actual CNS capabilities of equipment NATS uses. There are no planned changes to CNS coverage, other than those associated with the VOR rationalisation programme. 145. Para 4.3.1o MOD The MOD has been advised that there will be CNS issues at our Area Radar The CAA’s final proposals take NATS’ suggestions for change into account; Units. The re-classification of Class F en-route airspace, to any category of these in turn have been based upon the actual CNS capabilities of equipment CAS, brings with it the requirements for radar coverage as set out in CAP670. NATS uses. This is equally applicable to both the MOD and NATS through the FMARS contract for equipment support. As such, where NATS have indicated that sufficient coverage exists for the introduction of Class E, this would support the provision of service to IFR OAT flights crossing CAS. Conversely, where such infrastructure does not exist to meet the requirements for CAS, then such airspace should revert to Class G. 146. Para 4.3.1o MOD In addition to radar coverage at our Area Radar Units, radio coverage has also The CAA’s final proposals take NATS’ suggestions for change into account; been examined. As with radar coverage, it is confirmed through the FMARS these in turn have been based upon the actual CNS capabilities of equipment contract with NATS that due to insufficient radio coverage Class E airspace NATS uses. could not be introduced in all areas. Airspace outside of coverage should revert to Class G. 147. Para 4.3.1p GATCO There is a requirement for a 'training gap analysis' to be completed by ATC The CAA agrees with GATCO’s assessment. providers to give controllers adequate familiarisation with any changes to airspace classification. 148. Para 4.3.1t MOD The revised arrangements should not impact on “non-radio operations” as there MOD’s comments are noted. The issue is reflected in proposed CONOPS, to is no restriction on VFR and “non-radio operations” under IFR should not be the drafting of which the MOD has contributed. permitted to enter Class E as separation could not be assured against other IFR. 149. Para 4.3.1u BAE Systems Warton Warton would not object to W911D becoming a part-time airway, between 1900- BAE Systems’ comment is noted. The CAA’s final proposals anticipate the

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE 0900hrs local. disestablishment of W911D between DCS and IOM. 150. Para 4.3.1u MOD In order to improve FUA, some FUA agreements may be complex to ensure that This is acknowledged by the CAA, although every effort should be made to airspace can be accessed based on need. ensure any such operating agreements are kept as uncomplicated as possible. 151. Para 4.3.1u Scottish Hang Gliding & The SHPF considers that in order to avoid excluding our members from the The CAA has modified its change proposals in the light of consultation feedback. Paragliding Federation current class F, some complexity in the form of varying lower levels of E+ may These modifications include the distestablishment of a number of ADRs, with the be needed to ensure all users have fair access to airspace. remainder either being reduced in length or having raised base levels, or a combination of both. 152. Para 4.3.2 BALPA Stakeholders should have an opportunity to see and comment on the refined The report will be published in due course. proposals. 153. Para 4.3.2 MOD The MOD seeks confirmation that Safety and Airspace Regulation Group The report will be published in due course. (SARG) will conduct this safety assessment and request that the output will be published for external use. 154. Annex C BAE Systems Warton BAE Systems Warton is a member of NATMAC. Noted. 155. Addendum: Class F GAA The additional consultation information provided by NATS showing traffic using The CAA welcomes the GAA’s observation. Routes Trajectory Class F during the week 1st to 7th June 2012 is extremely helpful and has been Densities well presented in a number of useful numbered slides which are variously referenced below. http://www.caa.co.uk/docs/2582/20130524ClassFReplacementConsultationDocu mentAddendumClassFRoutesTrajectoryDensities.pdf 156. Addendum: Class F GAA Class F Routes in England The CAA welcomes the GAA’s comments. Routes Trajectory We note CAA’s stated intent to withdraw W2D before the Class F changes are N160D and W2D will be disestablished, W911D partially so (between DCS and Densities implemented, and agree that there is no justification to change it to anything IOM). other than Class G. The traffic density data provided confirms that usage of N160D is extremely low and we propose that it should revert to Class G. In the case of W911D we understand that NATS propose Class E+ only in the section between the Isle of Man and the Irish boundary, and have no objection to that proposal so long as the level at which Class E+ applies is set at the highest possible level. 157. Addendum: Class F GAA Class F Routes South and Southwest of Scottish TMA The CAA’s final proposals intend the disestablishment of A1D, N160D N552D, Routes Trajectory The data (slides 12-26 incl.) confirms that there is no case for classification other N553D, W2D and W928D. The remaining routes are reduced in size either Densities than Class G in advisory routes south of the Scottish TMA (N552D, N553D, vertically or longitudinally, or both. W958D (SE of BRUCE), W928D and N562D). In terms of the formal consultation as published we simply oppose the creation of controlled airspace (Class E+) in these almost unused routes. 158. Addendum: Class F GAA Class F Routes North of Scottish TMA The CAA’s final proposals intend the disestablishment of A1D, N160D N552D, Routes Trajectory The data (slides 3-11) also provides invaluable insight into traffic levels using N553D, W2D and W928D. The remaining routes are reduced in size either Densities routes north of the Scottish TMA. vertically or longitudinally, or both. A number of points are noteworthy. The differences between slide 3 (all levels) and slide 4 (below FL195) illustrate the significant proportion of total traffic that is above FL195 and therefore represents traffic which is not in today’s Class F or relevant to this consultation. Below FL 195 we can look at individual routes, and although detailed numbers are not quoted for these levels we are able to categorise under two headings:- A - Very Low Usage (Clear Candidates for class G) – N580D and W958D west of Tiree, A1D, N560D north of INS, P600D east of ABD (traffic exists but is above FL195). In terms of the formal consultation we object to the creation of controlled airspace on these routes. We also understand that NATS propose and are in agreement that these routes should be made Class G. B – Low (but relatively higher than above) Usage (Candidates for Class E+) -

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE N580D and W958D east of Tiree, W6D, N560D GOW-INS, W4D, W5D. In terms of the formal consultation (which proposes the blanket creation of controlled airspace in the existing Class F height bands, typically FL60 or lower – FL195) we object to the proposal as written which would create controlled airspace at levels where no CAT flies. However, subject to the application of appropriate levels that relate to actual levels required to be flown by significant numbers of CAT (i.e. not just theoretical SIDs) and an agreed way forward to accommodate soaring activities at Cairngorm Gliding Club (Feshiebridge) we are prepared to support Class E+ in these areas. If for some reason either of these two conditions were to be unfulfilled we would feel compelled to object to the proposal. 159. Addendum: Class F GAA Required Height Profile on N560 GOW-INS The base levels of N560D will be reduced following consideration of consultation Routes Trajectory Before supporting a profile for CAS (if any) on N560D we need to understand responses. Densities how it would be used. That in turn requires an understanding of the general flow It is acknowledged that these reductions may not entirely satisfy all airspace of CAT north of the central belt in a situation which is likely to be itself changed users, however the CAA believes there is a real will amongst affected airspace by the influences of other changes. This is neither easy nor simple, but given the users and service providers to broker effective operating agreements that will consultative deadline we have endeavoured to give our best view prior to having serve to mitigate the impacts of the replacement of Class F airspace. clarity on all relevant data. We understand from NATS that they propose that both the whole of A1D, and N560D north of Inverness should revert to Class G; we are happy to support that view. These changes are likely to influence exactly how future commercial flights connecting the Central Belt with CAT from Northern Isles, Western Isles, and transatlantic traffic are routed. • Northern Isles – For efficiency it would seem obvious that flights from the Northern Isles to Glasgow or Edinburgh would initially route via the retained W4D or W5D to Aberdeen and then follow existing CAS in P600 to the Scottish TMA. We have heard some concerns about buffer requirements between the various parts of D809 and W4D and W5D. We would simply encourage appropriate stakeholders to work together to make these routes function. • Western Isles – in the absence of A1D it would seem obvious that flights from the Western Isles should connect to the Scottish TMA via retained stubs of N580D and W958D adjacent to Tiree. • Transatlantic – we would propose that these connect in the same manner as suggested for Western isles above. If the above three strategies are followed we find that there is almost no Scottish TMA bound traffic on N560D – it is overwhelmingly a route connecting Inverness with destinations far to the south. (We also note that even these routes are in decline - already announced changes to the INV – LON routes from three rotations a day for Flybe and two per day for Easyjet will become just 3 rotations per day for Easyjet only – a more than 10% reduction.) In the absence of a significant density of Inverness to Central Belt traffic there is no reason to create low level CAS at the southern end of N560D. The traffic density data provided also confirms (slides 9, 10 and 11) that there is no justification for CAS below FL100 at the southern end of N560D. There has not been an opportunity to fully explore the above logic with other stakeholders. It is thus possible that there are flaws in the logic that we have not understood – if so we would welcome the opportunity to explore, understand and if appropriate to challenge any obstacles. In the meantime we feel obliged to object to any proposal for CAS below FL100 between FOYLE and the vicinity of GUSSI.

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE An appropriate profile for a Class E+ in N560D would therefore be:- • INS – GUSSI FL95 – 195 as we believe is being proposed by NATS • GUSSI – Dalwhinnie FL105 -195 • Dalwhinnie – Lochearnhead FL150 – 195 • Lochearnhead – FOYLE FL100 – 195 The above figures are supported both by the supplied traffic density slides and our own observations of actual CAT flight tracking data. 160. Addendum: Class F GAA Height Profiles on Other Class E+ Routes The CAA’s final proposals intend the disestablishment of A1D, N160D N552D, Routes Trajectory Where other routes are granted E+ status we ask that every effort is made to N553D, W2D and W928D. The remaining routes are reduced in size either Densities maximise the level at which E+ begins. In particular the overland sections of vertically or longitudinally, or both. W6D, W4D and N580D are actively used by GA powered and soaring pilots and the same arguments as expressed for N560D above apply in equal measure. 161. Addendum: Theoretical BHPA Whilst the data supplied as part of the Consultation on theoretical CNS coverage The CAA acknowledges the BHPA’s observations. CNS Coverage was of use it was disappointingly insufficient in a number of ways: The information provided in the consultation packed was theoretical in nature, • There was no information on the SSR coverage. This is particularly and the CAA concedes actual coverage may differ. However in formulating its pertinent on two levels; the inclusion of TMZs as part of the proposed final proposals (following stakeholder consultation), the CAA has taken into solution, and given the CAA’s moves towards eliminating the use of primary consideration suggestions from NATS which do reflect actual CNS coverage. radar. Therefore the ability to see aircraft in some of the current ADRs is far from clear. • The NATS VHF communications transmitter site coverage was only given from 6,000ft AMSL upwards, yet the ADRs under consideration have bases as low as 3,000ft AMSL and the ground rises to over 4,000ft AMSL in a number of locations. Therefore the ability to talk to aircraft in some of the current ADRs is far from clear. • The primary radar coverage was only given from 6,000ft AMSL upwards, yet the ADRs under consideration have bases as low as 3,000ft AMSL and the ground rises to over 4,000ft AMSL in a number of locations Therefore the ability to see aircraft in some of the current ADRs is far from clear. • Up to now it has been a fundamental of UK controlled airspace (CAS) that it must always be able to be managed, that without suitable CNS tools management cannot take place, and so without suitable CNS coverage CAS cannot be established. • Where NATS has insufficient SSR coverage of sufficiently consistent quality the BHPA objects to the creation of Class E+ airspace, as it will not be possible for it to be managed efficiently. Where it continues to be proposed that Class E+ be established the BHPA expects the Consultation Report to show that NATS will have sufficient SSR coverage for all of it. • Where NATS has insufficient VHF communications capability the BHPA objects to the creation of Class E+ airspace, as it will not be possible for it to be managed efficiently. Where it continues to be proposed that Class E+ be established the BHPA expects the Consultation Report to show that NATS will have sufficient VHF communications coverage. 162. General Private pilot Gliders will be forced out of [the affected airspace] as they will not have suitable The consultation package foresaw the need to develop procedures to allow transponders permit access by non-SSR aircraft. These would either be required to be in radio contact with the controlling authority (but would not require a clearance to cross) or in accordance with published crossing procedures. It was additionally acknowledged that appropriate arrangements for non-radio access will need to be developed. Procedures for access by non-transponder aircraft feature in the draft CONOPS.

