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Burbo Bank – Airspace Change Proposal

Date: 7 July 2014 Author: Revision: Issue 1 Osprey Ref: 7750 025

This document is of UK origin and has been prepared by Osprey Consulting Services Limited (Osprey) and, subject to any existing rights of third parties, Osprey is the owner of the copyright therein. The document is furnished in confidence under existing laws, regulations and agreements covering the release of data. This document contains proprietary information of Osprey and the contents or any part thereof shall not be copied or disclosed to any third party without Osprey’s prior written consent.

© Osprey Consulting Services Limited 2014 The Forge, London Road, Bentley, Hampshire. GU10 5HY 01420 520200 / [email protected] Registered in England and Wales under No: 6034579

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Document Details

Reference Description

Document Title Burbo Bank TMZ – Airspace Change Proposal

Document Ref 7750 025

Issue Issue 1

Date 7 July 2014

Client Name DONG Energy

Classification Nil

Approval Level Authority Name

Author Osprey CSL

Internal Approval Osprey CSL

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Executive Summary

DONG Energy (DONG) plans to develop an extension to the existing operational Burbo Bank Offshore Wind Farm in Liverpool Bay. The Burbo Bank Extension Offshore Wind Farm will cover an area of 40 km2 and have an estimated generating capacity of up to 259 Mega Watts (MW). The project development site will be located west of the operational wind farm, around 7 kilometres (km) (3.8 Nautical Miles (NM)) north of the North Wirral coast near the village of Meols, 8.5 km (4.6 NM) from Crosby beach, and 12.2 km (6.6 NM) from the Point of Ayr on the Welsh coast. The Issue The presence of the Burbo Bank Extension Wind Farm would affect BAE Systems Warton (Warton) Aerodrome flying and Air Traffic Service (ATS) operations, with the most significant impact being the detection of the wind turbines by the Warton Primary Surveillance Radar (PSR). Wind Turbine Generators (WTGs), with maximum blade tip heights of up to 223 metres (m), located within PSR coverage can present themselves as reflecting moving targets to the radar, which look very similar to aircraft radar returns. Air traffic controllers are required to take action in response to these false radar returns (also known as “clutter”) displayed on the radar screen, as it cannot be assumed they are not aircraft, which has the potential to erode levels of effectiveness and efficiency for the control of aircraft flying in the area of the Burbo Bank Offshore Wind Farms. DONG has worked with Warton to identify a solution to mitigate the effects of the WTGs on the PSR, which will enable the Burbo Bank Extension Offshore Wind Farm WTGs to be built without affecting Warton flying operations. Proposed solution In developing the plans to resolve these issues, DONG and Warton have considered a variety of options to determine how best to meet the needs of Warton as well as other aviation and non- aviation stakeholders. Whilst the existing operational WTGs do not affect the Warton PSR, from an airspace user perspective, DONG and Warton consider that if mitigation involves a change to local airspace, then it is simpler to apply the change to both the operational and proposed extension Wind Farms. It would be difficult for a pilot to make a visual distinction between the two sets of WTGs. Warton’s preferred solution is to establish a Transponder Mandatory Zone (TMZ) around the Burbo Bank operational and extension Offshore Wind Farms up to the base of Controlled

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Airspace (CAS), to be active during the Warton Lower Airspace Radar Service (LARS) provision times1. The proposed TMZ (lined in green) is illustrated in Figure 1 below. The proposed establishment of the TMZ is one element of a 3-part Mitigation Package aimed at negating the impact of the clutter from the Burbo Bank Extension Offshore Wind Farm WTGs upon the Warton PSR. The three parts are: • Element 1: Establishment of a TMZ; • Element 2: Authorisation to control Secondary Surveillance Radar (SSR)2-only and; • Element 3: Suppression of PSR returns within the boundary of the Wind Farms.

Figure 1 Burbo Bank Proposed TMZ. Contains Ordnance Survey data © Crown Copyright. All rights reserved. 2013 License number 0100031673.

CAA Safety and Airspace Regulation Group (SARG) Stirling is the organisation that authorises Warton Air Traffic Control (ATC) to provide services using SSR-only. Warton have made the request for ATS using SSR-only within the proposed TMZ. This document outlines the proposal from DONG to maintain the effectiveness and efficiency of the airspace surrounding the Burbo Bank Offshore Wind Farms by mitigating the effects of the WTGs on Warton flying and PSR-based ATS operations.

1 Monday to Thursday 0730 – 1900, Friday, 0730 – 1700 (local time). 2 SSR is a radar system used in Air Traffic Control (