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE In addition, it is understood that NATS and the BGA are engaged in developing operating agreements to facilitate glider access as much as possible. 163. General Private pilot [Reclassification] will upset a large number of paraglider, hanglider, sailplane The concerns are noted. and GA pilots who cannot or do not want to fly with a transponder. From the Modification of the CAA;’s proposals has resulted in a reduction in the volume of flight density plots it is clear that very few flights were conducted in the FL75-55 Class F that will be replaced by Class E+TMZ, with the remainder reverting to region, so FL75 would be a good lower bound for the new airspace. Class G. Of the future planned airspace, most lies above 7500 ft amsl with at least 50% by area above FL95. This will mitigate the impacts of the more restrictive VMC in Class E. 164. General Private pilot Object The comment is noted. Lower altitude limit too low. FL75 preferred. Modification of the CAA’s proposals has resulted in a reduction in the volume of Class F that will be replaced by Class E+TMZ, with the remainder reverting to Class G. Of the future planned airspace, most lies above 5500 ft amsl with at least 50% by area above FL95. This will mitigate the impacts of the more restrictive VMC in Class E. 165. General Private pilot Object The CAA acknowledges that the original proposals would have impacted upon As a paraglider pilot, unable to carry a transponder, I will be excluded from certain aerial activities, however the scale of the change (and therefore the cross-country flying over certain heights in certain areas. impacts) have been reduced following modification of these proposals in the light of consultation. These modifications result in a reduction in the volume of Class F that will be replaced by Class E+TMZ, with the remainder reverting to Class G. Of the future planned airspace, most lies above 5500 ft amsl with at least 50% by area above FL95. 166. General Aberdeen International Safety implications [have] been discussed at length with our ANSP. Although The potential operational and economic impacts of the original proposals have Airport (AIA) NATS have confirmed that they will respond to the consultation separately we been acknowledged by the CAA and discussed at length with the service must also fully endorse the importance of any safety implications. A brief provider at Aberdeen. overview of these includes; These deliberations led the CAA to conduct an addendum consultation For AIA, Class F and G Airspace is utilised to vector many aircraft types from the regarding the ‘Aberdeen fillets’. There was no objection to the establishment of number of air traffic routes that converge into Aberdeen Airspace. these, and they are a feature of the CAA’s final change proposals. There are a significant number of advisory routes that currently converge into the It is the CAA’s firm belief that AIA’s operations will be best served by the Aberdeen airspace. Routes particularly affected are those from Scandinavia, establishment of the fillets, and that they will ensure that Aberdeen’s operations Orkney and Shetland (life services, particularly pertinent as the main hospital for remain safely and efficiently undertaken. Orkney and Shetland is Aberdeen Royal Infirmary). Although Helicopters do not fly these classes of route, as they approach Aberdeen Controlled Airspace they require to be positioned to allow routing into the airfield without confliction concerns. 167. General Aberdeen International Under the current airspace infrastructure we technically have no boundary as to The potential operational and economic impacts of the original proposals have Airport (AIA) how far east and north we vector aircraft that originate from, or depart into Class been acknowledged by the CAA and discussed at length with the service F Airspace. British Airways and Easyjet, amongst others, who fly via the airway provider at Aberdeen. from London, will always be kept inside the existing controlled airspace. If we are These deliberations led the CAA to conduct an addendum consultation allocated the Class E option as currently proposed by the CAA, we will have an regarding the ‘Aberdeen fillets’. There was no objection to the establishment of extremely narrow volume of airspace in which to funnel aircraft through, resulting these, and they are a feature of the CAA’s final change proposals. in increased workload and complexity. Our concern that as a business we It is the CAA’s firm belief that AIA’s operations will be best served by the handle over 115,000 aircraft movements per annum, of which 43,000 are establishment of the fillets, and that they will ensure that Aberdeen’s operations helicopter movements for the Oil and Gas Sector and understandably these are remain safely and efficiently undertaken. industries which operate in a highly sensitive safety environment. 168. General Aberdeen International Flow control and capacity issues – the capacity study undertaken by NATS in The potential operational and economic impacts of the original proposals have Airport (AIA) preparation for the 2013 Airport Master planning states that at present Aberdeen been acknowledged by the CAA and discussed at length with the service International Airport promulgates that its main runway 16/34 is capable of provider at Aberdeen. operating at 36 fixed wing movements per hour. In addition to the fixed wing These deliberations led the CAA to conduct an addendum consultation operation runway movements consistently increase to in excess of 40 regarding the ‘Aberdeen fillets’. There was no objection to the establishment of movements per hour at peak times to accommodate the movement of the large Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B29 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE public transport helicopters that are required to ensure that the North Sea Oil these, and they are a feature of the CAA’s final change proposals. and Gas operation is maintained. It is the CAA’s firm belief that AIA’s operations will be best served by the There are many dynamic and tactical aspects to the operation undertaken by the establishment of the fillets, and that they will ensure that Aberdeen’s operations ATS provider to ensure that all traffic is managed safely, including full utilisation remain safely and efficiently undertaken. of Class F and G airspace to ensure that aircraft are vectored appropriately to allow deconfliction of departing and arriving aircraft, without over utilising the current aircraft holds. It is important to stress that if Class F Airspace is replaced, as matters stand there is no alternative means of operating the complexities of this airspace without increased safeguards being put in place and a major increase on ATS Controller workload. We have been working closely with our colleagues in NATS to gauge how much of an impact that the replacement of Class F airspace may have and our understanding at this juncture is that a drop in capacity at peak times a conservative figure of 20-25% could be evidenced. This figure has been based on the added routing and holding of aircraft that will be required from the resulting increase in controls determined by the removal of Class F airspace. Primarily of real concern is the additional risk that this brings to safety due to the increased workload for the ATC Controllers however from a business perspective the potential commercial impact that this may have is also an area of grave concern for AIA. 169. General Aberdeen International Noise & Emissions; there are no SIDS and STARS at Aberdeen, but are some It is the CAA’s firm belief that AIA’s operations will be best served by the Airport (AIA) defined noise preferential routes, ATC work hard to ensure that aircraft operating establishment of the Aberdeen fillets, and that they will ensure that Aberdeen’s to and from the airfield utilise the best and most efficient routing for the aircraft to operations remain safely and efficiently undertaken. satisfy the local community and to ensure fuel efficiencies for the airlines. The However, the establishment of SIDs and STARs serving the airport is outside the volume of aircraft holding is likely to increase and without question will result in scope of the CAA’s proposals. If these are to be established then AIA must our local environment being affected by increased CO2 emissions. Presently submit an appropriate airspace change proposal in accordance with the CAA’s such Holds only see this level of activity during periods of adverse weather or airspace change process. when an operational situation requires us to flow traffic into the airfield at a much reduced rate. We have recently had many requests from airlines to review processes in an effort to reduce their rate of fuel burn, this is not only required for the environmental piece, but also for the ever increasing costs of our airline partners. 170. General Aberdeen International The criticality of AIA to the Region is highlighted below and this is further The potential operational and economic impacts of the original proposals have Airport (AIA) underlined by the data which confirms that AIA has the fifth busiest airfield in the been acknowledged by the CAA and discussed at length with the service UK (Monday – Friday), with an average 383 movements per day and hourly provider at Aberdeen. movement figures consistently reaching 36+. Should the forecast drop by even These deliberations led the CAA to conduct an addendum consultation 20% in available runway capacity during our peak operating period it is regarding the ‘Aberdeen fillets’. There was no objection to the establishment of envisaged that the movements would consequently drop to 29 movements per these, and they are a feature of the CAA’s final change proposals. hour, giving rise to an estimated loss in revenue of approx. £980k per annum It is the CAA’s firm belief that AIA’s operations will be best served by the and 982,963 passengers disrupted. A 25% reduction takes the runway capacity establishment of the fillets, and that they will ensure that Aberdeen’s operations to 27 movements per hour, but greatly increases the loss of revenue to just over remain safely and efficiently undertaken. £2m with 122,251 passengers disrupted. The replacement of Class F Airspace will almost certainly result in delays for our airline partners, which in addition will manifest through increased fuel burn, issues with crew hours, potential displaced aircraft and also lack of terminal space as there will be an increase in passenger waiting times for their flight. There is an inherent risk that over a longer period, this will manifest into a situation where airlines will no longer see AIA as a viable proposition and look for an alternative airport to operate from which will not have the same restrictions in place. In addition to negatively impacting on the growth forecast through our Long Term Business Plan, the aspiration of growing our business to include a much stronger International offering will also suffer, as well as an irredeemable reputational risk. A further consideration, and complexity, is that following on from the grounding of the EC225’s the Oil and Gas Industry is now insisting that all operators must operate a significantly different proposition Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B30 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE with a mixed fleet being a mandatory part of the contract, including an ever increasing introduction of fixed wing traffic which has been directly attributable to the EC225 helicopter issue. These are all positioned directly into the area currently designated as Class F Airspace. 171. General Aberdeen International Aberdeen International Airport (AIA) stands out from any other regional airport in The potential operational and economic impacts of the original proposals have Airport (AIA) the UK for a number of reasons. In addition to having a very unique operation it been acknowledged by the CAA and discussed at length with the service holds a key role within the UK economy as a result of the airports’ position as a provider at Aberdeen. vital enabler for national and international oil, gas and energy renewables. This These deliberations led the CAA to conduct an addendum consultation is clearly endorsed when considering the contrasting fortunes of AIA when regarding the ‘Aberdeen fillets’. There was no objection to the establishment of compared with the impact that the global economic downturn is having across these, and they are a feature of the CAA’s final change proposals. many other airports and their respective airline partners. During the period of the It is the CAA’s belief that AIA’s operations will be best served by the current recession AIA has experienced sustained growth in passenger numbers establishment of the fillets, and that they will ensure that Aberdeen’s operations and the trajectory within the long term business plan highlights that this will remain safely and efficiently undertaken. continue through to 2018 and beyond. Passenger numbers are forecast to increase to 4m which is a 3.2% rise on today’s passenger figures... During 2012 the airport was also confirmed as the “Best Connected Regional Airport in the UK” (CAA data). The following highlights provide clear context as to the importance of the airport to the local and national economy and the commercial strengths of Aberdeen International Airport; THE FASTEST GROWING AIRPORT IN THE UK 2011 and 2012 – In 2012, Aberdeen International Airport was audited by the CAA and confirmed as “The fastest growing airport in the UK” * for the second year running. *Airports over 1m paxMORE GROWTH MORE PASSENGERS • 33% Growth in International Traffic in two years through to end December 2012* • Abz has propensity to fly of 5.1% - Double that of any other UK Regional Airport* • 20.4% Growth in two years through to end December 2012* *Source: CAA THE DEMAND IS YEAR ROUND • 65% OF PASSENGER TRAFFIC AT ABZ IS BUSINESS TRAVEL (Source BOSS) • THE NORTH SEA ENERGY INDUSTRY DRIVES CONSISTENT TRAFFIC THROUGHOUT THE YEAR • ABZ is a Global hub for the export of specialist technical expertise, products and services • even year round demand, very even seasonality This is high value • North East Scotland is the second greatest UK provider of gva per head Source ONS • 15% more A, B, C1s than the Scottish national average • Average energy industry salary is £64,000 pa Source Oil & Gas UK This is a strong economy • Residential property prices increased 94% in 10yrs to end 2012 • The region has a – 1% unemployment rate (minus 1%) • Average household income 28% above national average • ABZ is home to over 29% of Scotland’s top 100 companies • Strong in-bound tourism market (driven by Royal Balmoral, castle/heritage, whiskey trails, golf and outdoor pursuits in the Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B31 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE Cairngorms National). Energy is for the Long Term • Investment in production will create 100,000 new direct/indirect jobs over the next 5 years * • Three key energy markets – North Sea, Global Sales, Renewables* • North Sea de-commissioning of old rigs is valued at 24 Billion over 25 years* • Another 24 billion barrels of oil to be extracted in next 5yrs (2013 – 2018)* • Active North Sea production is projected through until 2049* *Source: Oil & Gas UK Growth Driven Market • Proven high-value, seasonally-resistant market • Leisure market under-served by 100,000+ seats • New/emerging energy routes-across Scandinavia and wider Europe European ‘hybrid’ routes offering strong business demands = high end leisure traffic 172. General Aberdeen International Airspace changes; If the final decision of this consultation is to move all Class F The potential operational and economic impacts of the original proposals have Airport (AIA) Airspace to Class E Airspace, the ability that the airport has to efficiently position been acknowledged by the CAA and discussed at length with the service aircraft into and out of the airfield will be compromised, the only viable alternative provider at Aberdeen. would be to allow Class E Airspace fillets to be added to link what will become These deliberations led the CAA to conduct an addendum consultation the Class E Airways. If this does not happen, the area to the North end of the regarding the ‘Aberdeen fillets’. There was no objection to the establishment of Aberdeen Airspace will become congested, further airspace consultation will these, and they are a feature of the CAA’s final change proposals. need to be undertaken. If this is the position, to allow the airspace to be It is the CAA’s firm belief that AIA’s operations will be best served by the managed with these changes in place, it is likely that shortly afterwards there will establishment of the fillets, and that they will ensure that Aberdeen’s operations be a requirement for AIA to look at the remainder of the existing airspace around remain safely and efficiently undertaken. the airport as it will no longer be suitable for efficient movement of aircraft, this However, the establishment of SIDs and STARs serving the airport is outside the may include an Airspace Change Proposal (ACP). This will undoubtedly lead to scope of the CAA’s proposals. If these are to be established then AIA must a review of SID and STARS, which AIA currently don’t have and Aircraft Holds, submit an appropriate airspace change proposal in accordance with the CAA’s as a minimum. This is not something that has been seriously considered and airspace change process. will be as a direct result of the reclassification of Class F Airspace. It may be prudent to include these changes at the time to allow efficiencies. 173. General Aberdeen International In summary as an Airport operator we would initially urge you to reconsider the Recognition of these and similar concerns led the CAA to conduct an addendum Airport (AIA) decision to mandate the removal of Class F airspace and to take account of the consultation regarding the ‘Aberdeen fillets’. There was no objection to the significant impact that this will have commercially, environmentally and without establishment of these, and they are a feature of the CAA’s final change doubt by introducing additional risk into the airspace identified. If this cannot be proposals. accommodated, a revision of the current Class E Airspace to include fillets is It is the CAA’s firm belief that AIA’s operations will be best served by the essential to allow Aberdeen International Airport to continue to grow and establishment of the fillets, and that they will ensure that Aberdeen’s operations prosper, and as such continue to allow the prosperity of the region to be remain safely and efficiently undertaken. supported fully by an integral transport link. 174. General Avinor (Norway) Avinor provides ATS in delegated airspace in the North Sea. No change in Noted. There will be no impacts for ATS in North Sea Area II, because this operations as the proposed reclassification is outside of (and does not border) airspace only goes to FL085, while P600D starts at FL095. The offshore- the delegated airspace. Supportive of proposals sectors, both on British and Norwegian side have an upper limit of FL085. 175. General BAE Systems Warton Warton is a test and development airfield, primarily for military aircraft, with The CAA’s final proposals intend the disestablishment of W2D and the partial autonomy granted by the CAA to operate in all classes of airspace. We disestablishment of W911D between DCS and IOM. welcome the removal of W2D; however, we object to the reclassification of CONOPS appropriate to the Class E + TMZ routes that will replace ADRs are W911D to an airway with TMZ as it will have a significant impact on our currently being developed. operations. Warton’s main test area lies within the Irish Sea and, over recent years, we have seen a gradual erosion in the available class G airspace due to the increase in CAS to accommodate GAT. We recognise that the amount of Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B32 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE test flying is reducing, but the test flights are often extremely demanding and operate over large areas, crossing W911D. These sorties include practice intercepts over 100nm splits involving formations up to 8 aircraft, with the actual intercept point often in the area of W911D. Should the ADR become an airway, regardless of class, aircraft will be provided with radar control service and the concurrent separation standards. As these practice intercepts often involve numerous aircraft, at significant cost, and take some time for controllers to position them all to meet the flight test profile, to then have to avoid the occasional GAT on a seldom utilised airway would mean that fuel-limited fighters would not be able to complete the schedule. Whilst aircraft flying VFR, as is mostly the case for Warton, does not need permission to enter, it would be impractical to terminate the service to allow them to track directly towards GAT on the airway. However, the rules as they stand allow that. 176. General BAE Systems Warton [Implementation] costs could be significant if sorties were disrupted because of The CAA’s final proposals intend the partial disestablishment of W911D between W911D becoming an airway. BAE Systems has concentrated its UK capability DCS and IOM. to flight test and develop from Warton. What is clear, however, is that significant man hours have been devoted to providing the reply to this consultation and supporting the Technical Sub-Group (TSG) work. 177. General BAE Systems Warton The following Papers, which refer in some way to Class E or F airspace, have Each document has been referenced in the proposal material. not been referenced in detail in the consultation document: CAA DAP Policy Statement “The Future of Class F Airspace in UK Flight . CAA DAP Policy Statement “The Future of Class F Airspace in UK Flight Information Regions” dated September 2009 was replaced on 12 November Information Regions” dated September 2009. Para 5.5.1 states that “Class 2012. Para 5.5.1 states that ‘Class E airspace is intended by ICAO to be E airspace is considered to be insufficiently different in nature from Class F exceptionally specified at locations where a known traffic environment is and G airspace, especially when the provision of the UK Air Traffic Services necessary only in IMC. Unlike Class D, VFR flight in Class E airspace is not Outside Controlled Airspace (ATSOCAS) is taken into consideration. As subject to a clearance to operate within it, and does not constitute a known traffic such, it does not confer operational and safety benefits over either of the environment. Whilst separation between IFR traffic is provided, separation lower Classes. In addition, it is the CAA’s intention to progressively replace between IFR and VFR traffic is not provided, traffic information on VFR traffic Class E airspace within the UK FIRs in accordance with Reference F. being provided when practicable. Class E airspace as defined in ICAO Annex 11 Therefore Class E is not considered to be an appropriate alternative to Class is considered to be insufficiently different in nature from Class F and G airspace, F. especially when the provision of the UK Air Traffic Services Outside Controlled . CAA DAP Policy Statement “The Application of ICAO Airspace Airspace (ATSOCAS) is taken into consideration (specifically, where a Classifications in UK Flight Information Regions” dated 31 August 2010. Deconfliction Service can be guaranteed). As such, it does not confer perational Para 3.5 states “It is the intention of the CAA for Class E to be progressively and safety benefits over either Class F or G airspace.’ The CAA’s proposals for replaced where appropriate within the UK FIRs by airspace classes that are the replacement of Class F airspace do not support the application of Class E considered to be better suited to the operational conditions associated with without the use of an enhancing (and permissible) tool, in this case Transponder the airspace structures in question…..”. However, whilst it is recognised that Mandatory status. in the same paragraph it states “Enhancements to the requirements of Class CAA DAP Policy Statement “The Application of ICAO Airspace Classifications in E airspace, such as transponder and/or radio carriage and operation UK Flight Information Regions” dated 31 August 2010 was replaced on 1 August requirements, may be considered where replacement by a more restrictive 2013. Para 2.5 stats that ‘Class E airspace is notified where a known traffic classification (i.e. Classes A-D) cannot be justified”, this is at odds with the environment is necessary only for IFR operations. Enhancements to the previous text, and that outlined in the previous bullet from a separate Policy characteristics of Class E airspace, such as mandatory carriage and operation of Statement, stating that the CAA wishes to remove Class E airspace. transponders and/or radios, may be considered where the application of Classes . CAA DAP Decision Letter “Reclassification of the Glasgow Control Area A-D cannot be justified. Class E is not to be applied to CTRs.’ (CTA)”. Following an AIRPROX in the Glasgow CTA where the airspace BAE System’s observations concerning the Glasgow CTA, however the two was notified as Class E, DAP deemed it of such safety critical concern that a Class E environments are not alike. The Glasgow CTA was originally Class E, fast track to Class D was required, without consultation. Whilst the current whilst the proposed replacement for Class F is Class E with Transponder consultation suggests replacement of Class F ADRs with Class E airway Mandatory status, thus affording greater conspicuity of VFR traffic accompanied by a TMZ, it is questionable whether this meets a known traffic environment such that it provides sufficient safeguards for the traffic operating within, all reasons that Class E in the Glasgow CTA was removed in the first place. 178. General BAE Systems Warton Warton is a flight test centre with a requirement to operate test and development The CAA acknowledges BAE Systems’ comments and welcomes the additional Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B33 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE aircraft in IFR and VFR in all classes of airspace, as authorised by the CAA and insight into Warton operations. the MAA. Its main operating area is the Irish Sea, where the unit has seen a Following stakeholder consultation the CAA has modified its proposals. As a gradual erosion of available airspace due to an increase in CAS to consequence a number of ADRs will be wholly or partially disestablished. The accommodate GAT. In the main, these proposed changes have included remainder will, upon reclassification, have higher base levels than is currently detailed consultation with Warton in order to reach an agreed solution which the case, or will be shortened in length, or a combination of both. meets all operators’ requirements; this has demonstrated sound implementation of FUA. Warton test flights include: . General Handling. . Air to air refuelling. . Practice Intercepts. . Multi-ship formations. . Supersonic testing. These flights are often time critical and any delay or re-route can impact significantly on fuel reserves such that test flight schedules are not completed. Concerned that a blanket change from Class F to Class E with TMZ does not take into account the requirements of other airspace users (namely Warton), this submission hopes to highlight to the CAA the impact of such a change. We recognise the reasons behind the requirement to change but do not believe that there is suitable evidence to establish an airway, of any classification, across the middle of the only test area which can accommodate our flights (there is often the requirement to remain within the Irish Sea airspace to facilitate transmission of telemetry data between the aircraft and flight test division at the airfield). Moreover, by enhancing FUA further in the North Wales MTA, we are often precluded from operating with tactical freedom in that airspace. 179. General BAE Systems Warton In order to cross CAS, Warton controllers adopt the rules within the Manual of The CAA’s modified proposals are based upon NATS consultation input which Military Air Traffic Management (MMATM). It states that there is to be a takes account of actual CNS coverage. minimum of 5000ft of radar cover below CAS in order to provide a crossing As a consequence of stakeholder consultation a number of ADRs will be wholly service. In analysing the coverage provided by the Warton Radar and the NATS or partially disestablished. The remainder will, upon reclassification, have higher Great Dun Fell (GDF), the latter also linked into Warton systems, the lowest level base levels than is currently the case, or will be shortened in length, or a to cross CAS would be FL90. Therefore, any CAS lower than that level would combination of both. preclude Warton from providing radar services to aircraft conducting test flights throughout their full flight testing envelope. Moreover, regardless of the (current) airway classification, Warton controllers, like their military area radar counterparts, provide ‘radar control service’ to aircraft crossing airways, mandated as IFR; it is not clear what instruction the MOD will publish for Class E airways, hitherto not available in the UK. If IFR and radar control service is mandated, the restrictions placed on the Unit will severely impede its ability to conduct flight testing. 180. General BAE Systems Warton Object to W911D as a Class E airway with TMZ. Support for the CAA’s proposal to disestablish W2D is welcomed. Support the withdrawal of W2D. W911D will be partially disestablished between DCS and IOM Class F airspace should be replaced on a case-by-case basis. Warton supports Elsewhere several ADRs will either be wholly or partially disestablished. The the decision to disestablish W2D. Warton would argue for the disestablishment remainder will, upon reclassification, have higher base levels than is currently of W911D. the case, or will be shortened in length, or a combination of both. 181. General BALPA Support. BALPA’s support for the CAA’s proposals is welcomed. Subject to there being no reversion of Class F to Class G beyond that in the current proposals. 182. General BGA Observation. When discussing the consultation document within the gliding The CAA welcomes the BGA’s analysis of the consultation material and confirms community it has been pointed out that the text is written very much as that it is correct. a proposal for Class E with additional TMZ status. Only when the text is carefully Aircraft crossing Class E+TMZ airways under VFR would not require a clearance studied does the description of TMZ or mandatory radio contact come to light Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B34 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE (in paragraph 2.4.2g). From previous discussions and briefings we are confident to cross but must be carrying and operating a suitable SSR transponder. Aircraft that the CAA intent for this airspace has always been to include radio as a totally crossing Class E ATS routes under VFR without a functioning suitable SSR valid alternative to a transponder and that we should not be concerned about the transponder would either be required to be in radio contact with the controlling reference to radio not being prominent in the text. Indeed in our discussions with authority (but would not require a clearance to cross) or in accordance with controllers we have generally found that they have a preference for radio calls agreed crossing procedures. It is acknowledged that appropriate arrangements over simple transponder use. for non-radio access will need to be developed. 183. General BHPA [Reclassification as proposed will affect BHPA operations] adversely The BHPA’s concern is noted. The CAA welcomes BHPA’s detailed suggestions regarding change options; these have significantly informed the Authority’s modifications to its original proposals following stakeholder consultation. 184. General BHPA The BHPA welcomes the opportunity to participate in this Consultation. The The BHPA’s objection is noted. The CAA welcomes BHPA’s detailed BHPA has no option but to object to the Consultation’s proposal as it stands at suggestions regarding change options; these have significantly informed the the moment. However, with suitable modifications, the BHPA believes that it can Authority’s modification to its original proposals following stakeholder see a way that it could support a proposal for the replacement of Class F with a consultation. mixture of Class G and Class E+. 185. General BHPA BHPA Proposals for the ADRs The CAA welcomes the BHPA’s analysis of ADR utilisation and its conclusions The BHPA has analysed data from the following sources to arrive at its regarding change options. proposals for the ADRs: These have significantly informed the Authority’s modifications to its original • The dimensions of the existing ADRs proposals following stakeholder consultation. These modifications have resulted • The Consultation’s ADR Uptake data in the volume of Class E+TMZ being reduced both laterally and vertically, thus reducing the impacts of the change on all airspace users. These modifications • The Consultation’s Trajectory Densities data are in part based upon recommendations from SHPF and BHPA. • Knowledge of existing and future CAT timetables Of the future planned airspace, a small amount in the vicinity of Aberdeen and • The BHPA’s usage requirements Sumburgh airports has a base of 4500 ft amsl; most lies above 5500 ft amsl with • Observing real world tracks using www.flightradar24.com at least 50% by area above FL95. This will mitigate the impacts of the planned The following factors were considered significant: TMZ requirements. • FL100 is effectively the highest that BHPA aircraft are interested in and also represents existing transponder and oxygen limits • Class E+ is effectively closed to BHPA aircraft • For transits over hostile territory, be it mountains or the sea, greater height represents greater safety • The HRA represents a significant low level barrier • The need for some ADRs as different routings could offer the same or lower track miles • Both the military and GA desire as large blocks of contiguous Class G airspace as possible 186. General BHPA Subject to it only being implemented for levels where the amount of fixed wing The CAA welcomes the BHPA’s conclusions that Class E+TMZ is the most CAT traffic is sufficient for it to be needed, Class E+ is acknowledged as the appropriate solution for what is currently Class F, whilst acknowledging its most appropriate solution for what is currently Class F. All the remaining Class F objection to the original proposal. should be Class G. However in terms of the options offered in the Consultation BHPA’s detailed suggestions for proposal refinement have significantly informed there are therefore none that we agree with. the Authority’s modifications to its original proposals. These modifications have resulted in the volume of Class E+TMZ being reduced both laterally and vertically, thus reducing the impacts of the change on all airspace users. These modifications are in part based upon recommendations from SHPF and BHPA. Of the future planned airspace, a small amount in the vicinity of Aberdeen and Sumburgh airports has a base of 4500 ft amsl; most lies above 5500 ft amsl with at least 50% by area above FL95. This will mitigate the impacts of the planned TMZ requirements. 187. General bmi regional bmi regional flies very occasionally within Class F airspace in the London and/or Noted.

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE Scottish FIRs. Reclassification as proposed will have no impact upon operations. Nil impact on costs. Bmi regional have considered this proposal and fully support the change to Class E Airspace 188. General GAA Facilitation of Soaring at Cairngorm Gliding Club (Feshiebridge) The CAA is aware of the proximity of the site to N560D/N560. Neither the The gliding club is situated a mere 3.3nm from the edge of the proposed original nor the addendum proposals seek the lateral displacement of any of the controlled airspace. affected routes; this remains the CAA’s position. With this is mind the CAA Ideally N560D would route 5nm further west than its current route, however we welcomes the BGA/NATS engagement in order to develop an appropriate understand that the current consultation does not address its lateral location. We operating agreement that would enhance glider access the eastern half of have had useful discussions with NATS on mitigating the impact by creating an N560D under certain circumstances and subject to certain conditions. The CAA arrangement where the eastern half of N560D could be made available for can offer moderation/mediation if necessary to ensure a successful outcome to gliding on requested days (an analogous arrangement, vital to Deeside Gliding these deliberations. Club, has been in place adjacent to P600 at Aboyne for many years). At the time of writing discussions are incomplete (we have asked SARG to assist with alleviating any buffer policy constraints). More detailed information setting out the gliding safety logic is given in Appendix 1 [of the GAA response] below. The proximity of controlled airspace to Cairngorm Gliding Club is a very real concern. The club operates principally at weekends and during two important two-week periods (during May and October). When weather conditions permit we would ask for the ability to operate (up to FL195) in an area west of Feshiebridge up to the centreline of the current advisory route. There is precedent for such an arrangement where Deeside Gliding Club at Aboyne may request the use of a wave box; when it is activated controllers route P600 traffic east of that airway's centreline. For N560D we would suggest that the northern and southern limits would be GUSSI and abeam Dalwhinnie (c. 35nm S of INS). This arrangement would remove the need for multiple radio calls from clusters of gliders climbing locally to the club and in close proximity to each other (as described above it is most undesirable for a glider to leave a mutual information- sharing frequency in this situation). Such an arrangement would of course be activated responsibly (only during genuine need) and we understand that the Aboyne arrangement has been demonstrated to work well in this way. 189. General GAA Details on Glider Wave Flying in Critical Areas The CAA welcomes the GAA’s detailed input regarding glider operations in the Over a 2 mile wide (North to South) section, gliders operating on the Loch Tay vicinity of ADRs affected by the CAA’s proposals. wave bar are channelled by the wave conditions into a narrow lateral operating Under the CAA’s revised proposals, that part of N560D would have a base of band above and in front of the wave bar lenticular cloud. The importance of FL105, thus reducing (but not removing) the impact of reclassification upon the situational awareness and the contribution that monitoring 130.1MHz makes to glider operations described by the GAA. this cannot be understated. Forcing a change to an ATC frequency in this area It is not clear from the GAA comment whether operations at 12000 ft are will increase the risk of glider on glider collision in the Class G just outside of the frequently undertaken; that operations are undertaken above 12000 ft for a very proposed Class E. Once inside Class E+ the controller may also experience a small number of times suggests that a local operating agreement between “Duty of Care” and feel the need to try to separate gliders from each other; this is affected glider operators and the airspace controlling authority is the appropriate a task more efficiently achieved by pilots who are talking to each other on their means of address glider access issues in the local area. own frequency and concentrating on situational awareness and lookout without the distraction of adjusting multiple digits on a radio. Should gliders consider that they may be close to the relevant VMC minima they will request a formal clearance; the controller will then be obliged to sepate gliders from each other and from other IFR traffic. It is hard to imagine a less efficacious situation. Again this supports a requirement for Class E to have the maximum possible base. [Barograph traces showing the altitude of gliders on a good wave day illustrates] that mean cross country operating heights are in the band 6000’-12000’. In few occasions, 5 or 6 times, gliders have climbed higher for short periods of time. Therefore, if in the area between N56°:10’ and N57°:10’ the Class E had bases Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B36 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE of FL150 or above the collision risk for all aircraft would be minimised. 190. General GAA Points of Principle for Airspace Classification The GAA’s comments are noted, and the GAA’s qualified acknowledgement that Fundamental to this consultation should be the following statement from the Class E+TMZ is an appropriate replacement for Class F is welcomed. CAA’s “CLASS G AIRSPACE FOR THE 21ST CENTURY” paper, paragraph The purpose of the statement in the consultation document was to attract input 3.3.2, that enhanced the CAA’s understanding of the continuing need for routes in “It is only by the use of Class G airspace, and the application of other airspace certain parts of the UK FIRs, based upon utilisation levels. The outline classifications set out in the ICAO Airspace Classifications Policy Statement15, information provided in the consultation package served to inform CAA that the CAA, on behalf of the UK, can ensure that the requirements of owners assumptions as to where Class E+TMZ routes were likely to be required – and operators of all classes of aircraft are met. It is this principle that the least consultation feedback added considerably to that understanding. restrictive classification of airspace (Class G) should be the norm, with more Indeed, it has led the CAA to reconsider its original proposals and as a result a restrictive classifications only being established where necessary, that is one number of ADRs will be disestablished as part of the Class F replacement of the key means by which the CAA meets its statutory obligations for the safe programme. The remainder will either be reduced in length or have wholly or efficient use of airspace permitting the expeditious flow of all air traffic, whilst partially increased base levels (many will have variable bases), or a combination ensuring that all airspace users have reasonable and safe access to the of both. national asset that is airspace.” The CAA is of the view that these refinements answer the GAA’s comment. Paragraph 1.1.3 of the Class F consultation states, “The CAA proposes to regularise all Class F ADRs as Class E airways notified as Transponder Mandatory airspace ….. Exceptionally, and where justified in consultation responses, the CAA will consider either the disestablishment of certain ADRs ….” We question this use of “Exceptionally”, indeed we maintain that considerable portions of the existing ADR route structure are not needed and should be Class G, in keeping with the CAA’s own statement above on Class G being the norm. Subject to it being implemented only where significant CAT densities must exist, Class E+ is acknowledged to be an appropriate solution for what is currently Class F. All the remaining Class F should be Class G. 191. General GAA Equipage Issues The GAA’s concerns are acknowledged, as are the current lack of suitable As has been acknowledged by the CAA on many occasions there are a lightweight transponders and the practical difficulties associated with operating considerable number of UK based aircraft for which there is no suitable hand-held radios as described. transponder in terms of: However, the CAA believes the refinements to its change proposals that see a • the physical ability to fit any of the currently available models, and/or reduction in the amount of Class E+TMZ that will replace Class F will result in a much reduced impact upon the recreational aviation communities referred to in • the available battery life through having no other suitable power source, the GAA’s comment. and/or Nevertheless, the CAA would welcome further engagement with the GAA to gain • the cost of the equipment and its fitting relative to the value of the aircraft, the greatest possible understanding of where the impacts of Class E+TMZ would There are a considerable number of UK based aircraft for which the only be felt by the communities referred to in order to identify what scope existed for practical radio is a hand held unit. This is because of: local operating agreements to be developed in order to reduce the impacts of the • the physical ability to fit any of the currently available models, and/or change proposals further. • the available battery life through having no other suitable power source, and/or • the cost of the equipment and its fitting relative to the value of the aircraft, Hand held radios have a number of issues that will or could render them inappropriate for use to access the Class E+ airspace as described: • They have a much more limited transmit range and will be of no use in some of the current ADR structure • Are not designed for use wearing the types of gloves essential in some aircraft, so frequency changing is very difficult and if possible can be detrimental to aircraft handling, so compromising safety • Are not rugged enough for use in aircraft where the pilot is very open to the elements, and so are stowed in safe locations where frequency changing

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE isn’t possible Therefore Class E+ airspace will be effectively closed to all unpowered hang gliders and paragliders as soaring aircraft cannot predict their track with sufficient accuracy to be able to establish procedural access. Through a possible pre-flight arrangement of some sort, other non-transponder aircraft with little or no radio capability may possibly be able to gain access. However in practice we believe that the airspace will effectively be closed to them as well. 192. General Gama Group Support. Gama’s support for the CAA’s proposals is welcomed. Class E with a TMZ will create a known traffic environment for Gama’s Scottish air ambulance operations There will be some costs involved in an education programme for aircrew. Unknown at present. 193. General GATCO Changes to ATS services will require, in some circumstances, changes to The CAA agrees with GATCO’s observation. operational procedures in accordance with appropriate MATS 2. 194. General Highlands and Islands At a minimum this change will introduce an element of controlled airspace into HIAL’s concerns are acknowledged. Airports Ltd (HIAL) the operational environment within which HIAL ATC units provide an ATS under CONOPS are being developed to provide clarity regarding procedures the rules associated with ATSOCAS. This will pose a considerable challenge applicable to airspace users and service providers alike; HIAL is engaged in this should non-radar units have to provide an ATS within both controlled and non- development process. These will spell out which units can provide what controlled airspace at the same time. The extent of this challenge will be services within the proposed replacement airspace. dictated to some extent by the height of the base of the ADRs within 30 – 40 Nm Radar and non-radar unit interactions will have to be revised upon of the airports. implementation of the changes; this include procedures for transfer of control and bilateral agreements between affected units will need to be developed. HIAL is therefore urged to engage with adjacent units as appropriate to prepare for the revised operating environment. 195. General Highlands and Islands The full range of costs which will be incurred by HIAL as a result of the transition The CAA welcomes HIALs outline assessment of cost impacts and of the Airports Ltd (HIAL) of the ARDs to controlled airspace i.e. Class E or Class C cannot be accurately measures they believe the company will need to take to adjust to the revised assessed at this time based on the fact that we will not know what the final operating arrangements. solution will be until after the consultation process has concluded. However, we HIAL’s comments regarding an ACP for the Highland and Islands region are envisage that HIAL will incur significant costs Management, Training, and noted. Administrative costs. The proposed changes will have an effect to some degree or other on ATS operations at all of HIAL’s 11 airports. Therefore, HIAL will have to establish a Joint Working Group to oversee all aspects of the transition including change management, ATSA/AFISO/ATCO conversion training, and operational substantial changes to operational and training documentation. Management Depending on the scale of the overall change and the time frame involved between the time a final decision is made and the implementation date HIAL may, due to resources, have no option but to contract an outside consultant to project manage this project. As a start point this will include the conduct of an in-depth Training Needs Analysis (TNA) to determine exactly what training requirement will requirement will be for the three categories of ATS staff i.e. ATSAs, AFISOs, and ATCOs. Training Depending on the outcome of the TNA it may be necessary to contract one of the approved Training Providers to deliver conversion for our ATCO (47) compliment. Training for ATSAs and AFISOs could possibly be delivered in- house but this will be confirmed by the TNA. So, taking the possibility of course fees, salaries T&S etc. etc. so, in summary we can expect the overall training costs to be significant. Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B38 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE Documentation Operational and Training ATS documentation will have to change to some extent to reflect the changes. At a minimum his will include all the MATS Part 2, MAFIS, ATCO UTPs, AFISO UTPs, USCs, and TRUCE. LOAs. There will more than likely be a requirement to review the existing LOAs with Prestwick Centre, Aberdeen and RAF Lossimouth etc. depending on the airspace classification of the new routes and the base altitudes ACP The consultation document hints at the fact that if a stakeholder makes a submission which differs from the CAA’s preferred option of a once of across the board change to Class E with MTZ then that stakeholder becomes the sponsor of that proposal and as such becomes liable for the costs of an ACP. While HIAL’s submission proposes something other than the CAA’s preferred option (Class E with MTZs) the fact of the matter is that HIAL simply cannot meet the costs associate with an ACP due to the current financial situation and the timeframe involved. However, this should not preclude HIAL from making a proposal which we consider to be the most appropriate option for the Highland and Islands region. Based on this assumption, we have NOT including the cost of an ACP in this consultation submission. 196. General Highlands and Islands With the exception of the N560D on the GOW to INS route HIAL supports the The CAA welcomes HIAL’s qualified support for its proposals to replace Class F Airports Ltd (HIAL) CAA proposal to replace all of the other existing ADRs with Class E Airspace airspace. and an associated MTZ. In answer to HIAL’s specific comments: HIAL feel that the following issues are worthy consideration and seek clarity on • TSG concluded in 2010 that, based on assessment of ADR utilisation same. originally circulated amongst NATMAC members (25 September 2009) • Confirm the basis upon which the argument to change the ADR running from N560D may warrant reclassification to either Class C or Class E+TMZ. GOW-INS with Class E Airspace is based upon when the 2010 TSG report • The current base of N560D between Wick and Kirkwall is 3000 ft amsl. Under recommended that this route be changed to Class C Airspace. The most the CAA’s revised proposals the replacement Class E+TMZ N560 will have a recent stats indicate that the movement on this route today are relatively base of FL95. similar to what they were in 2010. • There is no requirement for additional safety buffer protection along N560D • Review the base levels of the proposed CAS at Wick and Kirkwall to ensure between INS-WIK route where it abuts D703 (Tain Range). As stated in the that the base heights are sufficiently high enough to afford both ATSUs with CAA’s Safety Buffer Policy, the buffer criteria are not required to be applied sufficient Class G Airspace between the overhead and the base of the new retrospectively where existing airspace arrangements have been proved safe Class E Airspace in order to allow the ATSU to safely manoeuvre its traffic through operational use. and avoid any funnelling effect for transit VFR traffic. • An Air Traffic Control Service is provided to IFR traffic within Class E • Clarify if there is a need for buffer protection along N560D on the INS-WIK airspace; for surveillance-equipped units this is realised through Radar route where it runs adjacent to the D703 (Tain Range). Control. This does not preclude the provision of an Air Traffic Control Service • MATS Part 1 Section 3, Chapter 2, Para 2.2 leads one to conclude that a by non-surveillance means when the capability is unavailable. CAP670 radar control service has to be provided in Class E controlled airspace ? SUR01 provides the surveillance coverage requirements in the terminal and Based on this assumption can the CAA please confirm exactly what type of en-route environments. This currently states that in the en-route low density service provision is permitted within Class E Airspace without the use of environment, ‘coverage shall be provided with data from a suitable co- surveillance radar equipment. operative surveillance technique as a minimum’. However, CAA policy and • Review use/activation of CDR Category One. oversight position on the surveillance availability, constraints, and absence, for the current provision of ATS in today’s Class F airspace, is considered to be appropriate for the direct replacement Class E airspace. ATS units that are not authorised to provide Air Traffic Control Service in controlled airspace shall not provide ATC service to IFR aircraft in Class E airspace. • It is not clear whether the reference to CDR status applies to current use or its application to future routes. Suggestions for CDR use featured in the consultation document; none were provided by stakeholders although a requirement has subsequently emerged (and will be carried forward).

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE 197. General Private pilot [Proposals will lead to major] restriction on paragliding activity in several The comment does not indicate which sites will be affected, therefore it is not established free flying areas, where climbs above the proposed transponder possible to indicate how far and where the CAA’s modified proposals will ceilings are possible. continue to affect operations in the manner suggested.

198. General Private pilot [Proposals will lead to loss] of a number of important and recognised free flying The CAA has, following consultation, modified its proposals such that the areas. Impractical requirement for a transponder. planned volume of Class E+TMZ is reduced both laterally and vertically, thus reducing the impacts of the change on all airspace users. Of the future planned airspace, a small amount in the vicinity of Aberdeen and Sumburgh airports has a base of 4500 ft amsl; most lies above 5500 ft amsl with at least 50% by area above FL95. This will mitigate the impacts of the planned TMZ requirements. Non-SSR aircraft may operate within the replacement airspace but must establish two-way communications with the appropriate controlling authority to do so. 199. General Private pilot [Proposals will lead to not] so much a cost as restriction. Noted. 200. General Private pilot The [proposals show] usual disregard for the foot launched, free-flying The objection is noted. community that actively uses much of Scotland’s Class D airspace on a regular The CAA has, following consultation, modified its proposals such that the basis, from hill height to 9,000ft (when cloudbase allows). The use of a planned volume of Class E+TMZ is reduced both laterally and vertically, thus transponder by paragliders has already been shown to be inappropriate for the reducing the impacts of the change on all airspace users. These modifications sport. are in part based upon recommendations from SHPF and BHPA. Of the future planned airspace, a small amount in the vicinity of Aberdeen and Sumburgh airports has a base of 4500 ft amsl; most lies above 5500 ft amsl with at least 50% by area above FL95. This will mitigate the impacts of the planned TMZ requirements. Non-SSR aircraft may operate within the replacement airspace but must establish two-way communications with the appropriate controlling authority to do so. 201. General Private pilot Object The CAA acknowledges the objection to its original proposals. Any proposal for mandatory transponder use should only apply above 10,000ft These have been modified in response to comments received during consultation 202. General Private pilot There are no transponders suitable for Paragliders and hang gliders . Imposing The concern about transponder availability is acknowledged, however the CAA’s TMZs at the levels proposed would effectively close off the areas concerned for proposals have never suggested wholesale change to Class E+TMZ, only Class free flight use by such gliders F ADRs. The CAA’s original proposal has been significantly modified in the light of consultation responses. This has resulted in a reduction in the volume of Class F that will be replaced by Class E+TMZ, with the remainder reverting to Class G. A number of ADRs will be disestablished in toto, the remainder being reduced either longitudinally or vertically, or both. Of the future planned airspace, a small amount in the vicinity of Aberdeen and Sumburgh airports has a base of 4500 ft amsl; most lies above 5500 ft amsl with at least 50% by area above FL95. This will mitigate the impacts of the planned TMZ requirements. Non-SSR aircraft may operate within the replacement airspace but must establish two-way communications with the appropriate controlling authority to do so. 203. General Private pilot As no practicable Transponders for PG or HG use exist, this is not capable of The concern about transponder availability is acknowledged, however the CAA’s any sensible response. It would effectively prevent flights by paragliders and proposals have never suggested wholesale change to Class E+TMZ, only Class hang gliders in TMZs in the areas proposed F ADRs. The CAA’s original proposal has been significantly modified in the light of consultation responses. This has resulted in a reduction in the volume of Class F that will be replaced by Class E+TMZ, with the remainder reverting to Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B40 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE Class G. Of the future planned airspace, a small amount in the vicinity of Aberdeen and Sumburgh airports has a base of 4500 ft amsl; most lies above 5500 ft amsl with at least 50% by area above FL95. This will mitigate the impacts of the planned TMZ requirements. Non-SSR aircraft may operate within the replacement airspace but must establish two-way communications with the appropriate controlling authority to do so. 204. General Private pilot An increasing number of Paraglider pilots are coming to Scotland to fly in the It is acknowledged that the CAA’s proposals could impact upon airspace users, Highlands following technical development in gliders that now make crossing however the CAA’s proposals have never suggested wholesale change to Class large uninhabited areas more feasible. Several record flights have been E+TMZ, only Class F ADRs. recorded in the last 3 years. One such flight effectively enabled a record score to It is not possible to comment specifically on Mr Kennedy’s statement as no detail be achieved in the British Cross Country League run by the BHPA. It is is provided regarding the routes flown and the feared consequences of the anticipated that this development will continue (the technology is trickling down change. to the types of glider flown by most pilots). The proposed changes would make The CAA has, following consultation, modified its proposals such that the such flights no longer possible. This will have economic consequences for planned volume of Class E+TMZ is reduced both laterally and vertically, thus remote communities who benefit from these tourists and kill of an increasing reducing the impacts of the change on all airspace users. In addition, the CAA market. anticipates affected airspace users and ATS providers to engage with each other to develop operating arrangements that afford the greatest possible access to the new structures. 205. General Private pilot Option 3 is the better option. No appreciable safety benefit would accrue from The CAA’s original proposal has been significantly modified in the light of adopting the preferred option consultation responses. This has resulted in a reduction in the volume of Class F that will be replaced by Class E+TMZ, with the remainder reverting to Class G. A number of ADRs will be disestablished in toto, the remainder being reduced either longitudinally or vertically, or both. 206. General Private pilot An increase in the levels at which TMZs might be imposed to say 10,000ft, (a Modification of the CAA’s proposals has resulted in a reduction in the volume of level beyond ordinary flight capacities of PG and HG given Scottish Class F that will be replaced by Class E+TMZ, with the remainder reverting to meteorological conditions) would address the free flight concerns of PG and HG Class G. Of the future planned airspace, most lies above 5500 ft amsl with at in the areas propsed, should the preferred option be proceeded with. The least 50% by area above FL95. heights proposed in the preferred option would not affect Commercial flights to any major extent nor would an increase to the suggested higher levels 207. General Lanark and Lothian Transponders suitable for Paragliders and hang gliders do not exist. The Consideration of consultation responses has led the CAA to modify its proposals Soaring Club imposition of TMZs at the levels proposed would effectively close off the areas such that the volume of Class E+TMZ will be reduced, both vertically and concerned for free flight use by such gliders laterally, thus reducing the impacts of the changes upon recreational aviation interests. Of the future planned airspace, a small amount in the vicinity of Aberdeen and Sumburgh airports has a base of 4500 ft amsl; most lies above 5500 ft amsl with at least 50% by area above FL95. This will mitigate the impacts of the planned TMZ requirements. Non-SSR aircraft may operate within the replacement airspace but must establish two-way communications with the appropriate controlling authority to do so. 208. General Lanark and Lothian As no practicable Transponders for PG or HG use exist, this is not capable of Of the future planned airspace, a small amount in the vicinity of Aberdeen and Soaring Club any sensible response. It would effectively prevent flights in TMZs in the areas Sumburgh airports has a base of 4500 ft amsl; most lies above 5500 ft amsl with proposed at least 50% by area above FL95. This will mitigate the impacts of the planned TMZ requirements. Non-SSR aircraft may operate within the replacement airspace but must establish two-way communications with the appropriate controlling authority to do so. 209. General Lanark and Lothian Option 3 is the better option. No appreciable safety benefit would accrue from The CAA’s original proposal has been significantly modified in the light of

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE Soaring Club adopting the preferred option consultation responses. This has resulted in a reduction in the volume of Class F that will be replaced by Class E+TMZ, with the remainder reverting to Class G. A number of ADRs will be disestablished in toto, the remainder being reduced either longitudinally or vertically, or both. 210. General Lanark and Lothian An increase in the levels at which TMZs might be imposed, to a level beyond Modification of the CAA’s proposals has resulted in a reduction in the volume of Soaring Club ordinary flight capacities of PG and HG given UK meterological conditions to say Class F that will be replaced by Class E+TMZ, with the remainder reverting to 10,000 would address the free flight concerns of PG and HG in the areas Class G. Of the future planned airspace, most lies above 5500 ft amsl with at concerned, should the preferred option be proceeded with. The heights least 50% by area above FL95. proposed in the preferred option would not affect Commercial flights to any major extent nor would an increase to the suggested higher levels 211. General Lanark and Lothian Object Strongly Noted. Soaring Club The proposal seems unnecessary and unjustified to the extent set out. The CAA’s original proposal has been significantly modified in the light of consultation responses. This has resulted in a reduction in the volume of Class F that will be replaced by Class E+TMZ, with the remainder reverting to Class G. A number of ADRs will be disestablished in toto, the remainder being reduced either longitudinally or vertically, or both. 212. General Loganair Object. The CAA acknowledges Loganair’s conclusion, however the case for As an airline we are one of the biggest users of Class F airspace within the reclassification to anything other than Class E + TMZ (either generally or for Scottish FIR. specific routes) was not presented in any of the consultation responses. Any reclassification could potentially have a detrimental affect on the safety of It is understood that Loganair operates to a significant degree in Class G our operations. airspace and does not believe these to be inherently unsafe. Cost impacts unforeseen at this time. The provision of an air traffic control service to IFR traffic, plus the provision of As a Company our main concern is the safety of our aircraft, crews and traffic information on other aircraft in a transponder mandatory environment is as passengers. good as – if not better than - current ATSOCAS arrangements for Class F in the UK FIRs. Ideally we would like to see the airspace classification ‘upgraded’ and not ‘downgraded’. The loss of any protection afforded to us by the loss of an ADR (eg W958D) would be unacceptable. Should any ADRs have their classification ‘downgraded’ then the busier ADRs (eg N560D and W5D) should be reclassified to Class C. 213. General MOD MOD has considered the options put forward as part of the CAA's consultation As a consequence of stakeholder consultation a number of ADRs will be wholly on the replacement of Class F airspace. The MOD's preference would be to or partially disestablished. The remainder will, upon reclassification, have higher adopt Option 3, that is to replace all existing Class F airspace by Class G base levels than is currently the case, or will be shortened in length, or a airspace. In reaching this conclusion the MOD has taken into consideration the combination of both. number of aircraft movements on the various routes and on the impact that a change to Class E airspace could have on military operational training. 214. General MOD It is acknowledged that Option 3 steers away from the CAA’s preferred option, As a consequence of stakeholder consultation a number of ADRs will be wholly Option 5, which aims to replace all existing Class F airspace by Class E airspace or partially disestablished. The remainder will, upon reclassification, have higher with a TMZ. The MOD considers that the adoption of Option 5, as stated, could base levels than is currently the case, or will be shortened in length, or a unjustifiably result in over classification of airspace in certain areas and it is felt combination of both. that it lacks the clarity of Option 4, which acknowledges that any decision on change should be made on a case-by-case basis. Should Option 5 be amended to a case-by-case basis, the MOD would be more minded to consider Class E airways with TMZ where traffic levels and safety improvements would justify enhanced CAS and the impact on military operational training could be mitigated, such as closure of routes during major exercises. The MOD believes that the number of movements along the majority of these routes might be insufficient to establish CAS through an ACP process, as the Regulator would rightly question the utilisation; therefore, it would be difficult to justify the replacement of most of the ADRs with anything other than Class G routes. 215. General MOD MOD understands that another consultee believes that operations within Class E The provision of an air traffic control service to IFR traffic, plus the provision of Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B42 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE with a TMZ may be less safe than operations in Class G under an ATSOCAS traffic information on other aircraft in a transponder mandatory environment is as and has suggested additional ‘Bolt-Ons’ to mitigate, such as RMZs and insisting good as – if not better than - current ATSOCAS arrangements for Class F in the that aircraft crossing Class E under a service with the military cross as IFR. The UK FIRs. MOD could not accept such restrictions to its operational training as it would In addition, the CAA is considering the appropriateness of providing DS to VFR further impact on our freedom of movement. Should a higher classification of traffic in Class G and will staff any resultant changes to the UK FIS as a airspace be required, this should be approached in a separate consultation. separate project. Additionally, such ‘Bolt-Ons’ are not contained within this consultation and the CONOPS appropriate to Class E + TMZ where this replaces Class F airspace MOD would expect that a further formal consultation would have to be will serve to address crossing VFR traffic. MOD has been a key player in their undertaken if any such proposal was put forward. development and the CAA is confident the issues raised by MOD here are answered by them. 216. General MOD It is considered that the introduction of Class E airspace will add complexity and The observation concerning the Inverness airspace change proposal is noted, loss of flexibility to MOD operational training from an aircrew perspective. The however comment is not possible as the proposal remains under development. majority of existing ADRs are in the Scottish FIR and therefore mostly affect The airport’s consultation on its proposals is not expected to begin until October aircraft operating from RAF Lossiemouth – be they Tornados, Typhoons or 2013. visiting exercise traffic. Most aircraft operating from RAF Lossiemouth currently fly through or operate close to ADRs, be that during transit, Air Combat Training or Medium to Low level Ground Attack training. Typhoon operations will commence at RAF Lossiemouth in 2014 and it is highly likely that they will look to utilise EGD809 more frequently; any increase of classification of the ADRs surrounding this area (W4D, N560D and W5D) would have an impact on their operations. The ACP proposal at Inverness Airport could constrict aircraft operating from RAF Lossiemouth and within Tain Air Weapons Range; an additional airspace change to the ADRs is likely to further restrict operational freedom. The conduct of Class E operations will need to be clarified, in particular with regard to service provision. Agreement will be required to authorise controlling within Class E airways or Class E airspace not including CTZ, CTA and TMA. 217. General MOD It is considered that the introduction of Class E airspace would add complexity The MOD’s comment has been noted. Service provision issues are being and increased workload from a provision of service perspective. addressed through the development of CONOPS appropriate to the replacement structures. MOD has played a pivotal role in this activity and agreement on the final wording of the CONOPS is imminent. 218. General MOD There will be an increased training burden with associated costs, in particular Service provision issues are being addressed through the development of from an ATM and Air Defence controller perspective. The MOD assumes that CONOPS appropriate to the replacement structures. MOD has played a pivotal NATS will continue to provide services to GAT that currently operate within role in this activity and agreement on the final wording of the CONOPS is Class F airspace, following any change to airspace classification either by re- imminent. designation to controlled airspace (CAS) or reversion to Class G. It should not There have been no suggestions whatsoever that NATS will not continue to be assumed that the military will be able to accommodate an extension in its provide services following any change to airspace classification either by re- provision of service under the auspices of ‘irreducible spare capacity’ without designation as Class E + TMZ or reversion to Class G. significantly more cost analysis in terms of both increases to controller numbers The MOD’s comments concerning implementation costs are noted. It is and workstations. It is of note that there is a savings measure for the reduction assumed that costs associated with military aeronautical publications (including of controller numbers; this would need to be re-examined and the console charts) will be absorbed as part of routine document amendment cycles. numbers set out in the MOD/NATS roadmap would need to be reviewed. In addition, there will be costs for amendment to publications, surveillance display mapping, and maps and charts. An increase of the airspace classification to Class E may have operational cost implications, as aircraft may be required to re-route or comply with ATC instructions, which could introduce a delay to their CAS crossing (increase in fuel burn and CO2 emissions). It is impossible to make specific calculations on this until the likely airspace classification for each ADR is known. 219. General MOD A reclassification of airspace could change the behaviour of airspace users. The It is possible that reclassification of airspace could change the behaviour of current arrangements provide a safe and manageable system. Reclassifying certain airspace users, however it is not possible to quantify which users, where

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE some of the Class F airspace north of the Scottish TMA could lead to a and how they will be affected, and to what extent. significant increase in incident reporting even in situations where there has been Aircraft unable to comply with conspicuity and/or communications requirements no change in actual risk. will be affected, but again quantification of the impact is not possible. In addition, placing further restrictions on airspace usage would be incompatible It is not possible to respond to the claim tthat reclassification of some of the with the Government’s stated intent to repatriate some of the air training Class F airspace north of the Scottish TMA could lead to a significant increase in currently conducted overseas due to budgetary pressures. incident reporting as examples of where this could indeed be the case hav not Whilst not acknowledged within the consultation document, there would be a been provided. requirement for the MOD to request suppression of specific routes in order to The CAA notes the assumption that ‘placing further restrictions on airspace facilitate major exercises using Exercise ACNs. usage would be incompatible with the Government’s stated intent to repatriate some of the air training currently conducted overseas due to budgetary pressures’. However, the definitive proposed solution represents the minimum amount of change (and impact) necessary to replace Class F airspace. The CAA’s original proposal has been significantly reduced following its consultation with industry, with an associated reduction in impacts. The CAA acknowledges that there would be a requirement for the MOD to request suppression of specific routes in order to facilitate major exercises using Exercise ACNs. This would be undertaken during the course of exercise planning. One of the replacement routes has been established to facilitate access to/from Oceanic airspace when other routes have been suspended during major exercises. 220. General MOD VFR Conspicuity Code The need for such a code has been discounted. VFR access issues are There is at present no general VFR conspicuity code within the UK SSR code addressed in the draft CONOPS, development of which has been undertaken in allocation plan. The introduction of such a code would allow controllers to concert with MOD. identify where a pilot is operating under such rules, without being in receipt of a service. 221. General MOD IFR Conspicuity Code The need for such a code has been discounted. IFR crossing issues are There could be a separate squawk for operations within Class G airspace to addressed in the draft CONOPS, development of which has been undertaken in indicate that the Flight is being conducted under IFR, but without the receipt of a concert with MOD. service. 222. General MOD AARAs One AARA is affected by the replacement of Class F airspace by Class E+TMZ. ‘Non-Deviating status’ would be required to provide primacy of the refuelling Operating arrangements can be developed to ensure AAR activity is levels against IFR traffic within Class E. appropriately separated from route traffic. 223. General MOD Training Needs Considerations These issues are noted and are being addressed through the development of A standard approach needs to be taken by the SARG to ensure consistency CONOPS applicable to the replacement Class E + TMZ structures. across all ANSPs and other controlling authorities, regarding the application of MOD has played a key role the development of these CONOPS. separation standards, application of rules, and phraseology. Amongst others, suggestions are: • The use of flight rules when passing traffic information so the pilot is aware of separation requirements i.e. “VFR Traffic Left 10 o’clock” etc. • Definition of ‘when practicable’ in regards to the provision of traffic information on or to VFR aircraft and the parameters used to provide such information i.e. how far away. • Definition of ‘Duty of Care’ in regards to aircraft within Class E in line with those stipulated for ATSOCAS, in particular those surrounding IFR and VFR interaction. • The type of service offered to VFR ac and the responsibility of controllers in regards to any instruction given that may place the aircraft in weather conditions that precludes VFR. • The responsibility of controllers in regards to speed restrictions for VFR aircraft operating below FL100. Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B44 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE • The miss-distance advocated between IFR and VFR aircraft when a pilot flying IFR asks for avoidance instructions. • The actions of the controller when it is suspected or known that an aircraft has inadvertently penetrated Class E, and the mechanisms in place to identify such aircraft, given VFR aircraft are not required to maintain radio contact. • The differences between ATSOCAS and the rules used within Class E and the controllers responsibility in regards to aircraft transiting both structures in terms of either separation requirements or deconfliction minima. • Actions in the event of TCAS RA or STCA alerts that would not require controller action within Class E but would in other forms of airspace. 224. General MOD Future MDA Requirements Noted. Any changes to MDA arrangements will be addressed as and when the A review is currently underway to assess if improvements could be made to need arises. make more efficient use of the MDAs. With future changes in aircraft basing, better use could be made of the Northern MDA should the area be extended and the base lowered. This in turn could reduce the MODs dependency on using the Central MDA, allowing more flexible use of that airspace when not in use by the MOD. However, the introduction of Class E CAS for N560D and W5D could prevent the MOD from exploring that option thus reducing the options available to improving FUA in the North Sea airspace. 225. General MOD Object to Option 5, as it does not clearly articulate that changes would be MOD’s comments are noted. considered on a case-by-case basis. Consultation feedback has led modifications to the CAA’s original proposal, such The MOD supports Option 3. that a number of ADRs will be disestablished, with the remainder either being The MOD could accept Option 4 on the basis of Class E CAS (with a TMZ), reduced in length, or base levels raised, or both. providing any reclassification is suitably justified on a case-by-case basis, taking The CAA’s proposed application of Class E + TMZ remains; none of the ADRs into consideration the impact on other airspace users. The MOD would not will be replaced by a more restrictive airspace classification, neither will any bolt- support the inclusion of RMZs and/or additional Bolt-Ons as detailed at para ons such as RMZs be applied to the replacement route structure. 2.3.3e above. Provision needs to be made to close routes to accommodate major exercises. 226. General NATS As part of the assessment of the proposals, NATS made the following The CAA welcomes NATS’ suggestions; these have greatly informed the assumptions: Authority’s modifications to its original proposals. With regards to NATS’ • All new Class E+TMZ Airways would have an upper limit of FL195, with the assumptions: exception of W4D as described in Appendix B [to the NATS consultation • All new Class E+TMZ Airways will have an upper limit of FL195, with the response]. exception of W4D’s upper limit of FL155 between 17nm N and WIK. • For ATS outside Class E+TMZ Airways, the provision of an Air Traffic • UK FIS will continue to be provided outside Class E+TMZ airways as is Service Outside Controlled Airspace (ATSOCAS) will be provided as it is currently the case. now. • The need for internal technical changes arising from the reclassification is • Removal of the ADRs will require some internal technical changes. acknowledged. • Controllers from several NATS units will need to be trained/familiarised to • The need to train personnel is acknowledged. operate a Class E+TMZ Airway. • The CAA notes that NATS has recently launched consultation on its • The Consultation has indicated that the connectivity to the existing Class C proposals to establish Class C stubs. stubs be considered in the light of the proposals. NATS’ proposals indicate • Mode S transponder requirements associated with the TMZ bolt-on will be in that these Class C stubs be revised to better accommodate user profiles accordance with the requirements of Article 39(2) and Schedule 5 to the Air and as such the associated Temporary Reserved Airspace (TRA) Navigation Order 2009 and AIP GEN 1.5, and the operating requirements at boundaries may need to be revised. AIP ENR 1.6. • A Mode S transponder will be mandated for any TMZ established and any • Consultation responses indicate there is no case for the establishment of exemptions approved will be limited to where this can be justified by the RMZs in support of the removal of Class F airspace. users concerned. • To mitigate identified hazards, a Radio Mandatory Zone (RMZ) may be established where appropriate, in line with current CAA Policy. Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B45 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE 227. General NATS Operation of Class E+TMZ Airways will be a new type of operation for NATS and Service provision issues (including VFR/IFR interactions) are being addressed we will need to address IFR/VFR interactions as part of training/familiarisation. through the development of appropriate CONOPS. Current rules in CAP 493 MATS Part 1 as to the scope and priority of traffic NATS are playing a pivotal role in developing these. information on VFR flights, is perceived to be limited and so to accompany the introduction NATS requests the CAA develop further guidance in this area. 228. General NATS To specifically address some of the hazards identified in the safety assessment, The CAA has considered the points raised by NATS as follows: the CAA is asked to consider employing a further suite of regulatory airspace • The new Class E+TMZ Airways will be depicted on AIP ENR 6-1-4-1 and management tools as mitigation to make the Class E+TMZ Airways a suitable VFR charts in accordance with current standards and practices. alternative to the ADRs from a safety perspective. These include but are not • A VFR conspicuity code for aircraft crossing/operating in the vicinity of a limited to: Class E+TMZ Airway is not considered necessary. • The new Class E+TMZ Airways be colour-coded on charts for better • CONOPS appropriate to the replacement airspace are in the process of conspicuity. being developed: NATS has played a central role in this process. The • The establishment of a VFR conspicuity code for aircraft crossing/operating resultant CONOPS will address facilitate civil/military co-ordination, extending in the vicinity of a Class E+TMZ Airway. existing MOD procedures whereby non-autonomous VFR OAT aircraft are • To facilitate civil/military co-ordination, extending existing MOD procedures treated as IFR within CAS whereby non-autonomous VFR OAT aircraft are treated as IFR within CAS. NATS would welcome the opportunity to jointly develop with the CAA our proposals and any of those suggested by the CAA or MOD, so that we have the appropriate tools in place to address the identified risks presented by the removal of the ADRs. 229. General NATS Aberdeen airport does not have SIDs/STARs and therefore all arriving and NATS’ comment is noted. departing traffic must be individually de-conflicted, both laterally and vertically, The potential operational and economic impacts of the original proposals have primarily on a tactical rather than a procedural basis. The airspace available for been acknowledged by the CAA and discussed at length with the service this function is limited, and as such Aberdeen uses a volume of class G airspace provider at Aberdeen. to the north and east of the Aberdeen Control Zone/Area (CTR/A) to de-conflict These deliberations led the CAA to conduct an addendum consultation certain categories of arriving and departing traffic. This traffic originates from the regarding the ‘Aberdeen fillets’. There was no objection to the establishment of existing Class F ADR structure and/or Class G IFR operation and as such can these, and they are a feature of the CAA’s final change proposals. be accommodated via a Deconfliction Service across both classes of airspace. It is the CAA’s firm belief that AIA’s operations will be best served by the establishment of the fillets, and that they will ensure that Aberdeen’s operations remain safely and efficiently undertaken 230. General NATS The main impact from the CAA’s proposals results from Aberdeen ATC The potential operational and economic impacts of the original proposals have compliance with the MATS Part 1 Section 1, Chapter 5, Para 13.1.3 provision, been acknowledged by the CAA and discussed at length with the service which states that “Unless an aircraft has planned to leave controlled airspace, it provider at Aberdeen. is not to be vectored outside the horizontal or vertical limits” of CAS. Should the These deliberations led the CAA to conduct an addendum consultation existing Class F ADRs be replaced by Class E+TMZ Airways, then Aberdeen regarding the ‘Aberdeen fillets’. There was no objection to the establishment of ATC would be precluded from vectoring aircraft into the airspace that is currently these, and they are a feature of the CAA’s final change proposals. used to enable an efficient ATM system. The convergence of W4D, W5D and It is the CAA’s firm belief that AIA’s operations will be best served by the P600D at the ADN VOR would mean that keeping the arrivals and departures establishment of the fillets, and that they will ensure that Aberdeen’s operations within CAS would result in the funnelling of a significant amount of additional remain safely and efficiently undertaken. traffic into the northern part of the Aberdeen CTR/CTA, particularly with respect

to approaches for Runway 34. This constraint will impact the CAA’s aspiration that “There are no plans to change where aircraft physically fly as a result of the proposed regularisation” (Section 2, Para 2.8.1). More significantly however, this would result in a confluence of traffic to the north of the airport with a resultant increase in the number of conflicting tracks required to be tactically deconflicted but with a decrease in the amount of airspace available to achieve this as Class G airspace would no longer be available for this purpose. It is also worth noting that the ADN VOR is situated at 7nm on the final approach track for Runway 16, and also on the climb-out for Runway 34, and is also the Holding Fix for Runway 16 Instrument Approach Procedures. This concentration would result in a significant increase in controller Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B46 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE workload compared to the current operation. A detailed ATM impact assessment on the Aberdeen ATS operation is available for any subsequent discussion between affected parties, as part of the implementation solution for this area. 231. General NATS It is likely that the proposal to replace the Class F ADRs in the vicinity of The potential operational and economic impacts of the original proposals have Aberdeen with Class E+TMZ Airways on a like-for-like basis will have an been acknowledged by the CAA and discussed at length with the service adverse environmental impact and as it currently stands the CAA would need to provider at Aberdeen. carry out an analysis as to its extent. In general terms the requirement to operate These deliberations led the CAA to conduct an addendum consultation within the limits of the new controlled airspace would require changes to the regarding the ‘Aberdeen fillets’. There was no objection to the establishment of Aberdeen operation and therefore at this stage it can assumed that the CAA’s these, and they are a feature of the CAA’s final change proposals. proposals may have a negative environmental impact in the following areas: It is the CAA’s firm belief that AIA’s operations will be best served by the • There would be a likely increase in track miles flown by arrivals and establishment of the fillets, and that they will ensure that Aberdeen’s operations departures. remain safely and efficiently undertaken. • The reduction in airspace available for use would require additional vertical restrictions to be employed for inbound and outbound aircraft in order to ensure that separation requirements could be met. As a consequence there would be a likely increase in periods of level flight. • There would be increased use of the Holding facility. These implications therefore would have a detrimental effect on Aberdeen’s bility to help manage CO2 emissions, fuel burn and other environmental factors. Also of note is the fact that the volume of class G airspace that is currently utilised to provide lateral separation between traffic to the east of the CTA is predominantly over the sea. As such there is a low impact on the environmental factors highlighted in the consultation document (Section 2.8, para 2.8.1 i.e. “noise impact, tranquillity, and visual intrusion”). Should this Class G airspace become unavailable to Aberdeen then the subsequent change to aircraft profiles would increase the amount of traffic operating over land thereby potentially creating e a negative environmental impact on the area. 232. General NATS The challenges to the Aberdeen operation suggested by the CAA’s proposals The potential operational and economic impacts of the original proposals have were identified following real-time simulator exercises of the new CAS structures been acknowledged by the CAA and discussed at length with the service and the safety hazards identified formed part of the overall NATS’ Impact provider at Aberdeen. Assessment referenced in section 3 of this document. These deliberations led the CAA to conduct an addendum consultation To mitigate against the potential for reduced ATM efficiencies and a negative regarding the ‘Aberdeen fillets’. There was no objection to the establishment of environmental impact, Aberdeen proposes the establishment of small Class these, and they are a feature of the CAA’s final change proposals. E+TMZ fillets around the existing CTR/CTA boundaries. It is the CAA’s firm belief that AIA’s operations will be best served by the establishment of the fillets, and that they will ensure that Aberdeen’s operations remain safely and efficiently undertaken. 233. General NATS The proposed Class E+TMZ fillets impact the current boundary of MDA The impacts of the Aberdeen fillets and EGD613A upon each other are EGD613A. This issue may be mitigated by an amendment to the MDA’s lateral acknowledged, and the CAA is of the view that EGD613A should not be reduced dimension in line with the CAA’s Buffer Policy, or in accordance with FUA in size and accepts that activity may take place up to its lateral limits. Therefore principles whereby a process for airspace sharing may be agreed between Flexible Use of Airspace principles must apply in the context of the proposed Aberdeen and the Danger Area sponsor, or by Aberdeen on a procedural ATC Aberdeen fillets. To that end the CAA believes that, when activated, EGD613A basis. A combination of one or more of these may be feasible but in any case will take primacy over that overlapping Aberdeen fillet. When EGD613A is not Aberdeen is happy to consider all options in order to establish a workable activated, the fillet will be used as anticipated. solution for this area. CAA Safety Buffer policy paragraph 2.4 states that ‘Due to the intensive utilisation of some areas of the UK FIRs/UIRs where it may not be possible to meet the needs of all airspace user groups or when dual use (the release of ordnance and unusual air activities) of segregated airspace is considered, it may be appropriate to consider deviation from the above criteria. 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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE policy deviation are provided with the ACP. Should a possible need for such a policy deviation be identified during the airspace design phase, it is recommended occasional activities and/or a airspace sharing arrangements under approved MoU/LoA may also provide suitable mitigation. Therefore it is both necessary and essential that MOD and NATS work to establish operating arrangements to ensure compliance with CAA Safety Buffer Policy requirements, ideally through the identification of appropriate (and safe) mitigations that could include positive ATC management of potentially hazardous activities, dynamic ATM procedures, use of internal safety buffers for occasional activities, airspace sharing arrangements under approved MoU/LoA, any combination of these, or indeed any other agreed solutions. For example, this could be achieved by NATS ensuring that, by means of ATS surveillance in the affected airspace, that aircraft under their control remains clear of the range boundary and from aircraft operating within the range. Any such agreement should be conditional upon MOD providing a clear understanding to NATS of the actual take-up of EGD613A, and for MOD to ensure that robust booking, cancellation and promulgation procedures are applied to ensure the airspace is managed to minimise the impact of activation upon NATS operations. Similarly, MOD should provide NATS with clarity on the nature and conduct of operations undertaken within EGD613A. The CAA is willing to offer mediation/moderation in these deliberations if either party consider it necessary. The CAA is confident that an appropriate operating agreement can be reached between NATS and the MOD in order to maximum utilisation of the airspace by both parties. 234. General Ozone Gliders Ltd [Reclassification] will restrict our flights and the flights of our customers. Ozone Gliders Ltd’s comment is noted, however the nature and extent of the restrictions is not described, therefore a more detailed CAA response is not possible. 235. General Ozone Gliders Ltd The main cost [of implementation] is not definable as it will make the sport less Ozone Gliders Ltd’s attractive to our customers. 236. General Ozone Gliders Ltd [Unforeseen consequences of the proposals include the] potential negative Ozone Gliders Ltd’s comment is noted, however the nature and extent of the economic consequence to a British paraglider and paramotor wing anticipated negative economic impacts to a British paraglider and paramotor manufacturer. wing manufacturer are not described, therefore a more detailed CAA response is not possible. 237. General Ozone Gliders Ltd As the only designer and manufacturer of paragliding and paramotor wings in Comment noted, however it is not clear how the proposals would impact upon the UK, who are also probably number 1 in the world, we are against any the manufacturer as the proposals to not represent a blanket restriction on measures that will restrict our customers pleasure that could mean that the paragliding and paramotoring. Also the comment appears to be economic in attractiveness of our sport is reduced and hence reducing our potential market. nature, yet no indication of the potential const impact is provided, nor is there any indication as to the size of the market in the affected area as a proportion of the company’s total market. 238. General Ozone Gliders Ltd Our customers have to carry on their back what they fly with, therefore weight Ozone Gliders Ltd’s comment is noted. and bulk is of a critical importance to them. The extra weight and bulk of a transponder will cause our sport to be less attractive. Especially in the Highlands of Scotland where the hills we fly from are big and the potential walkouts when going down early can take 6 hours. 239. General Ozone Gliders Ltd Our customers take part in the cheapest form of airsport that is available, the Ozone Gliders Ltd’s comment is noted. added cost of a transponder will reduce the accessibility of our sport. 240. General Ozone Gliders Ltd We have not seen a transponder that is practical in size, weight or cost for use Ozone Gliders Ltd’s comment is noted. on a paraglider/paramotor wing 241. General Pennine Soaring Club Having read the Consultation document again we realise that paragliding The Pennine Soaring Club’s support for the CAA’s proposals for the

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE and hang gliding in our local area will not be impacted as W2D (paragraph 2.7) disestablishment of W2D are welcomed by the Authority. is to be disestablished. The Pennine Soaring club support the disestablishment of W2D. But the Pennine Soaring Club feel it is still important for us to submit a response as many of our members often travel to Scotland for the excellent flying – which we believe the current proposals would greatly curtail. We know the Scottish Hang gliding and Paragliding Federation have submitted a response, the PSC wish to support the SHPF’s response to indicate that it is not just pilots from Scotland who fly there, many pilots from south of the border travel north to fly. In fact pilots from all round the world travel to Scotland to fly. 242. General Pennine Soaring Club If Scottish ADRs are changed to Class E as proposed the impact on cross- The Pennine Soaring Club’s concerns are acknowledged, although it is not clear county Hang Gliding and Paragliding in Scotland would be catastrophic. There how significant an impact the change proposals would have upon their member would be no reason for our members to make the long drive to Scotland. specifically, or where the cross-country activity takes place. Consultation feedback has led the CAA to revise its change proposals; the BHPA and BGA have played a significant role in this process. These modified proposals result in the disestablishment of a number of ADRs, while the volume of Class E+TMZ that will be established is rather less than that originally proposed. Therefore the impacts of the changes upon all airspace users will be markedly reduced. 243. General Pennine Soaring Club [An unforeseen consequence of the proposal is that it] would effectively ban Given the current extent of Class F airspace it is not clear how the original hang gliding and paragliding activity in much of Scotland, as these aircraft will proposals ‘would effectively ban hang gliding and paragliding activity in much of NOT be able to fly in the proposed Class E airspace. Scotland’, as much of Scottish airspace is Class G. The CAA’s modified proposals result in the disestablishment of a number of ADRs, while the volume of Class E+TMZ that will be established is rather less than that originally proposed. Therefore the impacts of the changes upon all airspace users will be markedly reduced. 244. General Pennine Soaring Club The PSC promote and manage hang gliding and paragliding in the mid Pennine The Pennine Soaring Club’s comments and its support of the SHPF’s hills (between Lancaster / Manchester and Leeds) so our area is not directly consultation response are noted. impacted by the current proposal. Consultation feedback has led the CAA to revise its change proposals; the But many PSC members often travel to Scotland to free fly and take part in flying BHPA, the SHPF and BGA have played a significant role in this process. These competitions. If the current proposal (Option 5) were to be implemented, hang modified proposals result in the disestablishment of a number of ADRs, while the gliding and paragliding would be impacted so negatively that our members would volume of Class E+TMZ that will be established is rather less than that originally no longer feel it worth travelling to Scotland to fly. proposed. Therefore the impacts of the changes upon all airspace users will be Replacing Class F with Class E would effectively ban hang gliding and markedly reduced. paragliding in much of Scotland as current technology means there is no suitable transponder or airband radio for foot launched aircraft. So the PSC wish to support the Scottish Hang Gliding & Paragliding Federation's (SHPF) objection. The is no point in the PSC repeating each point in the SHPF's response, the PSC want to add weight to the SHPF's recommendation for Option 4. The PSC want to make it clear that it is not just Scottish pilots that will be negatively impacted by the current proposal, many pilots in England will also so impacted. 245. General Sandair Reclassification to E will limit flying training above FL35. TMZ will require The CAA acknowledges the stakeholder’s concerns. clearance from Mode C or non-equipped aircraft Part of W4D currently has a base of FL35; under the CAA’s original proposals this would have been reclassified as Class E+TMZ. However, modification of these following stakeholder consultation will result in most of the replacement airspace having bases at or above FL75; the lowest bases will be 4500 ft amsl in the vicinity of the Aberdeen CTR/CTA and to the south of Sumburgh. Part of W6D will retain a base of FL55 between ULLA and Stornoway More generally, a number of ADRs will now be disestablished and the remainder either reduced in length or have raised base levels, or a combination of both, Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B49 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE thus reducing the impact upon non-SSR operations. That said, TMZ status will still apply to the replacement Class E airspace – CONOPS that are currently under development will provide clarity on service provision requirements regarding non-SSR aircraft and these will be reflected in pre-implementation awareness material and the UK AIP. VFR aircraft operating without a functioning Mode S SSR transponder shall be required to obtain approval to enter the airspace from the notified civilian airspace controlling authority. Such aircraft are required to be either in radio contact with the controlling authority (but would not require a clearance to cross), or to operate in accordance with agreed procedures. 246. General Sandair [Reclassification will] require VMC Conditions (1000feet 1500m separation from VFR flight within the replacement Class E+TMZ airspace will be required to cloud) to operate in Class E where at present can operate below those limits. comply with the applicable VMC, namely 1500 m horizontal and 1000 ft vertical distance from cloud. Modification of the CAA’s original change proposal will result in the disestablishment of several extant ADRs, while the remaining routes will either be reduced in length or have their base levels raised, or both. Of the future planned airspace, most lies above 7500 ft amsl with at least 50% by area above FL95. This will mitigate the impacts of the more restrictive VMC in Class E. 247. General Sandair [Reclassification will result in more] operations concentrated outside and below The comment is noted however the CAA is of the view that, whilst the planned the current Class F. reclassification could change the behaviour of certain airspace users, it is not possible to quantify which users, where and how they will be affected, and to what extent. Aircraft unable to comply with conspicuity and/or communications requirements will be affected, but again quantification of the impact is not possible. 248. General Sandair Object Deconfliction Service will remain available to airspace users operating in Class Deconfliction in Class G will remain used most often and the additional G airspace, however the CAA is reviewing (as a separate undertaking) the restrictions and re-equipment requirements of Class E TMZ are unnecessary appropriateness of providing the service to VFR traffic. 249. General Scottish Hang Gliding & If existing Scottish Class F airspace is reclassified as Class E+, as proposed, It is acknowledged that the CAA’s proposals could impact upon airspace users, Paragliding Federation then Hang Gliders and Paragliders (HGs/PGs) will be significantly affected as however the CAA’s proposals have never suggested wholesale change to Class current flight activities cross current class F ADRs on a regular basis. Several E+TMZ, only Class F ADRs. world class launch sites will be directly affected by new class E+ being It is not possible to comment specifically on Mr Kennedy’s statement as no detail established overhead. Equipment practicalities mean that HGs and PGs cannot is provided regarding the routes flown and the feared consequences of the carry the necessary flight equipment to access E+ airspace. change. The CAA has, following consultation, modified its proposals such that the planned volume of Class E+TMZ is reduced both laterally and vertically, thus reducing the impacts of the change on all airspace users. In addition, the CAA anticipates affected airspace users and ATS providers to engage with each other to develop operating arrangements that afford the greatest possible access to the new structures. 250. General Scottish Hang Gliding & Access to Class F airspace (which is currently accessible to Hang Gliding and The SHPF’s concern is acknowledged, however it should be noted that the CAA Paragliding Federation Paragliding pilots) will be lost if reclassified Class E+ has, following consultation, modified its proposals such that the planned volume of Class E+TMZ is reduced both laterally and vertically, thus reducing the impacts of the change on all airspace users. Of the future planned airspace, a small amount in the vicinity of Aberdeen and Sumburgh airports has a base of 4500 ft amsl; most lies above 5500 ft amsl with at least 50% by area above FL95. This will mitigate the impacts of the planned TMZ requirements. Non-SSR aircraft may operate within the replacement airspace but must establish two-way communications with the appropriate controlling authority to

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE do so. Finally, the CAA anticipates affected airspace users and ATS providers to engage with each other to develop operating arrangements that afford the greatest possible access to the new structures. 251. General Scottish Hang Gliding & The SHPF objects to the proposal in its current form, specifically Option 5. The CAA acknowledges the SHPF’s comments and has used their detailed Paragliding Federation SHPF recommend Option 4, i.e. a fair assessment of current airspace usage suggestions regarding future route structure (along with the BHPA’s) to help levels and appropriate provision of E+ with suitable lower levels rather than a inform its modified change proposals. Consequently, the planned volume of blanket reclassification of current F. Class E+TMZ is reduced both laterally and vertically, thus reducing the impacts Wholesale reclassification of Class F to Class E+ would make such airspace of the change on all airspace users. unavailable to hang gliders and paragliders, since there is no suitable Of the future planned airspace, a small amount in the vicinity of Aberdeen and transponder or airband radio equipment available to us. Sumburgh airports has a base of 4500 ft amsl; most lies above 5500 ft amsl with There should be no controlled airspace where there is no justification for it. at least 50% by area above FL95. This will mitigate the impacts of the planned Where there is justification, the controlled airspace lower vertical level should be TMZ requirements. as high as possible so as not to negatively impact our current usage of class F Non-SSR aircraft may operate within the replacement airspace but must ADRs. establish two-way communications with the appropriate controlling authority to The SHPF have made an assessment of our desired minimum lower limits of do so. each ADR section based on our current usage patterns (see Appendix 1 [to the Finally, the CAA anticipates affected airspace users and ATS providers to SHPF response]). It is clear that some of the ADRs have very low utilisation by engage with each other to develop operating arrangements that afford the commercial traffic (see Map 2 in Appendix 2 [to the SHPF response]) at lower greatest possible access to the new structures. levels and could be reclassified (in whole or in part) as class G. The SHPF considers that E+ should be limited to FL100 or above wherever feasible. The SHPF understand that the BHPA will be making a further case for raising lower limits, or disestablishment of certain ADRs based on the Trajectory Density Plots shown in the NATS presentation. 252. General Private pilot I would like to register my strong objection to the proposed changing of Class F The objection is noted. airspace in the UK to E+. The CAA has, following consultation, modified its proposals such that the I have been a paraglider pilot for the past 25 years flying in the UK and planned volume of Class E+TMZ is reduced both laterally and vertically, thus internationally. We enjoy world class flying conditions in the UK and in Scotland reducing the impacts of the change on all airspace users. These modifications exist some of our most spectacular locations. The experience of flying in these are in part based upon recommendations from SHPF and BHPA. conditions has resulted in UK pilots performing at the highest level in Of the future planned airspace, a small amount in the vicinity of Aberdeen and international competitions and with outstanding results. Sumburgh airports has a base of 4500 ft amsl; most lies above 5500 ft amsl with In the post-Olympic 'legacy' of inspiring a generation of young people to get out at least 50% by area above FL95. This will mitigate the impacts of the planned and engage in sport the proposed changes will severely limit the aspirations of a TMZ requirements. new generation of young paraglider and hang glider pilots. These sports may not Non-SSR aircraft may operate within the replacement airspace but must be mainstream but access should be no less available. establish two-way communications with the appropriate controlling authority to The proposed changes will require carrying and using equipment that is just not do so. feasible for paraglider and hang gliders. I recognise that the CAA must re-classify Class F airspace but would ask that this is not done as a blanket change. I support the recommendations being made by the SHPF and the BHPA. 253. General Private pilot The heights at which transponders are mandatory are too low. On very good Modification of the CAA’s proposals has resulted in a reduction in the volume of spring cross country days, altitudes of 7,000’ have regularly been achieved by Class F that will be replaced by Class E+TMZ, with the remainder reverting to pilots. Class G. Of the future planned airspace, most lies above 5500 ft amsl with at least 50% by area above FL95. This will mitigate the impacts of the more restrictive VMC in Class E. 254. General Private pilot Until transponders are small and cheap enough to be carried by foot-launched The concern about transponder availability is acknowledged, however the CAA’s pilots, then any transponder option will always be opposed by the free-flying proposals have never suggested wholesale change to Class E+TMZ, only Class community. F ADRs. Consideration of consultation responses has led the CAA to modify its proposals such that the volume of Class E+TMZ will be reduced, both vertically and laterally, thus reducing the impacts of the changes upon recreational aviation Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B51 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE interests. 255. General Private pilot Object Noted 256. General Private pilot I am an active Hang Glider pilot, living in Perth, flying both for leisure and The CAA welcomes the detailed feedback and acknowledges the current lack of competitively throughout Europe, I have flown for both the UK national team and suitable lightweight transponders and the practical difficulties associated with the Scottish national team. I fly approximately 100 hours per annum and have carrying and operating both these and hand-held radios as described. 1500 hours of airtime. The BHPA and SHPF consultation responses have greatly informed the CAA’s I am also a member of the BHPA who I understand will be responding, however, post-consultation refinement of its original proposals for the replacement of given the significance of this proposal I felt the need to provide feedback directly Class F airspace, such that the volume of Class E+TMZ resulting from the and present my personal views. change will be reduced. This reduction will result from the non-replacement of a Living in Perth the bulk of my flying is in Scotland, this is one of the last areas in number of ADRs, plus reductions in the lengths and/or increases in the bases of the UK where it is possible to attain large distances without meeting airspace the remainder. restrictions and as such this is a national asset for free flying in the UK. My Of the future planned airspace, a small amount in the vicinity of Aberdeen and flying is typically at altitudes up to cloud base usually a maximum of 8000' on Sumburgh airports has a base of 4500 ft amsl; most lies above 5500 ft amsl with unstable days and up to 10,000 foot (wave) on stable days, the average height at least 50% by area above FL95. over a whole flight would typically be 4000' with the high climbs necessary to With regards to the areas described in Mr Reid’s response, N560D/N560’s cover distance. base levels will become variable - from south to north bases of 5500 ft amsl, The mountains in this area are typically between 3000;-4000' in order to cross FL105, FL95 and FL75 will now be proposed, the majority of the route being the more remote areas a good level of clearance above the mountain tops is above FL75. necessary, increasingly so with the proliferation of wind farms. Of the sites specifically referred to by Mr Reid, Class E+TMZ will now be Flights typically can last up to 5 hours with record class flights up to 8 hours. proposed as follows: The current Class F routes are close to or above Hang Gliding sites of national • Ben Lawers – base FL105. significance, including Ben Lawers, Glencoe and Strathyre, these have been the • Glencoe – no impact, A1D to be disestablished. starting points for National record flights. • Strathyre – base 5500 ft amsl (to accommodate Glasgow departures and If you are familiar with hang gliders and para-gliders you will appreciate the arrivals to and from the north). The segment with the revised proposed following: base of FL105 would begin at Killin, approximately 8 nm north of • They are a relatively affordable means of flying and as result accessible to Strathyre. less wealthy members of society, a transponder if available would in some The CAA believes the refinements to its change proposals that bring a reduction cases double the cost of equipment. in the amount of Class E+TMZ that will replace Class F will, overall, present a • They have no power supply of significance. reduced impact upon the recreational aviation activities than the original • They have limited payload capacity proposals. • Any unsuspended mass on the glider is a potential source of injury to the pilot in the event of a poor landing • There is no Transponder available with a suitable price point, low power consumption or weight and size for hang gliders or para-gliders. • Pilots have to physically carry equipment to launch so weight is of significance. • Hang gliders and para-gliders typically do not carry air-band radios, if carried they have limited scope for altering frequencies or completing complex dialogues. As a result transponders are to all intents and purposes a nail in the coffin of the sport and given the cost of alternatives would deny a section of society from aviation of any note, and impact on the economy of the highlands where free flying activity is now providing a contribution to the local economy. Given your position i.e. recommending option 5 this would make the new Class E airspace a glider exclusion zone severely impacting the flight potential north of the Scottish TMA. I would like to point out a number of factors which I believe would point to the case for making Hang Gliders and Para-gliders exempt from any Transponder requirements: • I note the air traffic density plots provided indicate that below FL100 the

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE amount of air traffic north of the central belt is extremely low including in existing Class F airspace, this plot does not factor in time of day or day of week, and yet in terms of assessing the risk this would be relevant with the greatest density of domestic commercial flights taking place early and late in the day and during weekdays. For a number of reasons Hang Gliders and para-gliders have a relatively light contribution to collision risk in the case of the Class F north of the Scottish TMA. 1. The vast majority of flights take place during weekends or public holidays 2. Flights take place typically between 11:00 and 17:00 3. Flights are always made in good visibility 4. The average height of a Hang glider flight is relatively low (3-4000'asl) with only a relatively small (but essential) proportion of any flight spent above 6000'. 5. Hang Gliders and Para-gliders do not fly with oxygen as a result we have a natural ceiling of approx 10,000' above which transponder enforcement would have no practical impact on the sport. 6. In practice a commercial aircraft flying an 5800' would be crossing terrain with a clearance of 1800' in the case of Ben Lawers, not something that most commercial airlines would consider as routine! I do understand the need for change and trust you will consider these observations in your deliberations taking into account all forms of aviation to form a pragmatic implementation of this proposed change, by which I mean: 1. Reclassification of Class F to Class E with no requirement for Hang Gliders and Para-gliders to carry Transponders below 10,000' within Class E. 2. Or increase the base of the proposed Class E to FL100 or above (Preferred) 257. General Private pilot Several sites and popular cross country flying routes will become unusable due Modification of the CAA’s proposals has resulted in a reduction in the volume of to altitude restrictions in A1D, W6D, N560D. Transponders for unpowered Class F that will be replaced by Class E+TMZ, with the remainder reverting to aircraft are currently impractical/unavailable and therefore the reclassification will Class G. Of the future planned airspace, most lies above 5500 ft amsl with at curtail our existing operations severely and provide no alternative. least 50% by area above FL95. A1D will be disestablished in toto; 50% of W6D will have a base of 5500ft amsl, the remainder FL95. N560D’s base levels will vary (from south to north) from 5500 ft amsl, FL105, FL95 and FL75, the majority being above FL75. Non-SSR aircraft may operate within the replacement airspace but must establish two-way communications with the appropriate controlling authority to do so. 258. General Private pilot The sports of paragliding and hang-gliding will be diminished at several popular The comment does not indicate which sites will be affected, therefore it is not flying sites in the Scottish Highlands. possible to indicate how far and where the CAA’s modified proposals will continue to affect operations in the manner suggested. 259. General Private pilot A1D, W6D, N560D appear unused between FL75 - FL55 and rarely used up to Modification of the CAA’s proposals has resulted in a reduction in the volume of FL95. Preventing us from using this airspace at these levels will end our current Class F that will be replaced by Class E+TMZ, with the remainder reverting to activities in these areas but not benefit other users. Class G. Of the future planned airspace, most lies above 5500 ft amsl with at least 50% by area above FL95. This will mitigate the impacts of the more restrictive VMC in Class E. A1D will be disestablished in toto; 50% of W6D will have a base of 5500ft amsl, the remainder FL95. N560D’s base levels will vary (from south to north) from 5500 ft amsl, FL105, FL95 and FL75, the majority being above FL75. 260. General Private pilot Object Modification of the CAA’s proposals has resulted in a reduction in the volume of I understand that Paragliding is a minor consideration and Class F ADRs require Class F that will be replaced by Class E+TMZ, with the remainder reverting to replacement but believe reclassification of A1D, W6D, N560D to Transponder Class G. Of the future planned airspace, most lies above 5500 ft amsl with at Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B53 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE Mandatory Class E Airways should only be above FL95 to allow the continuation least 50% by area above FL95. This will mitigate the impacts of the more of Paragliding and Hangliding below these levels. restrictive VMC in Class E. A1D will be disestablished in toto; 50% of W6D will have a base of 5500ft amsl, the remainder FL95. N560D’s base levels will vary (from south to north) from 5500 ft amsl, FL105, FL95 and FL75, the majority being above FL75. 261. General ATC Instructor My proposal relates to MATS 1 Section 1 Chapter 2.68 relating to the guidelines Accepted. MATS Pt 1 text reviewed and amended as appropriate. for controllers when aircraft navigation lights fail at night. Prior to the introduction in the UK of VFR at night, the recommendation that controllers should authorise the flight if it was to be contained wholly within UK controlled airspace was based on the presumption of a known traffic environment. Now that a VFR flight may be conducted at night inside controlled airspace without ATC clearance, the see and avoid principle for the VFR aircraft could be negated against an IFR flight without any navigation lights. Although the proposal includes the introduction of a TMZ, I would like to suggest that the guidelines for controllers be amended to exclude Class E airspace.

ADDENDUM CONSULTATION (ABERDEEN FILLETS)

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE 262. Addendum Consultation Defence Airspace Air Another solution could be to remove the requirement within the MATS Part 1 that The CAA does not believe this to be a practical solution as the consequences Introduction, paras 3 and Traffic Management requires ATC not to vector aircraft outside the horizontal or vertical limits of would have far-ranging consequences throughout the UK FIRs. 4 controlled airspace unless an aircraft has planned to leave it. 263. Addendum Consultation Aberdeen Airport Introduction – reference ‘There are no plans to change where aircraft physically Noted. This was considered by the CAA prior to launching addendum Introduction Consultative Committee fly as a result of the proposed regularisation and generate adverse consultation. environmental impacts.’ We strongly urge that this principle must be achieved in the proposed reclassification of air space necessary for the continued smooth operation of Aberdeen International Airport. 264. Addendum Consultation Aberdeen Airport As a Consultative Committee made up almost entirely of lay people, in terms of The CAA welcomes the Consultative Committee’s comments and acknowledges 2.1.1, 2.1.4 Consultative Committee air traffic control matters, we must accept at face value that it is perceived by its support for the proposed Aberdeen ‘fillets’. ICAO desirable for the existing Class F air space in the UK to be reclassified. However, we are concerned that ICAO, in concluding that the use of Class F is ‘an inappropriate use of airspace classification’, CAA has had to observe that this requirement has had ‘an unintended/unforeseen consequence’ on the air traffic management of the UK’s fifth busiest airport (in terms of aircraft movements) and most important heliport. We are grateful to the management of NATS Aberdeen for raising this issue with the CAA, the management of Aberdeen International Airport and other stakeholders, and to the CAA for pursuing a double round of consultation on how the potential problems of the ICAO requirement might best be resolved to the satisfaction of NATS, the airport, the operators that regularly use the airfield, travellers and the local economy. The airport is too vital to the local resident and business population for a remotely-located international body to require a reclassification that could potentially impact adversely on the airport’s current operations and growth aspirations. If the ‘Aberdeen fillets’ will provide an enduring and sustainable solution to the

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE problem, then we support it. 265. Addendum Consultation Aberdeen Airport These two paragraphs sum up the unique traffic mix that AIA experiences and The CAA welcomes the Consultative Committee’s detailed comments 2.2.2, 2.2.7 Consultative Committee the range of prevailing weather conditions, and underscore in our opinion the concerning operations in the Aberdeen area – these supplement those provided need to ensure that there is absolutely no reduction in air space available to the by the airport itself and NATS – and the impacts associated with not establishing air traffic control service for the airport. the proposed Aberdeen ‘fillets’. The peak flow of 40+ aircraft movements an hour is essential for the diverse range of operators to maintain their published schedules and to make the most effective of their equipment. There has for some time been a conflict of demand for air traffic movements between the operators of fixed wing scheduled services working under slot allocation constraints and the rotary operators seeking to meet the demands of their energy company customers for maximum rotations within the hours available to them. This is most apparent from about 0600 until 0730 when every operator on the airfield is keen to expedite their first flights of the day. As CAA are aware, in good weather, NATS is able more easily to segregate fixed wing and rotary arrivals and departures, with the latter taking routes to the east away from the main 16/34 runway over local residential areas. In poor visibility and other adverse weather conditions, helicopters have to use the ILS approach, already requiring holding of fixed wing aircraft. Failure to provide the fillets will inevitably have an unwelcome impact on fixed wing schedules, with the associated costs to the operators, and frustration and potential missed connections for travellers. 266. Addendum Consultation Flybe Given that Aberdeen is 5th busiest airport in the UK (2.2.2) perhaps some Aberdeen SIDs and STARs are beyond the scope of the Class F project. 2.2.3 thought should be given to Standard Instrument Departure and Arrival AIA may in due course choose to develop and submit an airspace change in procedures in the future accordance with the CAA’s airspace change process should it identify a requirement for SIDs and STARs. 267. Addendum Consultation Aberdeen Airport The reference to offshore Danger Area 613 underscores the further dimension in The CAA acknowledges that the Aberdeen fillet/EGD613A overlap is required to 2.2.6 Consultative Committee air traffic management for AIA, around which there are located a number of comply with CAA Safety Buffer Policy requirements, or in accordance with military flying zones. Whilst the Consultative Committee would not wish to Flexible Use of Airspace principles. request any reduction in the size of these zones, military and civilian aviation The CAA is confident that an appropriate operating agreement can be reached must each have sufficient preserved air space for their needs. between NATS and the MOD in order to maximum utilisation of the airspace by both parties. 268. Addendum Consultation Defence Airspace Air This proposal should have no effect on the use of Aberdeen for Practise The MOD’s comments are noted. 2.2.6 Traffic Management Diversions. The issue is the proposed impact on EGD613A; the MOD is unable to accept any reduction in size of this DA. 269. Addendum Consultation Aberdeen Airport This paragraph, in our view, clearly summarises the predicament which the The Consultative Committee’s comment is noted. 2.2.8 Consultative Committee ICAO requirement has created and which we, on behalf of all our respective stakeholders, would wish to see resolved satisfactorily. 270. Addendum Consultation Defence Airspace Air Another solution could be to remove the requirement within the MATS Part 1 that The CAA does not believe this to be a practical solution. 2.2.8 Traffic Management requires ATC not to vector aircraft outside the horizontal or vertical limits of controlled airspace unless an aircraft has planned to leave it. 271. Addendum Consultation Aberdeen Airport This is the paragraph on which we have the strongest views on behalf of our The Consultative Committee’s detailed comments concerning the economic 2.2.9 Consultative Committee stakeholders, including the airport operators, the helicopter operators’ significance of Aberdeen Airport to the local area and by inference the likely association, the local authorities’ economic development service, the local impacts of not establishing the Aberdeen ‘fillets’ are acknowledged. These chamber of commerce and business and leisure travellers collectively. supplement the comments provided by the Airport itself and NATS. Since Aberdeen is at the periphery of the UK, recourse to air travel is much greater than further south, where rail and road both offer an alternative to air, where journey times can be completed within 3½ to 4 hours (the measure recognised by the DfT as the length of journey where travellers should be discouraged from flying). The propensity to fly on business (5.1) is higher than at

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE any other airport in the UK. The proportion of business travellers and lone travellers (both at almost 60% of total passengers) is greater than at any other airport in the UK, apart perhaps London City. The proportion of traffic that originates at AIA and continues through the hub airports in the UK, The Netherlands, France, Germany and Scandinavia, is potentially higher than at any other UK airport. The main local business sectors (oil, gas and renewables; life sciences; financial services; high added-value food and drink; and higher education) all require regular, frequent and easy access to scheduled air services, more often to many of the more remote areas of the world. Furthermore, the energy companies responsible for the operation of exploration and production rigs in the UK sector of the North Sea are increasingly requiring access to a mixed fleet, including a greater number of fixed wing services to link with rotary services from Scatsta and Sumburgh, adding further to the demand for airspace access to and from Aberdeen International Airport. As exploration continues West of Shetland, this demand is likely to increase further, adding yet more pressure to the ATC service. None of these sectors would thank ICAO and the CAA if the airport had to suffer the reduction of up to 20% in capacity at peak periods that it has estimated, based on the proposed reclassification without the additional fillets. AIA has been one of the fastest growing airports in the UK, with new services being announced on a regular basis, and with an aspiration also to grow its leisure business. The Consultative Committee has consistently shown its support to the airport’s Master Plans, and would not wish to see this trend put into reverse as the result of an ‘unintended/unforeseen consequence’ of a decision taken by the international body for civil aviation. The importance of the airport to the region is further underlined by the very substantial investment in new business and industrial premises and hotels that will effectively form an ‘airport city’ once completed. Finally, without seeking to labour the issue, we would be concerned at the prospect of additional noise and carbon pollution arising from the ICAO requirement, or most particularly any increased risk to safety. 272. Addendum Consultation Flybe Whilst not objecting with the proposal, Class A would be the most suitable for Flybe’s comment is noted, however as stated in the consultation document, any 2.3 commercial operations, but recognise that this is trade-off between delay and classification other than that proposed must be subject to an airspace change fuel efficiency as noted in 2.2.9 as well as a constraint on CAA and AIA. sponsored by the appropriate organisation (not the CAA). No such proposals featured in consultation responses. 273. Addendum Consultation Grampian Microlight The mention of TMZs is of concern since most of our based aircraft are not Grampian Microlight Flying Club’s concerns are noted and the CAA would urge 2.3.1c Flying Club transponder equipped. Aberdeen ATC to develop an operating agreement with them to ensure that the AT PRESENT the limits of the airspace proposed are manageable in that operational impacts of the proposed fillets are kept to a minimum. respect however any future proposals that would propose further increasing regulated airspace, particularly at lower levels, and any introduction of a TMZ concurrent with all off Aberdeen airspace would be greatly resisted by us. This change will only very slightly impact on our operations and we can accommodate the proposal AT PRESENT 274. Addendum Consultation Aberdeen International If the final decision of this consultation is to move all Class F Airspace to Class E The CAA welcomes AIA’s support for its proposals to establish the Aberdeen 2.3.4 Airport Airspace, the ability that the airport has to efficiently position aircraft into and out fillets. of the airfield will be compromised I would therefore urge you to consider what for us is the only viable alternative in allowing Class E Airspace fillets to be added to link what will become the Class E Airways. This is essential to allow Aberdeen International Airport to continue to grow and prosper, and as such continue to allow the prosperity of the region to be supported fully by an integral transport link. Option 3 carries our full support.

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE 275. Addendum Consultation Aberdeen Airport The Committee has received briefings from the General Manager of NATS Aberdeen Airport Consultative Committee’s support for the CAA’s addendum 2.3.4, 2.3.5, 2.5.1, 2.5.2 Consultative Committee Aberdeen. Based on his extensive experience, we are persuaded to accept proposals is welcomed. whatever solution he sees (in consultation with CAA) as appropriate. Since that is Option 3, then we support it, particularly for the reasons set out in 2.3.5 b and f and the supporting comment in 2.5.1 and 2.5.2. 276. Addendum Consultation Defence Airspace Air The application of a TMZ within Class E would be accepted. MOD’s support for the CAA’s addendum proposals is welcomed. 2.3.5c Traffic Management 277. Addendum Consultation Defence Airspace Air The airspace in question could still be accessed autonomously in VFR and with The CAA welcomes MOD’s detailed comment. 2.3.5d Traffic Management a clearance if IFR. As such the impact on military training operations is likely to The impacts of the Aberdeen fillets and EGD613A upon each other are be minimal, albeit that consideration will need to be given to the effect on acknowledged, and the CAA is of the view that EGD613A should not be reduced EGD613A. During discussions with the CAA, NATS, DAATM and aircrew in size and accepts that activity may take place up to its lateral limits. Therefore representatives from RAF Leuchars and RAF Lossiemouth, it was considered Flexible Use of Airspace principles must apply in the context of the proposed that the changes associated with this proposal could be safely accommodated Aberdeen fillets. To that end the CAA believes that, when activated, EGD613A without any detrimental effect, providing agreement can be reached on how to will take primacy over that overlapping Aberdeen fillet. When EGD613A is not deal with EGD613A. activated, the fillet will be used as anticipated. CAA Safety Buffer policy paragraph 2.4 states that ‘Due to the intensive utilisation of some areas of the UK FIRs/UIRs where it may not be possible to meet the needs of all airspace user groups or when dual use (the release of ordnance and unusual air activities) of segregated airspace is considered, it may be appropriate to consider deviation from the above criteria. Where this is necessary, [the CAA] will give careful consideration to a request for a policy dispensation, provided full details of the associated hazard mitigation to justify policy deviation are provided with the ACP. Should a possible need for such a policy deviation be identified during the airspace design phase, it is recommended occasional activities and/or a airspace sharing arrangements under approved MoU/LoA may also provide suitable mitigation. Therefore it is both necessary and essential that MOD and NATS work to establish operating arrangements to ensure compliance with CAA Safety Buffer Policy requirements, ideally through the identification of appropriate (and safe) mitigations that could include positive ATC management of potentially hazardous activities, dynamic ATM procedures, use of internal safety buffers for occasional activities, airspace sharing arrangements under approved MoU/LoA, any combination of these, or indeed any other agreed solutions. For example, this could be achieved by NATS ensuring that, by means of ATS surveillance in the affected airspace, that aircraft under their control remains clear of the range boundary and from aircraft operating within the range. Any such agreement should be conditional upon MOD providing a clear understanding to NATS of the actual take-up of EGD613A, and for MOD to ensure that robust booking, cancellation and promulgation procedures are applied to ensure the airspace is managed to minimise the impact of activation upon NATS operations. Similarly, MOD should provide NATS with clarity on the nature and conduct of operations undertaken within EGD613A. The CAA is willing to offer mediation/moderation in these deliberations if either party consider it necessary. 278. Addendum Consultation Defence Airspace Air From a military exercise perspective the effect on CQWI or any other likely The CAA welcomes the MOD’s pragmatic comment and agrees that any access 2.3.5e Traffic Management exercise, if any, has been considered and the impact is thought to be minimal as requirements associated with major exercises should be addressed through the Class E airspace could be accessed when aircraft were operating under exercise planning and airspace co-ordination processes. VFR. It would not be intended to routinely plan to manoeuvre within this airspace during an exercise, it would only be used by transit aircraft routing through. Should part of the airspace be required for a major exercise, this would be subject to normal booking requests.

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE 279. Addendum Consultation Defence Airspace Air The MOD would accept the requirement to be in radio contact or obtain a MOD’s position is welcomed by the CAA. 2.3.5g Traffic Management coordinated clearance should an aircraft’s transponder fail that needed to access the airspace. 280. Addendum Consultation Defence Airspace Air Regarding “VFR traffic being provided with Air Traffic Control Service to The MOD’s comments are noted. 2.4.1 Traffic Management communicating flights.”, the MOD would not expect that a VFR aircraft would Assessment of UK regulatory material has highlighted inconsistencies in the receive other than ‘Traffic Information as far as practicable’. The phrase within manner in which Class E service provision requirements are presented in the UK the UK AIP ENR 1.4 ATS Airspace Classification: “However, pilots are AIP. These are in the process of being corrected in order to provide the encouraged to contact ATC and comply with instructions.” cannot be relied upon necessary consistency. as there is no requirement for VFR aircraft to provide other than VFR separation IFR and VFR operations in the proposed replacement airspace are to be from all aircraft within Class E and the VFR aircraft pilot may not be able to addressed in detailed CONOPS; MOD has played a pivotal role in the comply with instructions that may require him to become IMC. development of these. 281. Addendum Consultation Defence Airspace Air An Air Traffic Control Service must be provided to IFR flights as this is the best Assessment of UK regulatory material has highlighted inconsistencies in the 2.4.2. Traffic Management way to ensure IFR aircraft are separated. However, this should not be manner in which Class E service provision requirements are presented in the UK mandated on VFR flights that may or may not be ‘communicating’. There is a AIP. These are in the process of being corrected in order to provide the phrase within the UK AIP ENR 1.4 ATS Airspace Classification: “However, pilots necessary consistency. are encouraged to contact ATC and comply with instructions.”, this cannot be IFR and VFR operations in the proposed replacement airspace address the replied upon as there is no requirement for VFR aircraft to provide other than issues raised in the MOD’s comment; MOD has played a pivotal role in the VFR separation from all aircraft within Class E and the VFR aircraft pilot may not development of these. be able to comply with instructions that may require him to become IMC. Traffic Information is the only part of an Air Traffic Service that should be provided but only ‘as far as practicable’. 282. Addendum Consultation Defence Airspace Air The MOD would not wish the provision of service to be limited to the designated The MOD’s comments and concerns are acknowledged and the CAA agrees 2.4.2. Traffic Management airspace operating authority (this is also the MOD’s position regarding all of the that operations within the proposed replacement airspace should be in other proposed Class E airways). There are provision of service issues that will accordance with ICAO and SERA requirements. need to be addressed associated with the proposed Class F airspace change to Assessment of UK regulatory material has highlighted inconsistencies in the Class E. These will impact on any final MOD position that cannot be made until manner in which Class E service provision requirements are presented in the UK the service provision requirements are known. The provision of a service to VFR AIP. These are in the process of being corrected in order to provide the aircraft needs to be in accordance with ICAO and SERA regulations; there must necessary consistency. be no requirement imposed to have to provide IFR separation to VFR aircraft IFR/VFR operations and service provision within the proposed replacement under an ATS within Class E. In addition, provision of service should not be airspace is addressed in detailed CONOPS; MOD has played a pivotal role in limited to the designated airspace controlling authority as the MOD requires the the development of these. ability for its autonomous and authorised units to be able to provide an ATS within Class E. If the MOD is unable to satisfactorily access the airspace using Class E rules as ICAO and SERA intended when a VFR aircraft is under a Service, then the MOD would be minded to object. 283. Addendum Consultation Aberdeen Airport We are grateful that the CAA has recognised the importance of the Consultative Aberdeen Airport Consultative Committee’s comment is noted. 2.6 Consultative Committee Committee in this discussion and thank them for inviting us to submit our observations. 284. Addendum Consultation Aberdeen International As defined within the briefing document there is a portion of overlap which when Aberdeen International Airport’s comment is noted. 3.2 Airport considering the criticality to Aberdeen International Airport of the fillets stipulated With regards to D613A, the CAA is confident that that MOD and NATS are in 2.3c it would be of significant advantage to our business for the reasons engaged in discussions tocan develop an acceptable agreement that will previously detailed within our original consultation response and follow up mutually satisfy local operational requirements, satisfy CAA safety buffer policy correspondence of 1st October 2013 to have the fillets permanently available requirements and accord with Flexible Use of Airspace principles. Such without infringement by the MOD. An alternative to this would be a mutually negotiations will serve to illustrate the frequency of the MOD’s actual use of the beneficial operating agreement which enabled NATS to maximise the overlapping airspace, and to afford both it and Aberdeen Airport the opportunity introduction of this specific fillet thus reducing the potential negative impact on to devise procedures to be applied to best accommodate Aberdeen and MOD Aberdeen International Airport. operations. The CAA is willing to offer mediation/moderation in these deliberations if either party consider it necessary. 285. Addendum Consultation Defence Airspace Air The proposed airspace infringes EGD613A from FL100 to FL195. The MOD has The CAA acknowledges that the Aberdeen fillet/EGD613A overlap is required to debated this issue and is unable to agree to relinquish the fillet of airspace comply with CAA Safety Buffer Policy requirements, or in accordance with Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B58 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE 3.2 Traffic Management involved, especially with the additional requirement for the 5NM buffer within the Flexible Use of Airspace principles. DA; in terms of the Buffer Policy, this should be applied outside of the DA, i.e. The CAA considers the MOD suggestion to be a pragmatic option and is training operations within the DA would continue as they do now with no impact. confident that an appropriate operating agreement can be reached between Improved capabilities of current aircraft together with new platforms shortly to be NATS and the MOD in order to maximum utilisation of the airspace by both in service require greater amounts of airspace, not less; therefore, no loss of parties. EGD613A can be accepted. However, under Flexible Use of Airspace principles, as long as the MOD retains primacy to this airspace, the MOD is prepared to allow Aberdeen to utilise the proposed airspace within EGD613A when the DA is not booked. When EGD613A is booked, Aberdeen traffic should remain clear with any safety buffer (vertical and/or horizontal) applied by Aberdeen and/or NATS outside of EGD613A. 286. Addendum Consultation Defence Airspace Air The proposed implementation date has been noted. Noted. 5.2.1 Traffic Management 287. Addendum Consultation Defence Airspace Air In parallel with the Class E proposals, all documents, procedures, charts, and MOD’s comment is noted by the CAA. It is assumed that some of the document 5.3.2. Traffic Management maps will require amendment. In addition, the training burden will be large. costs will be absorbed at least in part by current budgets. 288. Addendum Consultation Defence Airspace Air The promulgation of this change is important as Class E is a totally different MOD’s comment is noted by the CAA. 5.4 Traffic Management operation, using IFR/VFR, to what we are used to within the UK within Classes Appropriate CONOPS are being developed with MOD input and supporting pre- A-D and with ATSOCAS in Classes F and G. implementation awareness activity will be required in order to prepare for the necessary airspace change. 289. Addendum Consultation Cabro Aviation Ltd Cabro Aviation is based at Aberdeen Airport undertaking private pilot licence The CAA welcomes Cabro Aviation’s support for its proposals. General training and aircraft hire. Fully support this proposal to reclassify airspace. 290. Addendum Consultation Defence Airspace Air The ability to fly autonomous VFR through Class E without a clearance will limit The CAA acknowledges that the Aberdeen fillet/EGD613A overlap is required to General Traffic Management the impact on VFR operational training; although where today MOD aircraft can comply with CAA Safety Buffer Policy requirements, or in accordance with operate freely, the establishment of these Class E fillets to contain commercial Flexible Use of Airspace principles. air traffic will limit some of our operational freedom as we may be reduced to The CAA is confident that an appropriate operating agreement can be reached transits only. MOD aircraft frequently operate with a service from military ATC, between NATS and the MOD in order to maximum utilisation of the airspace by ASACS, E-3D and the RN; we would wish these Service providers to be able to both parties. treat VFR aircraft under their control as VFR and not have to apply IFR separation. During poor weather, MOD aircraft would accept an IFR service. The proposal impacts on EGD613A, the MOD is unable to agree to any reduction in the size of this Danger Area (DA). 291. Addendum Consultation Defence Airspace Air MOD Service Providers are not normally authorised to provide a service within The Aberdeen ‘fillets’ will be designated as parts of the replacement airways General Traffic Management CTRs or CTAs. Therefore, it is important to define the Class E fillets as en-route rather than additional Aberdeen CTAs. airspace to limit the impact of the change by allowing continued operations, or as There will be no change to the lateral and vertical limits of the current Aberdeen a minimum the airspace above the existing Aberdeen Zone with a top level of CTR/CTA, however that part of it which would overlap the replacement Class FL115 as a CTA and the Class E airspace above FL115-FL195 as en-route E+TMZ airways would remain Class D. Similar arrangements apply to parts of airspace. It is also essential to be able to provide a service in accordance with the Belfast TMA. ICAO and SERA Class E regulations with no requirement to mandate VFR Service provision issues are addressed in the draft CONOPS for the aircraft under a MOD service to fly as if IFR. If this is perceived to be a replacement airspace; MOD have been central in the development of these. requirement, then a different classification of airspace should be consulted on. 292. Addendum Consultation Defence Airspace Air There will be costs of amending all documentation, charts, maps, procedures The CAA acknowledges there will be costs associated with the changes to General Traffic Management and regulations. aeronautical information documents, charts and regulations highlighted by the MOD. It is assumed that the cost of amending aeronautical information publications and charts will be absorbed (at least to some extent) by extant aeronautical change budgets. 293. Addendum Consultation Defence Airspace Air The MOD supports the proposal subject to MOD primacy within EGD613 and The CAA acknowledges that the Aberdeen fillet/EGD613A overlap is required to General Traffic Management with no loss of airspace related to this DA, and ability to provide a service within comply with CAA Safety Buffer Policy requirements, or in accordance with the Class E using ICAO and SERA Class E rules. Flexible Use of Airspace principles. The CAA is confident that an appropriate operating agreement can be reached between NATS and the MOD in order to maximum utilisation of the airspace by

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE both parties. 294. Addendum Consultation Flybe Flybe foresees an increase in safety by the reclassification from Class F to Class The CAA welcomes Flybe’s comment. General E (TMZ) and hopes that, in time, more predictable fuel efficient routing AIA may in due course choose to develop and submit an airspace change in opportunities in and out of Aberdeen may become available. accordance with the CAA’s airspace change process should it identify a requirement for SIDs and STARs. 295. Addendum Consultation Gama Aviation Gama Aviation operates on average around 1,900 movements per year through The CAA welcomes Gama Aviation’s support for its proposals. General Aberdeen Airport, largely on behalf of the Scottish Ambulance Service utilising King Air 200 & Eurocopter EC135 aircraft. Having reviewed all three proposed options for change Gama Aviation is in agreement that Option 3 is the most appropriate way forward. We do not consider Option 1 as an appropriate course of action. Both Option 2 and 3 will have no operational or financial impact on our business. Gama Aviation supports this proposal in the interests of enhancing flight safety. 296. Addendum Consultation General Aviation Alliance The GA Alliance has considered the proposal for fillets of class E+ airspace to The CAA notes the GAA’s pragmatic comments and welcomes the GAA’s General be added at Aberdeen. Within the context of the overall Class F consultation we support for the Aberdeen ‘fillet’ proposals. understand the logic of the proposal and the need for a shorter than normal In addition, the CAA is of the view that, were the ADRs in the Aberdeen not to be consultation period. replaced by Class E+TMZ airways (i.e. were the ADRs disestablished and We also understand that the proposal is to create Class E+ airspace where the replaced by Class G), there would be no justification for the ‘fillets’. "+" requirement is either the use of a transponder or, if no transponder is fitted, a radio call to inform ATC of presence (not a clearance request). This is in accordance with the earlier Class F consultation. While the detail of this TMZ\RMZ aspect has been present in the respective consultation documents, it has not been easy to find in the detail of sub-paragraphs and a number of readers have mistakenly believed the proposal to be purely a TMZ. The difference is important to us and we therefore make the effort to highlight it here. Our principal Class F concerns were covered in our previous formal response and remain valid and critically important to us. We see this addendum as simply that, an addendum. If for example the CAA's decision on the main consultation were to not grant Class E+ status to existing Class F routes around Aberdeen there would be no case for the addendum and we would require it to also be denied. With the above comments in mind we support the addendum ACP. 297. Addendum Consultation Mark McDonald, MSP I note that the Airport Terminal Services at Aberdeen International Airport The purpose of the Addendum Consultation was to address the impacts upon General Aberdeen Donside operate in a number of airspace classes and I have been advised by officials at Aberdeen International Airport of reclassification as originally proposed. This the airport that the proposal to remove Class F airspace will impact considerably consultation has been completed and the CAA will now propose the on the airport and the city as a whole. As you will be aware, the airport is establishment of the ‘Aberdeen fillets’ as the means of obviating the feared primarily a business airport with over 3.5 million passengers having passed impacts. through over the past year. The CAA will be only too aware of the continuous national and international business expansion of the airport having confirmed it as ‘The Fastest Growing Airport in the UK” in 2012 for the second year running. However, it has been noted that without Class F airspace, the airport will be restricted to a narrow volume of airspace to funnel aircraft through which, the airport believes, would result in increased workload and complexity. Given that many fixed wing flights from Aberdeen International carry passengers to and from long haul flights, the demand for punctuality is pertinent to the airport’s operation, and I am aware that the current record for reliability and time- keeping is of extremely high standard. As you can appreciate, the demand for the smooth operational running of the airport is all year round with over 60% of passenger traffic being business orientated and the consistent traffic created as a result of the North Sea energy industry. Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B60 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE Aberdeen is in the unique position that there is also a high volume of helicopter traffic which needs to be factored into any potential changes to the class of airspace. The airport has informed that they would not wish for fixed wing flights nor helicopters to experience any delay or unnecessary holding as a consequence of any proposed measures by the CAA and concern has been raised with congestion of aircraft and lack of suitability for the efficient movement of aircraft should the proposals be implemented. It has been further noted that the increase in holding air traffic would result in the local environment being affected by increased CO2 emissions. Currently, the airport works hard to ensure that the aircraft operation to and from the airfield utilise the best and most efficient routing for the aircraft in order to satisfy the local community and fuel efficiencies for the airlines. Should the proposals go through, the airport foresees an increase in volume of aircraft holding which would, in turn, have a detrimental effect on the local environment. I have been advised that presently, such holds only see increased CO2 emissions during periods of adverse weather. Given the impact that these proposals would have upon the future growth of the airport and the economy of the city, I would be grateful if full consideration could be given to the points raised. 298. Addendum Consultation NATS NATS supports the purpose and intended aims of this consultation and believes The CAA welcomes both NATS’ support for the proposed Aberdeen fillets and its General its preferred option (option 3 as detailed in the addendum consultation paper) is undertaking to conduct operations within them to reflect current practice in Class the most appropriate design for this airspace given the wider proposal for the G. regularisation of this airspace from Class F to Class E+. The CAA is confident that an appropriate operating agreement can be reached NATS would like to re-iterate its commitment to working with CAA to ensure between NATS and the MOD in order to maximum utilisation of the airspace by “There are no plans to change where aircraft physically fly as a result of the both parties. It is, however, willing to offer mediation/moderation in these proposed regularisation” and recognises that this modification to the CAA's deliberations if either party consider it necessary. original design seeks to achieve this outcome. That said, NATS continues to The addendum consultation document was indeed in error when it stated that have a concern over the consequences of the application of the CAA’s buffer the part of airway P600 overlapping the revised Class E airspace will remain policy (para 3.2) in respect of the need to accommodate the current north Class D. Those parts of P600 above FL195 in the vicinity of Aberdeen will, of western geographical extremity of MDA613A, adjacent to the proposed southerly course, remain Class C up to FL245. fillets. This accommodation has the potential to severely limit existing GAT flight profiles in this area, to the extent that utilisation of the fillets would be marginal at best and result in a situation where efficient air traffic management of the operation would necessitate aircraft flying over areas where they do not fly today – a situation more representative of the original Class E proposals for the Aberdeen area and unfortunately contrary to the design objectives highlighted above. NATS is of course willing to engage with the MOD as appropriate but we wish the CAA to be aware of the potential consequences if a mutually acceptable airspace sharing process cannot be agreed and delivered. For information, NATS has outlined in detail and simulated these effects during consultation responses, engagement sessions and CAA workshops and is willing to share these impacts further on request. NATS would like to make clear its commitment to working across industry to secure an agreement that serves all users of this piece of airspace, and recognises the need to continue working with all stakeholders and airspace users to achieve an agreement that can support this Airspace Structure and ensure that the safety, effectiveness and efficiency for all users is sustained or enhanced through this change. Finally, it would be NATS preference that the part of airway P600 which overlaps the revised Class E airspace remains Class A and we assume that para 2.3.1 c quoting it as Class D was unintentional.

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# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE 299. Addendum Consultation Nestrans (North East of Nestrans understands that the CAA consultation is open to stakeholders and The CAA undertook public consultations regarding its proposals to replace Class General Scotland Transport) that the consultation is on the technical aspects of a change in operating rules. F airspace and to establish the Aberdeen ‘fillets’. Comments concerning the Aberdeen International Airport have however informed us that the CAA is open operational impacts of the changes upon Aberdeen International Airport and to receive consultation responses highlighting the impact that proposals could consequential economic impacts of not establishing the ‘fillets’ have been have on the wider economy of our region. We are therefore pleased to be able to presented by several stakeholders. These informed the CAA’s decision to pass on these comments to hopefully increase greater understanding of these propose the establishment of the ‘fillets’, which was of course the subject of the wider implications. Our response therefore doesn’t sit neatly with the form that addendum consultation. The continues to advocate establishment of the ‘fillets’. you have issued. We hope that this format will suffice. Compliance with ICAO requirements and EU law regarding airspace Nestrans understands the CAA’s desire to comply with the ICAO regulations and classifications and the Rules of the Air is essential. That said, the CAA as the European Law of Standardised European Rules of the Air. We are not sure Competent Authority seeks to afford the greatest possible degree of flexibility about the flexibility there may be in the implementation of these rules and permissible within the EU Implementing Rule. whether the CAA have had any discussions with these bodies on the extent that such flexibility may be available. Subsequent sections of this response, on the impact that the original proposals could have on the operation of Aberdeen International Airport and therefore on the economy of the north east of Scotland, would suggest that continuing current operational rules would have advantages for our airport and region. We believe that the option of flexibility being granted to keep the current rules of operation should be explored and understood. 300. Addendum Consultation Nestrans (North East of Nestrans would share a CAA view that all operations should be operated in a Nestran’s support for the CAA’s addendum proposals is welcomed. General Scotland Transport) safe manner. It is our understanding that the original proposals would place additional burdens on air traffic controllers controlling the airspace around Aberdeen International Airport. With the runway at Aberdeen International Airport being the 5th busiest runway in the UK during weekdays, due to the unique combined operation of fixed wing and helicopters, and the runway operating at capacity for several periods during the day it is our understanding that this additional burden would introduce concerns regarding additional risk, particularly at a time when the current climate in Aberdeen is sensitive to recent Health and Safety issues.. This situation would not be acceptable with the likelihood of reduced numbers of operations to bring back traffic movements to acceptable levels. Therefore if the current rules of operation cannot be maintained Nestrans would support the additional fillets proposed in the addendum consultation. The north east of Scotland has for over 40 years been in the fortunate position of supporting the development of the North Sea Oil industry. This has had enormous significance for the UK economy as well as boosting directly the economy of our region. The development of oil and gas fields along with the movement towards renewable energy has created many opportunities for companies across the north east of Scotland. Our region has been very creative in accepting the challenges of the North Sea and we have become the world experts in both sub sea engineering and supply chain logistics. This worldwide reputation has meant that the expertise developed in the north east of Scotland has spread across the UK and worldwide. In the north east of Scotland there are some 40,000 oil and gas related jobs with some 440,000 oil and gas jobs across the UK. A number of these jobs across the UK are dependent upon operations in the north east of Scotland where management control of operations leads to knock on contracts across the wider UK. Significantly too, the reach of the industry in the north east of Scotland has extended far beyond the North Sea region to all parts of the globe. The supply chain and logistics industry has a £16 Billion turnover of which just under a half is foreign contracts bringing both export income and jobs to the UK. The UK and Scottish Governments have both set ambitious targets for doubling this trade Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B62 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE over the next few years. This trade with worldwide destinations has had an impact on Aberdeen International Airport. • The runway is the 5th busiest in the UK, an astonishing figure for a catchment population of around half a million. • The runway operates at capacity for several periods during the day • 65% of travellers at Aberdeen International Airport are business travellers • Just under 25% of all Scotland to Heathrow traffic is via Aberdeen International Airport (for just under 10% of the population) • The airport has good connections to other European hub airports • Aberdeen International Airport is the best connected UK - UK airport • Over 40% of traffic to Heathrow is interlining to world destinations • The low cost carrier traffic at Aberdeen International Airport is very low • Despite some loss of helicopter traffic during the current difficulties for that industry the Airport overall has seen very strong growth in passenger numbers with figures now exceeding pre-recession peaks • The mix of aircraft types at Aberdeen International Airport is unique These statistics endorse the fact that Aberdeen International Airport is a very busy regional airport within a region with a very high propensity to fly. This is partly explained by the business traffic with its worldwide connections but also due to the geography of the UK with the distance between Aberdeen and London being significant enough to make air travel the only viable option particularly for business traffic. Even if High Speed Rail were to extend to Aberdeen, which will not happen due to distance and lesser passenger numbers, the journey times would still favour air travel as the most expedient method. The current levels of traffic are also predicted to significantly increase over the coming years with the Governments’ own Oil and Gas Strategies pointing towards this increase. Indeed the region is currently experiencing a significant post-recession construction boom with a high number of commercial developments under construction with an anticipated large number of new jobs being created. These developments are generally creating new office complexes for energy companies along with associated hotel etc. developments, not least of which is the three sizable developments currently under construction in the vicinity of the airport itself. Current planning applications and signed planning agreements also indicate a huge boost in housebuilding is about to commence. All this leads to the view that any change in operations at the airport which could limit the capacity of the airport could have very significant consequences not only for the north east of Scotland but also for jobs across the UK. Our discussions with Aberdeen International Airport have highlighted that the original proposals could have reduced the maximum air traffic movements at the airport from around 36 movements per hour to between 27 and 29 movements per hour. This could have a very significant impact on businesses in the north east of Scotland. Many of the businesses here could relocate quite easily to other parts of the world. With this there could be a significant job loss across the UK as contracts are lost to foreign companies. This comes about because many of the companies in our region are foreign owned, located here for a number of reasons and a number have started as local companies which have been bought over by foreign owners to capture their extensive knowledge base. One of the principal reasons for being located in the north east of Scotland is the Replacement of Class F Airspace in the UK FIRs – Consultation Report 17 April 2014 Page B63 of 64 Replacement of Class F Airspace in the UK FIRs – Consultation Report

# REFERENCE/SUBJECT NAME/ORGANISATION COMMENT RESPONSE relative ease of access to worldwide destination mainly via Heathrow but also through other European hubs. The frequency of flights to Heathrow in particular is important to our business community. Should a re-designation of airspace class as originally proposed affect this frequency of flights, or number of destinations reached or the ability to serve the North Sea then this would be unacceptable and have very significant knock on effects not only on our economy but across the whole UK. Therefore from an economic point of view if the current rules of operation cannot be maintained Nestrans would support the additional fillets proposed in the addendum consultation Nestrans hopes that this provides a non-technical background to concerns about proposals to amend the airspace category around the north east of Scotland that would impact adversely on flow rates at Aberdeen International Airport. Such proposals are of course important to the Airport and the air traffic control but this paper has tried to demonstrate that any decisions of this nature will have wider implications for our local economy and the UK economy in general. This is particularly so at an airport such as Aberdeen International Airport where the propensity to fly is high with this being a business led propensity. Disturbing the ability to fly has the potential to have great impact well beyond the aviation industry. Balancing the need to comply with European and World regulations with safety concerns and economic realities brings the view that if the current rules of operation cannot be maintained Nestrans would support the additional fillets proposed in the addendum consultation.

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Annex C Summary of CAA Final Proposals for the Replacement of Class F Airspace in the UK FIRs ROUTE PROPOSAL ROUTE NETWORK IMPACTS TERMINAL AIRSPACE IMPACTS Disestablish Glasgow LOMON SIDs A1D disestablish Cancel RONAR Cancel LOMON N160D disestablish N552D disestablish N553D disestablish Cancel TABIT

GOW-ERSON FL195/FL55 KOKAL-SUM disestablished ERSON-GUSSI FL195/FL105 Route redesignated N560 N560D GUSSI-INS-BONBY FL195/FL95 Requires deletion of N560D entry and incorporation of GOW-KOKAL element BONBY-WIK-KOKAL FL195/FL75 into current entry for N560 at AIP ENR 3.1 MAC-MIMKU disestablished Requires deletion of N562D entry and incorporation of TRN-MAC element into N562D TRN-MAC FL195-FL105 current entry for N562 at AIP ENR 3.1 Designated CDR2, available during notified military exercise periods. Activation by publication in the CRAM TIR-GOMUP disestablished GOW-BRUCE FL195/5500ft ALT Route redesignated N580 N580D BRUCE-TIR FL195/FL115 Requires deletion of N580D entry and incorporation of GOW-TIR element into current entry for N580 at AIP ENR 3.1 BUDON-KLONN disestablished Route redesignated P600 ADN-14nm NE ADN FL195/4500 ft Establish fillet with 4500 ft amsl base as Requires deletion of N600D entry and P600D 14nm NE ADN-24nm NE ADN FL195/FL75 shown at Enclosure 1 to connect with incorporation of ADN-BUDON element into Aberdeen CTA/CTR 24nm north-east of ADN to BUDON FL195/FL105 current entry for P600 at AIP ENR 3.1 Cancel NADIR

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ROUTE PROPOSAL ROUTE NETWORK IMPACTS TERMINAL AIRSPACE IMPACTS Delete references to W2D and FIWUD at W2D disestablish Cancel FIWUD, MORBY, VANIN AIP EGNM AD2.22.

ADN-17nm N ADN, FL195/4500 ft Establish fillet with 4500 ft amsl base as W4D Route redesignation TBC shown at Enclosure 1 to connect with 17nm N ADN-WIK, FL155/FL75 Aberdeen CTA/CTR ADN-14nm N ADN FL195/4500 ft 14nm N ADN-3nm N PETOX FL195/FL75 Establish fillet with 4500 ft amsl base as W5D 3nm N PETOX- 33nm S SUM FL195/FL105 Route redesignation TBC shown at Enclosure 1 to connect with 33nm S SUM-23nm S SUM FL195/FL75 Aberdeen CTA/CTR 23nm N SUM- SUM FL195/4500 ft INS-ULLAP FL195/FL95 W6D Route redesignation TBC ULLAP-STN FL195/5500 ft IOM-DCS disestablished W911D BOYNE-IOM FL195/FL75 Route redesignation TBC Isle of Man arrivals and departures (note W928D disestablish Cancel MIKEL neither SIDs nor STARs established) BEN-37.8nm N BRUCE disestablished BRUCE-TRN disestablished W958D 37.8nm N BRUCE-BRUCE FL195/FL115 Route redesignation TBC Cancel FULMA, TABIT Establish new 5LNC at 38nm N BRUCE

Replacement of Class F Airspace in the UK FIRs - Consultation Report 17 April 2014 Page C2 of 2 00900W 00800W 00700W 00600W 00500W 00400W 00300W 00200W 00100W 00000 00100E ALLOY 00200E 00300E 00400E 00500E 00600E

6100N

VALDI

6100N FAKSO

SORUD 01100W 01000W MATIK

OLKER

GONUT GUNPA SCOTTISH FIR LIRKI

BESGA DEVBI FL115 - FL195

BARKU

DIRGI FL105 - FL195

NASET MODGO

GIRNU FL95 - FL195

6000N

A1D FL75-FL185 6000N ATSIX FL75 - FL195

DOSUN AKIVO BILLY

KESEG 5500’ - FL195 NESTA VAMLA PEPIN

BODAM

IZACK

SUMBURGH 4500’ - FL195 CTR SFC-FL100 SILOK BENTY

RAPIR

ORVIK

CTA 1500-FL100

MOCHA TIRIK

KISTA

BAMRA

N560D GAVEL TYSTI FL40-FL190 5900N TOBUR

FL75-FL185A1D

SAPOT BALIX 5900N

BEREP NINEX §D809(N) 55000 SFC

SOXON KOKAL D712B §D801 FL660 55000 FL245 SFC BEKET

SODKI AREA 2 FL290

W5D §D809(C) (OCNL FL350) POTRA  FL70-FL190 INPET § D712C 55000 FL100 D802 MADOX SFC 55000 FL660 SFC FL245 §D803 D712B 40000 FL660 SFC FL245 D712A §D809(C)  P813 N560D 55000 FL660 3000-FL190  2100 SFC FL245 SFC D712D FL660 FL245

§D701B (MNM  FL35-FL185 UNL D712B W4D SFC FL660  AL SUGAR FL245 D712C T R610A FL660 3500) 5800N 5000 FL245 SFC R610C WIK10 R610A 2000 5000 SFC § SFC D809(S) ERAKA 55000 R610A SFC PEPOV 5800N 4000) 5000 N560D T AL D712D SFC FL50-FL190 FL660 (MNM PIPEM FL245

FL55-FL185 ETSOM W4D

MORAY

CHINN ‡§D703 FORTY 15000 AREA 4 ULLAP (OCNL 22000) FL240 P600D SFC (OCNL FL350) FL90-FL190 FL55-FL185W6D BONBY ‡§D701C (MNM D712D FL70 10000  § AL FL660 D701D (OCNL 15000) T 5200) FL245  (MNM UNL SFC FL55-FL185N560D NADIR SFC

§D701A R610A AL

UNL 5000 T SMOKI SFC R610B SFC R610DR610D 5000) 5000 22000000 750 SSFCFC GARVA BUDON

§ (MNM D701E FL35-FL185 10000 W4D

SFC AL

T AREA 1 3500) RONAR FL280 §D702 FL180 2100 PETOX §D710 SFC SPIKE 3500) 1500 W5D T TROUT SFC AL FL40-FL190

VADNO (MNM §D701 UNL SUPIT DENOG SFC CTA 1 RUGID 1500-FL115

DAVOT

5700N SHRUB D613A  (MNM FL660 GOMUP FL65-FL185 NOBAL FL100 A1D ABERDEEN GUSSI BALIS AREA 3 AL CTR 5700N SFC-FL115 FL290 T 6000) (OCNL FL350) GORSE FL100

FL1 GINGA (See Note 19) NESDI P18 P600 LAVTI 15-FL195 15-FL195

FL1 ORSUM AREA 14 FL240 DOWNI FL80 CTA 3 3000-FL115 ODMIX

CTA 2 N580D ADN26 FL55-FL195P600 1500-FL115 FL55-FL185 15 (MNM AL EG079 T 4700) LAGAV GLESK ULANU FL75-FL185W958D P18 P18 P18 4500-FL1 GIBSU 4500-FL115 4500-FL195 D613B  P600 (See Note 19) FL660 ELSAN EKSIT PELUX EG078 FL100 INRUT FL85-FL195 P18 (See Note 19) FL75-FL195

5800) FL75-FL115 P18 T EG080 IBROD AL 4500’- FL195 P18 N560D ABLUS EN109 VAXIT FL60-FL190 FL75-FL115 NEVIS RANOK

(MNM ANGUSFL75 - FL195 OMIRI FL105 - FL195 EG077 EPEKO (See Note 19)FL1 P600 P18

15-FL195 FL105-FL195 R612 6000 VALIX SFC

BALID OTRAL ERSON NAMON

N864 ‡§ RIVOT FL105-FL195 (See Note 3) D604 1500 (See Note 19)FL135-FL195 P600 (OCNL 9000) P18 EG082 D613C VALAL FL85-FL195 FINDO SFC FL660 FL100

DANOR

P600 PTH11 5600N BRUCE FL55-FL195 REKNA (MNM ALT 5000) MIMKU N864

PTH15 FL85-FL195 N580D (See Note 3) OSBAR FL55-FL185 (MNM NEXUS 5600N SCOTTISH GRICE EG081 AL TMA 6 TIBKO VAGAX T 4700) N864 ITSUX FOYLE 4000-6000 FL65-FL195 PEMAD D601 STIRA 4000 (See Note 3) PIPAR P611 SFC SCOTTISH FYNER LOMON TMA 3 R603 2200 EDINBURGH SFC 6000-FL195 EDINBURGH 2000 CTA 3 SFC CTA 2 3500-6000 2500-6000 SURAT N562D FL1 FL75-FL185W958D 15-FL185 SCOTTISH GILPA CLYDE ELBAN TMA 3 R516 CUMBO 6000-FL195 EDINBURGH 2100 CUTEL XEXUS CTR 4700) SFC ASKEK T ROBBO GLASGOW SFC-6000 SCOTTISH GOMOT AREA 5 GEGDA AL CTA 1 MADAD FL240 N553D TMA 3 FL155-FL195 OKTIR SCOTTISH (See Note 19) VESUV FL60-FL190 3000-6000 6000-FL195 (OCNL FL350) TMA 3 P18 EDINBURGH FL70 (MNM 6000-FL195 MAVIX LAMMA DONIB GLASGOW CTA 1R504 TABIT XETUN 2500-6000 TMR515A 5 CTR 2800 3000- SFC-6000 SFC 20006000 SFC §D513 (MNM EDINBURGH FL45-FL185W958D 10000 ROLVA KUGUR SCOTTISH CTA 4 GOMLA 3500-6000 SFC BEVAM SCOTTISH GLASGOW TMA 3 AL FENIK CTA 2 6000-FL195 LIBBA T TARTN 4400) 3500-6000 LANAK 3500-FL195 RITSI TMA TWEED 5 SCOTTISH EK002 4700) N562D T TMA 1 EK003 MAC30 § AVRAL BELUV FL55-FL185 N553D AL NORBO 4500-FL195 D513B BELAP (MNM 4 NAVEL FL60-FL190 1 23000 SUSIS AL A T 5000) SFC (MNM CT TMA 1500-5500 §D513 10000 FULMA SFC PRESTWICK 5500-FL195 CT 31MCT BEL56 2000-5500 CTR ADIKU BEL76 A 2 SFC-5500 SCOTTISH N552D SCOTTISH GIVEM INPUT TMA 2 FL115-FL185 HAVEN ROBEM CT 5500-FL195 A ALASO MAC29 3 3000- 4 RUBEX N552D CTA 5 A L602 FL55-FL185 N552D/N562D 3500-5500 5500 FL115-FL195 ALT 5000) CT (MNM FL45-FL185 HERON 3000-5500 6 TLA08 ‡ (MNM A D505 TLA09 TLA24

EGEI1 AL F ‡§ T 4400) CT SUMIN ENOKA D512 EGEI2 GILAN 2000 L

4000-5500 N

(OCNL 6500) 8 18000

6

5 0 CDR 2 - (OCNL 25000) SFC F ESKDO 1 L SFC ERLOT

1 L602 5500N SCOTTISH FL155-FL195 § ROPAL 9 OTBUN D412 ON P18 NIBOG EGEI4 C TMA 2 5 10000

3 03MCT 5500-FL195 FL155-FL195 A ‡†§ (See Note 19) § SFC EGLINT MAC57 D510A D513A CT GIRVA 5500 23000 3000-FL75 COLRE  (OCNL 15000) § D512A SFC 5500N 22000 DIGBI BEL44 SFC §D513 AREA 7 § FL165-FL195 ‡†§D510 SFC ON D509 NGY03 (See Note 12) 10000 FL290 N601 EGLINT C  TUNSO 5500 1500-FL105 BENUX A 1 55000 ‡§† †D508 CT FL100 CT D402B P600 TLA24 (OCNLN601 18000) SFC SFC 4100 A AGASO 1500-FL75 3000 FL165-FL195 EG076 (OCNL 23000)FL125-FL195 (SeeSFC Note 14) SFC P18 2 BEL90 FL85-FL195N615 FL75-FL125 SFC ASKAM EGLINTON DCS20 R501 CTA 2 C 2400 NEWCASTLENATEB DIMLI CTR TADEX 2000-FL75 SFC 1500-FL105 SCOTTISH FIR LARGA §†D402C BAGPO CT SFC-FL105 DUNGV 4000 A NIGOL 1 LONDON FIR SFC 3000-FL105 D323A LUNEX ‡§†D402A DCS19 3  EGEI5 §†D403 A FL660 BEL50 3000 CTA 4 BLACA  CT FL50 §D412 STRANGFORD (OCNL 23000) 35000 3000-FL105 RAPUM CTA 3 D SFC D323B 10000 FL105-FL195 SFC AREA 6 §D412  SFC RODSI BELFAST FL290 FL660 ELBOB FL95-FL195N615 CTA 5 10000  TMA 1 FL125-FL195 FL100 FL50 MOLAK (See Note 15) 3000-FL55 SFC 2000-FL105 CT MAGEE §†D403A 1500-2000 P18 A 2 D 3000 D323F FL55-FL125 MAC88 5000) FL135-FL195 TIPTA FL660 BELFAST TSFC N615 CTR 3500-FL105 FL55-FL195 §†D403 R432 FL250 P6 AL D323A PELET EGEI3 35000 2200 TIPAN SFC-FL105 FL55-FL195 2 E 3500-FL105 FL660 (MNM SFC CTA 6 SFC P600(MNM D FL55-FL195 FL125-FL195FL95-FL195 REVNU AL (See Note 13) FL50 (See NoteT 5500)22) TMA N601 4500-FL55 GIGUL ST FL95-FL195 MARGO GIRLI AKOXA AST ‡D407 CTA 3 ‡†D405 3000-6000 4500-FL195L10 10000 CTA 7 R446 (See Note 22) 15000 BELF (OCNL 13500) 6000-FL75 2000 AST/CITY P620 (OCNL 50000) GOTNA SFC SFC BESBU STRANGFORD FL55-FL185 EGEI6 R431 BEL10 CTR W928D SFC NIPIT NEW26 BELF 3 CTA 2 2000 SFC-2000 A †D405A SFC 3500-FL195 LISBO CT 1000 FL125-FL195 P18 DUFFY 2000-3500 STRANGFORD CT SFC DURHAM TEES CT BINTI FL75-FL125 DURHAMDURHARHAHAAM TEETEESEES 1500-2000 P18 TILNI VALLEY A 1 VALLEY GOLVO BALNA FL55-FL195 NELBO ARSAT CTR FL75-FL195 CTRC R2 2 D SFC-6000 FL95-FL195 SFC-60SFC 60000000000 FAMBO EG048 FL125-FL195N57 SHAPP APPLE RIKUD (See Note 9) D323D N34 FL75-FL195L603 L15 FL75- ‡§ FL660 EISG FL195 L10 FL75-FL195P6 D D408 RINGA A FL250 1 D 3000 1D P18 FL55-FL195 (See Note 22) R413 VENAS FL45-FL195 4700) (OCNL 5600) FL75-FL195 W91 T 2000 DEVIG ROLUM 4 UVAVU FL105-FL125

AL ( FL155-FL195 SFC ERNAN A FL50-FL190 SFC S CTA 1 D323B

AREA 13 e N864 SUBUK 1200-6000  ADOMI (MNM e FL660

P600 FL240 §D409 ABSUN N CTA 2 FL50 FL135-FL195FL135-FL19P6 D FL150 o 34001500-6000 D323E ‡§ t D406 e NESON EG177 SFC  STRANGFORD FL660 PEPOD 50000 1

SCOTTISH FIR 7 CTA 3 MIKEL FL250 SOTUN (OCNL 80000) ) D442 DEGOS FL105-FL195 SFC 3000 NEPSO 5400N STRANGFORD CT  L10 SFC BOGTI FL75-FL195 D401 FL135-FL195P6 A §D406C SLYDA LAKEY BAMLI 3200 (See FL45-FL195Note 6) IOM10  2 D 50000 DCS37 GASKO SFC A FL75-FL195 SFC N34 P18 NUMPI CT N57 P16 5400N DEVOL 2500-FL65 MASOP FL75-FL195 FL125-FL195 OBOXA STRANGFORD CT FL125-FL195 BIBIS P600 R445 FL125-FL195 POL27 BEGAM TINDI NEVRI EG176 2000 (See Note 9) ABKAT D323C ENULA FL75-FL195 ROMPA A 1 SFC FL125-FL195  DEXOR P620 ‡§D406B FL660 EIKN N615 P17 Y250 SUROX ROTEV  FL50 FL95-FL195 50000 FL145-FL195 EG003 EG018 ISLE OF MAN (OCNL 80000) EG014FL125-FL195 N601/P17/P18 CTR FL45-FL195L10 A SFC MAVET R444 N57 D410 DODIG SFC-FL65 FL95-FL195 TENDO ASGOS (See Note 6) 200000 FL75-FL195 1000 UMBEL NIMAT FL145-FL195L15 SFC SETEL RIBEL SFC VANIN DCS46 EG178 LONAM 1D REMSI N615 R315 ASKUP CTA 3 W91 FL95-FL195 3000-FL85 2000 CTA 1 D GETNO TUNUP SFC OTR80 FL50-FL190 KELLY MORBY N57 3 EKDAR 1500-FL65 A W2D FL55-FL195 ROVNI FL55-FL185 DCS53 P18/Y250/Y70 OLAPO CT (MNM BELOX FL85-FL195 DESUL 2500-FL65 AL FL145-FL195L15 4 T 4000) FIWUD EG001 A N615 NELSA LEEDS BRADFORD CT CASEL TUPEM FL65-FL195 CTR DWW04 DWN29 3500-FL65 SFC-FL85 BAGOV CT BOYNE N57 2500-FL85 POL05 A EG159 ULTAG RONON 4500-FL195 2 (See Note 17) FL155-FL195 R312 ARTHA RINUS CALDA ROKAN EBAGO L70 C FL75-FL195L10 N864 2100 DINIL ERUDA FL115-FL245 L70 SFC CTA 4 ORVEN ADSIS BILVO HALIF 1 BAGSO FL145-FL195 BURNI A 2000-FL65 LARDI INKUR DWN27 UMDAR ROKNA L70 C CT RIMTO BAPDA GIMRO FL75-FL245 EG004 P18/Y250/Y70 GIRAS FL85-FL195 R321 2500-FL85 DIMOX KERAV RAMOX Y70 1600 FL125-FL195 CTA 5 SOPAX ESTRY MANCHESTERDALEYROSUN CTA 3 DW706 SFC L975 2000-FL85 MITSO IRDUK DWN28 TMA 1 3000-FL85 BATLI DWW06 BABRA L70 C MANCHESTER FL85-FL195Y70 CT FL65-FL195 CROFT 4500-FL55 CTA 1 GIROSMC9 KOGAX PENIL FL85-FL195 TMA 2 3500-FL195 4000-FL65 LAGER L975 CT L70 WAL21 FL45-FL195L10 A (See Note 5) FL55-FL145 A GOLES 1500-FL85 FL55-FL195 10 UGNOR L70 C TENSO POL10 EG066A DWN26 WT001 FL115-FL195 L70 TADAL FL145-FL195 (MNM ALT 5000) UPTON 8 FL75-FL195 KOLID Y70 NORTH SEA BATED DW705 (See Note 5) MAN WAL64 DONCASTER FL105-FL195 NITIL EG044 POL11 SHEFFIELD CTA 2 KUDOM CTA 3 L975 LIBSO KORAK KISHA MIRSI WAL48 ‡§D307 FL175-FL195 RISAP LIFFY LIVERPOOL 3000-3500DESIG 3500-FL195 CTR 1 EG030 TOPPA DENBY BINBO THR16 2500-3500 SFC-FL85 20000 ROXAT NARMU DUB41 CTA 1 A 1 MANCHESTER Y70 NALAX DISRA THR10THR28THR34 3500-FL195L10 MAN CT SONEX FL125-FL195 (OCNL 23000) DWW02 GINIS EG068 RUGER 1500-3500 CTA 5 DWE51DWE54 NATKO ASNIP R319 CTA 9 DWW01GOSEL FAP28 2000-3500XOBRO EG015 EG032 SFC LAPMODWE52 LYNAS XUMATBARTN BOLBI EG070 1700 4000-FL85 DONCASTER DW814DW704 L975 C ROLEX WAL26 LIVERPOOLTIPOD SFC ADELUCTA 7 SHEFFIELD FL115-FL245 L975 EG072 DWS77 MALUDEG160 CTA 2 2000-FL105 MAMUL CTR 2 FL155-FL195Y70 AREA 8 DONEB DWS79 DWE55 SOPEP FL145-FL195 BAROS MANCHESTER L26/L603 EG008 VEGUS NASRI EG0742000-3500 MANCHESTER EG013 FL170 IBALO L975 CTA 4 FL85-FL195 SFC-FL105ARTIX INDEV TEDVO C L975 TMA 1 KINDR DOPEK FL70 GOLOR DWS81 DUNLO FL115-FL195 L975 LIVERPOOL 2500-3500 GIVPO 3500-FL195 LEGRO GODOS OTNER L975 FL75-FL195 L975 CTA 3 DAVENTRY EG010 DW815 FL45-FL195 3500- DA EVSON 2500-3500 LIVERPOOL MANCHESTER CTA 11 CTA 2 AKOKO MOMIN AGINI DWS80 SUGAD FL35-FL245 FL195 CT DEXEN CTR CTR VENTR FL85-FL195 A 6 1500-FL105 AMDIL (MNM R313 PELIG DWS78 2000-FL105 LAMIX TOPDA SFC-2500 SFC-3500 FL65-FL195 CTA 11 ELKAM 5 9500 OTBED KUSON IPVIS 9 FL60-FL85 INTOP DISAL L26/L603 EMLON DW816 Y124 C FL145-FL195L15 1 SFC L26

Y L FL105-FL195 R311 1 AL CTA 12 FL1 TABLY CT 8 FL155-FL195 15-FL245 F N601 IRDEX Y124 C A AMLET OKAMA 6 5300N TULSO C - ERABI 2200 T FL105- FL60-FL105 SUPEL KEROR (See Note 25) 8 KEPOR SIVNA FL145-FL245 LOVEL 5 5500) † A FL195 ROGAG § 8 LUSAT D201B CTD314 ENOKU SFC DAYNE RODOL M KOPADTOLSA KEKUL (See Note 25) 10 L DAVENTRY RIKUL ARVOK  Y UNL F MANCHESTER 2900 CTA 12 CTA 3 MIMVA GURGA SFC N864 SFC NAPEX L603 Y70 L989 SORIN †D201D KEGUN Y FL105-FL195 2000-FL60 AMVEL RUBAR TMA 1 FL155-FL195 FL175-FL195 SOPEK KONEP KOLAV ERVAD  3000-FL195 FL175-FL195 5300N UNL DWE53 DOGIT 3500-FL195 §4500-FL195D304EG179 GERVO VENTR EAST MIDS OSGAR DW682 N864 TIPIL GORTO FL55 MANCHESTER 3500 2 CTA 20 KOLAG FL55-FL245 FL55-FL105 DA A CTA 22 TOBRI L18 LISTO VENTR SUPUR †D201B (See Note 8) TORGO WAL16 CTANANTI 2 SANBA SFC FL75-FL105 (See Note 18) CT FL75-FL85 DA BODSO TORLU UNL LIPGO C NORTH WALES 2500-3500 EAST MIDS POL38 5500-FL195 AMGOD (NORTH) MTA WHI06 Y CTA 19 D305 OGONO DIGAN DIRUM SFC CTA 21 5500-FL105 1500 SONOL LOW HIGH NOKIN 5500-FL85TUMTI BEKMO ULSIT REXAM WAL32 POL42 SFC UNBEG FL285 FL660 DAVENTRY 3 DIPSO LERGO N864 VENTAR EAST MIDS NORTH SEA GULTU DERAG IRKUM FL195 FL285 4500-FL195 CTA 7 VEGAR RAMID KUBAX TOMTO RISLA 4500-FL195NUGRA DA CT CTA 7 L17 CTA 3 RAVLO NEPOD ROKUP FL175-FL195 NEPOG 5500-FL195 4000-FL105 BETAX DOLAS FL175-FL195 LASEX EAST MIDS ODPIX ROSRO FL85-FL245L18 WAL25 CTA 8 (See Note 8) EG075 WAL41 ESATA 4000-5500 EASTROBIN MIDS C R218 N864 CTA 1 GILOG D211 EAST MIDS DISUR 2700 FL65-FL195 2500-FL105 SUTEX 2400 CTA 10 EAST MIDS MOLIX SFC (MNM ALT 5500) BERGI THR24 SFC 3000-5500 CTA 6 § LUVOR †D201C N42/N862 D207 MONIL THR06 MONTY KARNO DA DAVENTRY 2500-5500 MEBOT UNL FL95-FL195 23000 ENITODIBAL TERDU GATLO ADMUP VENTR CTA 8 BEVES SFC FL145 N864 5500-FL195STAFA EAST EAST MIDS FL85-FL195 EAST MIDS BUKUT NEKAS NUPVO FL85-FL195 MIDS CTR 1 CTA 14 LAMSO Y CTA 5 FL65-FL105 OLONO ABLIN FL145-FL245 CT CREWE CTR 2 SFC-FL105 CTA 2 ASGON L18 BCN65 EG185 KEPAD WAL57 1500- MORAG (See Note 8) EG187 SKINA SFC-5500 1500-FL105 LUTEX LUPOR ADARU A 5500 EAST ANGLIAN C 20 ELPOM N864 LONLO CTA 12 MTA AREA B PETIK FL105-FL195 N42/N862 3500-4500 FL550 NORWICH EVELI TIPUR FL125-FL195 PEDIG MIDS LESTA NORWICH EG043 CTA 11 EAST MIDS EAST FL245 CTA 1 NORWICH A 3 CTA 1 OKTEM EG184 DAVENTRY 3000-4500 CTA 4 CT 1500-FL50 CTREGSH BUNED EG186 1500-FL50 PEPEL ROBVI CTA 19 CTA 13 2500-5500 ELVOS 2500-FL105 EAST ANGLIAN SFC-FL50 BADSI FL145-FL195 RERKA BERUL 2500-4500 EAST MIDS MTA AREA A NORTH WALES SUGOL TELBA CTA 15 §D215 FL550 B’HAMA 3 DAVENTRY EAST MIDS MC2 (SOUTH) MTA 4500-FL105 NUTBA 2400 ‡§D208 AREA 9 NAVPI ABAGU CT CTA 9 CTA 9 FL245 RENVU LOW HIGH EG042 B’HAM CT FL145-FL195 SFC 2500 FL50 3500-4500 4500-FL195 4500-5500 (See NoteN601 21) BUNON B’HAM CHASE PIPIN (OCNL 7500) LEDBO BEPAN VATRY FL285 FL660 MIDS EAST MIDS R212 2000 CTA 9 B’HAM 1 NORWICH NORWICH †D201 FL195 FL285 FL65-FL85 A EAST 17 CTA 16 2000 SFC CT DA CTA UPDUK CTA 3 CTA 2 UNL N42 FL75- SFC BARMI SULUT LUNIG NITON 1500-4500 A VENTRY CT TIMPO 2500-FL50 2500-FL50 SFC FL145-FL195 B’HAM 8 5500-FL105 FL105 ABIDO CTA 6 SAPCO5500-FL195 2000-4500 CTA 18 3500-FL145 CEDAR RETSI FL65- MAVAS TULIP FL105PIGOT AKUPA INRAD BIRMINGHAM A EG170 EG168 VOLLA B’HAM CT CTR 3 VENUX PESIT LANON N864 SFC-4500 LONDON FIR FL145-FL195 FL145-FL195 EG195 NIREX KURUM M17 VIDOK VELAG A OLIVE DAVENTRY FL1 GROVE (See NoteN601 21) SOMVA †D202A 5 MAPLE CTA 12 CLACTON BANEM ABEDA †D201A B’HAM 15-FL155 UMBAG N862 FL105-FL195 CTA 1 BANTO SIVDA EG172 EH610 UNL FL100 CTA 7 2500-FL145 EBOTO FL145-FL195 FL155-FL195 SFC FL60 FL65-FL145EBONY DITOB CKN27 CKN28 †D202B CLACTON DIMUS B’HAM 2 DAVENTRY MOGLI CTA 4 FL225 A EG166 BAKUR CT ROGBICTA 9 FL165-FL195 TISMO †§D201E REGNA FL100 4500-FL195 EG169 R217  1500-4500 EG173 FL125 PEPUL 2000 5200N GIVOL B’HAM 4 DAVENTWELIN RY CLACTON CKW26 FL145-FL195N546 SFC A CT CTA 13 CTA 2 SFC (OCNL UNL) BEDFO DENAG BARNU SLANY FL75-FL195 FL105-FL195 EH605 SFC 3500-4500TOBID CLACTON VALKO †D202B §D213 REDFA TIRUK DAVENTRY CTA 6 PEMOB FL225 2400 LTMA 18 SONOG 5200N FL145-FL195L9 DAVENTRY CTA 17 LTMA 9 FL135-FL195 FL100 †D202C SFC §D206 FL75-FL195 LAPRA ROVALFAF17 CTA 18 FL65-FL195 A 4 DTY03 5500-FL195 KEMPY EG167  HON13 6000 BIGLI SONDO EG171 ABAPO FL225 ‡D203 BCN25 5500-FL195 OLNEY BPK26 ADNAM CLACTON NEGEL 1 SFC FL100 23000 AMRAL R204 VENTRY CT DAVENTRY HEIDI LTMA 19 CTA 3 EG174 DA 5500-FL195 5500-FL195 BUSTA LTMA 16 OBILO OMASA EH164EH156 ††§ D202 SFC DAVENTR2200Y DISIT HON16 CTA 5 FL85-FL195 SOMEL 2 D216 POTON 5500-FL195 TEDSA FL125 18000 2300 CTA 19 SFC DAVENTRY L10 FL65-FL195 LAM37 ST 17 GINGI FL145-FL195 MID73 LTMA 6 ANSTED RIVER RINGI SFC SFCN864 (OCNL 10000) MOVEN CTA 16 FL55-FL195 BPK21LUTON CT EG192 3 HON19 DTY15 4500-FL195 1500-3500 TMA RATLO (OCNFL125-FL195L 50000 ) FL75-FL195 STOAT A ABBOT L CKW01 SFC PIXUP CTA 7 1 TABIS CASEY FL75- CLACTON GORLO THR17 NEXAT BANBA STU39 WOBUN LORELASKEY FL195 VAPAL SFC 3500-4500 STANSTED ADMIS CTA 5 THR35 EPERO PEVAD EH254 EH251 CLIPYFINMA BOMBO CTA 4 LTMA 3 FL85-FL195 L9 †D202A 2500-3500 3500-FL195 RINIS LANROUPLOMUPLON L175 FL145-FL195 D147 R214LUTON LUT LTMA 19 GOTEM FL100 TALGA CT LAM27 LUTON FL145-FL195 MEDOG SOPIT CTA 8 5500-FL195 4500-FL195 IDESI RILES 10000 LTMA 19 2400 A ON BUZAD L ARTOV FL60 3500-5500 6 LUTON CTA 1 TMA N864 SFC 5500-FL195 SFC 4500- 5500 CTA 5 2500-3500 STANSTED WD7 MASOS FL95-FL195TOPRO DAVENTRY KOMAG BANON L9 DAVENTRY CTA 9 3500-5500 CTR 3 7 CKW02 CTA 15 § LTMA 3 A REFSO ELTIG FL125- BCN10 MOSUN CTAD129 14 4500-5500 SFC-3500 ‡ GOSDAFAF35 FL105-FL195 3500-FL195 D139 CKE76 FL195 L9 N862 BAMBO NEDEXFL85-FL195FL120 DELBO LUTON WHSD EVRIN FL95-FL195 N864 DOBEM CTR 1500 LINRA EG190 AMMAN FL105-FL195 SFC CTA 3 DAGGA XAMAN ROBVO SILVA (OCNL 2000) FL75-FL195 2500-5500 SFC-3500 BRAIN BCN23 L9 N14 XIGAR 2000-3500 SFC COA76 CRK92 FL75-FL195 FL155-FL195 ANSTED CTLTMA 2 LILNO ATLAM BCN05 BEKSA CTA 4 HEMEL ST ST HON48 ANSTED 2500-FL195 LOGAN BCN15 3500-5500 CT TOTRI MATCH LTMA 8 A§ D138B INSAL DIKAS OSGOD CTA 2 1500-2500A JACKO § BRIZE 2 ROWAN 5500-FL195 RIMBU NEKAP §D115A D118 KIDLI 2500-3500 5000 CLACTON DIBRU 23000 UNBIG DILAXNORTON TRIPO SFC CTA 7 23000 FL125-FL195N14 CTR SABER SFC N864 LTMA 3 BOVVA LTMA 1 BAPAG FL65-FL195 VERE (OCNL 27000) L9 EVSEM MANGOR156 NORLA §D117 5500-FL195 SFC-3500 3500-FL195RODNI 2500-FL195 ODROB ERTER R154 4500-FL195L BRASO TINRA LND92 PERUP INGUR FL75-FL195 EG183 DAVENTRY FRANK SUMUM COLP SFC KUKIS TMA DONNA 2000 23000 ERNOK 2000 RISIN CTA 6 WESUL ‡§ IPRIL EVNAS SFC D138A TOLENMDYK CKS01 (OCNL 27000) SFC FL65-FL195 WATFO RIDLY 5 6000 EG193 R155 TAWNY SFC ALVIN N14 (MNM ALT 6500) BEREK R157 FERIT FERASSIRGO MAYLA §D113A ABDUK 2000 FL105-FL195 P106DIGUT TERKO (OCNL 60000) EG188 CARDIFF CTA 8 BADIM R105 EG182 1400 CITY CTA TOBIX ERING CRK80 15200 SFC 2500 SFC GILTI SASKI 5500-FL75 WOTAN 2000 L9 LTMA 10 SFC 1500-2500 GILDANILON (OCNL 40000) NUMPO SFC COWLY LTMA 3 SOVIX MOPAT EG191 §D113B SFC FL65-FL195 5500-FL195 SPEAR ‡§D138CLACTON SFC ‡§ BEMIDGINTIGAMDO 3500-FL195 CTA 8EG175 ALINA 15200 D115B Y3 MALBY 13000 DUB21 SWANY CARDIFF CTA 6 BENSU §D136 KOPULFL85-FL195 (OCNL 45000) 40000 FL105-FL195 D145 SIREN FINCH R158 (OCNL 60000) EG189  CARDIFF CT 4000-FL105 BASET R160 13000 NPT SFC (OCNL 50000) 2000 MIMBI 1400 SFC GISOK UNL CITY TEBRA SFC COTSWOLD SFC LTMA 23 SFC SFC BRISTOL POMAX KENET SFC CTR 3 A 4 CTA 3 5500-FL195 BAKER §D146 KEGIT HPLT A CTA 7 BRISTOL SFC-2500 RAPIX 3000-FL105 4000-FL105 FL105-FL195 3000 CLACTON EBEH5 DOKEK CTA 8 TANET DIBLI INLAK NORRY LONDON UMBUR CTA 9 SLUI B LTMA 11 LINDY SFC

BRIST 4500-FL105 R 4500-FL195 CTR TUNEL FL105-FL195

BRIST I B Y3 2 R104 EBEH4 3 BULAM SAMON S OKESI ABDAL SFC-2500 VATON 0 ORTOM CARDIFF R 1 FL105-FL195 CT 5 R107

2000-FL105 T

0 2400 5 0

I 2 1 O

CTR S 0 0 2000 CARDIFF CT 0

OL A R159 0 5

L SFC 0 - ठT ALKIN - D133

0 3 SFC-FL105 0 F F

OL - O SFC

C 1400 0 1 0 F CT L GATRA L ║  ‡†§D128 1200 LUMEN - †§ L A - L 1 T D125 1 R101 F HELEN F CT SFC BRISTOL DET04 A 1 0 0 LTMA 12 LEDGO 2 C (OCNL 2400) WORTHING DENUT MERLY L 1400 BEDEK L  A

0 5 50000 TABEN A 5 2400 LTMA 1 1 T CTR 6 1

1 5000-FL195 5 Q41 HILLY CTA 5 A (OCNL 50000) 0 SFC A 0 SFC-FL105 SFC SFC WEALD 2500-FL195 5 2 BIBLA KESUP CTA 5 5 FL65-FL195NUBRI WORTHING FL105-FL195 4 †§D124 SFC FL175-FL195 3000- TOMMO N160 NIGIT § CTA 4 (See Note 1 1000-FL105 UNL D133A VABIK MADUX FL105 LAMAT †§D126 FIMLI LAM43 FL85-FL195 CARDIFF CT SOMOT ║ § 1200 1500-FL105 †§D123 SFC D132 LTMA 1 DORKI LAVRI FL55-FL105 R153 1400 FL105-FL195 A 5 3000-FL105 BRISTOL CT  15 2500 SFC 2500-FL195 ACORN FL145-FL165N160D CARDIFF C2000T 50000 (OCNL FL90) WORTHING (See Note 1 SFC VAPID ROVUSLSFCTMA 4 CTA 5100N §D119 SFC SFC TAGOX LTMA 3 CTA 3 1) CARDIFF CTA 5 †D122C 3500-FL195 HOGBA 1500-2500 3500-FL195 LTMA 25 DVR10 FL75-FL195 Q41 N864 5000 ELRAG 3000- SEVERN  LTMA 13 5500-FL195 FL160 DVR10 FL105SFC CTA 1 FL65-FL1 PEPIS 5500-FL195 KONAN FL80 SOLENT §D131 TUNBY MAPAG 1) EXMOR FL105-FL165 SOLENT CTA 3 1400 GATWICK DVR11 5100N CTA 1 2000-5500 SOLENT BONDY NEMGO LESLU CARDIFF COTSWOLD SOLENT CTA SFC SFD31 CTR WIZAD CTA 7 SEVERN CTA 1 1500-5500 CTA 5 (See†D120 Note 1) SAM11 SFC-2500 PENUX §D110 4500-FL65 CTA 2 FL165-FL195 †D122A 2500-5500 BOGMI 2500 HANKY DIPKA FL105-FL165  SOLENT L 2000 FL160 4500-FL195 SANDY SFC TMA BISRU WORTHING SFC COTSWOLD FL80 CTA 4 TIGER §D141 RINTI EG020 CTA 1 GOLEX KERKY CTA 2 2500-5500 ROMTI 3200 LFEG1 24 FL65-FL195 SUDOD FL165-FL195 §D130 CTA SFC Q41 1500-2500 FERDI Q41‡║§D127 5500-FL195 L620 1800 DENOX MID10 LFAC MULIT FL65-FL9512000 (See Note 2) 5500-FL195 (OCNL 2300) LYD07 RODRI † HAZEL MOTOX PAVLO D122B SFC (See Note 2) SFC WILLO TEBLO FL160 SAM10 SOUTHAMPTON LF606 D064A FL80 SOUTHAMPTON LTMA 22 LUMBATIMBA D064B CTR SOLENT LTMA 14 R063 FL660 CTA 7 5500-FL195 EG062 FL660 D064C L620 SFC-2000 5000-FL195 LARCK 2000 10000 FL660 3000-5500 LTMA 20 10000 FL95-FL195 SFC TRACA (OCNL 5000) (OCNL 5000) 10000 SOLENT LTMA 15 4500-FL195 §D044 DEVAL AREA 10 (EAST) HOLLY LTMA 25 ROKOS (OCNL 5000) CTA 2 5500-FL195 4000 ROTNO AKOVI L620 LTMA 21 ASTRA 5500-FL195 FL145-FL185N160D FL260 2000-5500 SFC (See Note 1 DIDEL ATWEL FL80 FL135-FL195 MID16 FL65-FL195 5500) SAM25 SOLENT MOVAD REVGO T SOLENT CTA 2 SOLENT AVANT SOVAT BELOB TIVER ARKIL AL BUMUX CTA 2 2000-5500 CTA 2 N864 SAM36 2000-5500 PIMIX 1) 2000- SOLENT FL65-FL195 N862 BOURNEMOUTH EG060 LTMA 25 SISGA ‡D011A N90 5500 CTA 6 D POMPI (MNM CTR SFD56 BEGTO FL105-FL195 BEWLI N514 5500-FL195 HASTY 10000 (See Note 16) GIBSO 2500-FL552500-5500 Y8 A FL105-FL195 (See Note 7) N514 SFC-2000 (See Note 2) AREA 12 (OCNL 24100) DEVOM §D015 FL75-FL195 BEXIL FL280 TOMPO FL155-FL195 L151/N859 SFC 3600 BOGNA RATUK FL70 §D061 BRIPO FL75-FL195 MID23 LFQT RONOR KUTEX SFC LUCCO TUKVI 1500 P047 Q41 A SFD07 LYD26 N514 MID28 SFD06 IBERU TINAN 1000 SAM34BILNI KAPEX LFQQ TULNI ARVOL SFC 5500-FL195NEDUL L980/M185ELDER FL125-FL195 ‡†§ SFC EG058 D012 FL105-FL195 (See Note 4) 18000 CAMRA ADUTO ‡ ODENI D011B ‡D011C (OCNL 25000) SUSIX N863 ALESO WAFFU ROBAL †§D001 4500 10000 SFC SOLENT FL125-FL195 OSMOD (OCNL 24100) DAWLY CTA 9 (See Note 20) ABROM 1000 (OCNL 24100) SOLENT KUMIL WORTHING BANVA LFAT SFC †§D031 3500-5500 †§D037 SFC SFC N866 CTA 8 CTA 2 KUNAV †§D021 15000 55000 L151/N859 DIMAL SUDAP §D026 3500-5500 FL75-FL195 ELNUX 15000 FL165-FL195 SFC FL85-FL195 BARLI LUMIL VEKIN LULOX (See Note15000 23) SFC KATHY SFC ROKSI SUSON THRED HARDY DENIN (OCNL 20000) BEECH IDOKO SUBIP INSUN ‡†§D014 SFC CHANL MEDIL 5000 BENBO AREA 10 (WEST) LFAV NOTRO (OCNL 15000) VESAN FL260 BABAX N621 ) SFC 0 BEVEL 2 DIPER FL80 FL165-FL195 2000 e GITUS †§D013 t HAWKE SFC o XIDIL PLYMO †§  N D009 60000 ERMIN e  MOODY N863

22000 SFC e †§ RIGDI D007 S PILIP FL125-FL195 SFC ‡†§ ( 2000 †§D007B D017 SFC 22000 22000 ) †§ †§ FL105-FL195 (OCNL 55000) ASPEN 5 D038 D039 SFC (See Note 7) BENDY 4 VELOK †§D007A ‡†§ 9 ‡‡†§ D023 RUBMI 2 D040 SFC 1 55000 55000  N90 22000 DOMUTL e 22000 Q41 t SFC SFC 22000 F

o MATIX SFC FL105-FL195 MARUK - (See Note 10) (OCNL 55000) FL35-FL195 (OCNL 55000) 5 5000N TESDO N ABNUR TURLU Y91 0 FL85-FL195 P87 DRAKE XAMAB (See Note 16) SFC e SFC PETAX N862 1

e †§D009A L S

F SOBDO 55000 ( †§D036 AREA 11 ABUDA 5000N †§D006A SFC 19000 OSPOL GAPLI FL260 (OCNL 55000) 22000 VEXEN FL80 SFC KESAX SFC EG194 N867/P87 SITET ROSIV VERMA M189 SULEX FL125-FL195 FL75-FL195 ADNOR (See Note 24) RODIN NEBRU LFAQ LANLO BELDI LF608 SOSUN AGLAX BILGO †§D006 PERON SKERY NEVIL 1500 BIGNO ORTAC ORIST BOLRO GARMI KOTEM XORBI †§D008 NITAR SFC  LELNA BANTI 55000 CHANNEL OPALE ADSUD LFAY SFC CHANNEL ISLANDS CHANNEL ISLANDS ISLANDS PIREG ELVES LORKU ANGLO IDOKI CTA 1 CTR CTA 2 LESDO FL55-FL195 SFC-FL195 3500- LFAB SOPOL NURMO LONDON FIR †§D003 FL195 55000 †§D004 VEULE  ATREX SHANWICK OCEANIC FIR FL145-FL185N160D SFC 55000 GIKEL MABUG SFC SOMIL SKESO 00100W 00000 00100E 00200E 00300E 00400E VENOR EPATI MANIG NORDA IRBAL

UVRIL SALCO †§D008A NAKID †§D008B 22000 55000 DOMOK Note 1 SOLENT CTA Note 8 L18 Note 15 N615 Note 21 N601 SFC SFC MANTA BRILL ANGLA Winter hours: Monday-Friday 0630-2230 ETRAT CDR Category One (CDR 1) Daily from 0700 to 2000 (1 hour earlier in summer) between 545632N 0034415W and May to August inclusive CHANNEL ISLANDS Saturday 0630-2100 Monday-Thursday 1800-0900 (winter), 1700-0800 (summer) and from 1700 (winter and Dean Cross VOR (DCS) the lower limit is FL125 making the MNM FL (southbound) Monday - Thursday 1700 - 0830 the following day. CTR ALDERNEY NEMED ANNET AGANO Sunday 0730-2230. summer) on Friday or the day preceding a publicOLMES holiday to 0900 (winter), 0800 FL130 and MNM FL (northbound) FL140. Friday or the day preceding a public holiday to 1700 - 0830 Monday or the day RATKA SFC-FL195 CTR LFRC NAKIB SFC-2000 Summer hours: Monday-Friday 0530-2130 (summer) on Monday or the day following a public holiday. following a public holiday inclusive. Saturday 0530-2030 Note 16 N862 September to April inclusive LIZAD KABUR CDR Category Two and Three (CDR 2 and 3) LND41 ORMER Sunday 0630-2130. At all other times. ERNOK to Berry Head VOR (BHD) available only during: Monday - Thursday 2359 - 0930 the following day. REVTU AKIKI PHILI DIKROHours subject to change, consult latest NOTAM. 1600 Friday - 0800 Monday (winter). TALIG Activation of the North Wales MTA Southern Area beyond the published hoursIDLAB is Friday or the day preceding a public holiday to 1700 - 0930 Monday or the day DEMOM permitted on weekdays, weekends and public holidays (see UK AIP ENR 5.2-1). During 1500 Friday - 0700 Monday (summer). following a public holiday inclusive. BENIX Note 2 L620, N514 and Q41 LFOH TANCA MARKU these periods of activity L18 west of LANON will not be available. Non availabilityROUBO of During summer (BST) times for September to April are 1 hour earlier than stated above. PEMAK DOLUR BOGVA Outside notified hours of SOLENT CTA (above) L620, N514 andBAGEK Q41 base is FL55. L18 will be notified to GAT by London ACC and traffic will be re-routed via AWYs L9 Note 17 N864 MOBRO Between Dean Cross VOR (DCS) and Wallasey VOR (WAL), N864 is only available SUPAP LND47 and M17. Note 22 L10 and P6 LARLA from 1800 on Fridays, or the day preceding a public holiday, until 0800 on Mondays, or PIKEY Note 3 N864 Within the confines of the Belfast TMA, L10 and P6 assume the classification of the the day following a public holiday, winter (summer 1 hour earlier). For limited periods, PIKOD Note 9 N57 Belfast TMA. LONDON FIR R095 Between ANGUS and Talla VOR (TLA) established from 0001 on Saturday toATMOS 2359 on INPAX during these times, this part of airway N864, may be required for use by the MoD. GANTO CHUBB LAGUL Sunday as an alternative route when airway P600, to the south of Perth VOR (PTH), Daily from 0700-2000 winter (summer 1 hour earlier) between DeanLFOP Cross VOR (DCS) 2374 and 540532N 0023208W the lower limit is FL125 making the MNM FL (southbound) These activities will be promulgated by Scottish AC (Prestwick) and the alternative SFC has been made available to Portmoak for gliding activity. HoweveABAMU r, aircraft may flight route will be 'as directed by ATC'. Note 23 N866 plan to use this route at any time during the above hours. At certain times, notably FL130 and MNM FL (northbound) FL140. CDR Category One and Three (CDR 1 and 3) H24. TUNIT GUERNSEY GULDA when the airspace is required for military use, this weekend routeINGOR will not be available. LFRG The use of this airway can be interrupted when UN866 is notified as unavailable due to CTR Note 18 N864 In these circumstances, all of AWY P600 will be retained for use. Note 10 Y91 KEREX SOKVI activity above ALT 22000 ft within Danger Area EG D023. CAMBO SFC-2000 KOLIV Between 2000 and 0700 daily, winter (summer 1 hour earlier). An area with lower limit MUREL GANPU CDR Category One (CDR 1) KETIK of FL55 and upper limit FL105 bounded by straight lines joining:531733N LULIP 1600 Friday-0800 Monday (winter) ELBOX PODEM LF213 Note 4 N514 0031654W-530540N 0032345W-530348N 0031757W-531733N 0031654W. Note 24 N867 (GARMI - KATHY) and P87 GOBUR Between 0500-1000 winter (summer 1 hour earlier) an area of controlled airspace 1500 Friday-0700 Monday (summer). CDR Category Three (CDR 3) H24. bounded by great circle lines joining: 504626N 004942W - 503251N 0003514W - Not available on public holidays. The use of these airways may be interrupted when MoD (Navy) requires the activation Note 19 P18 BISKI LF212 503250N 0010741W - 504626N 0004942W is part of N514. of Danger Area EG D036 above ALT 19000 ft. Closures will be notified by NOTAM and Note 11 N160 and N160D (LEDGO - LND) CDR Category One (CDR 1) between Aberdeen VOR (ADN) and NATEB, CRAM. There may be circumstances when London Control (Swanwick) is given a 4900N JERSEY CDR 1 Tuesday-Friday 0530-0900 and from 1500 on Friday or the day preceding a EMPER LUSIT Note 5 L70 CDR Category One and Three (CDR 1 and 3) H24. minimum of only 2 hours notice of Danger Area activity. Non-availability of N867 and/or CTR Availability subject to SWMDA activity. public holiday to 1000 Monday or the day following a public holiday (1 hour earlier in P87 will be notified to GAT by Brest Control and traffic will be routed to ORIST R24 and CHANNEL ISLANDS SHARK Between KOLID and PENIL. Route subject to short notice closure to accomodate SFC-2000 LFRK summer). Additionally available overnight, May-September, Monday-Thursday L980. CTR Warton operational requirements. Aircraft will be tactically vectored by ATC. 1900-0900. (see GEN 2-1-2, para 6 for Scottish public holidays). The airway is not SFC-FL195 LF604 TAKAS Note 12 N601 available for use during these periods when MoD require access to the airspace. ALUTA Note 6 L10 Part or all of this airspace may not be available when activity associated with D510, Note 25 Y124 MOSIS PERCH SpadeadamLISEU requires access to the area. Non-availability of airspace will be notified to During the notified hours of operation of the Isle of Man CTR/CTA the lower limit of the Note 20 N863 CDR Category One (CDR 1) Winter. 1800 to 0800 Monday - Friday and 1700 Friday (or OYSTA section of this airway between SLYDA and CASEL will be FL65. GAT by Scottish AC (Prestwick). the day preceding a Public Holiday) to 0800 Monday (or the day following a Public SENLO RUBIX CDR Category Three (CDR 3) H24. DEKOR Holiday) (1 hour earlier in summer). BEVAV LEMAR PIKUP The use of this airway may be interrupted when MoD (Navy) requires the activation of Note 7 N90 Note 13 N601 CDR Category Two (CDR 2) Winter. 0800 to 1800 Monday - Thursday and 0800 to Daily from 0700 to 2000 (1 hour earlier in summer) between 550740N 0030443W and Danger Areas EG D037 and/or D038 above ALT 19000 ft. Closures will be notified by MINQI ORVAL CDR Category One and Three (CDR 1 and 3) 1700 Friday. 540922N 0022312W the lower limit is FL125 making the MNM FL (Northbound) FL140. NOTAM and CRAM. There may be circumstances when London Control (Swanwick) is NERLA LERAK 1600 Friday-0800 Monday (winter) CANSU given a minimum of only 2 hours notice of Danger Area activity. Non-availability of N863 CDR Category Two (CDR 2) Summer. 0700 to 1700 Monday - Friday. 1500 Friday-0700 Monday (summer). will be notified to GAT by Brest Control and traffic will be routed to ORIST R24 and RUSIB 4900N Note 14 N601 SAUVA L980. BETUV BASIK Between the hours of 1700 to 0900 each day Monday - Friday and 1700 Friday to 0900 ARGED Monday + public holiday (1 hour earlier in summer) (see GEN 2.1-2, para 6 for public holidays), an area of controlled airspace is part of N601. Base level FL165, bounded by KOKOS great circle lines joining: 551735N 0025427W-551724N 0024532W-551241N VIREX 0023052W-545912N 0022555W- 545610N 0024159W-551735N 0025427W. GILRA SOMEN Part or all of this area of airspace may not be available when MoD requires access to GALBO the area. Non-availability will be notified to GAT by Scottish AC (Prestwick). MOTAG DIRGO LASNO TITUB TIRGI 00900W 00800W 00700W 00600W 00500W 00400W MOLOV 00300W 00200W NORBU LFRO RANES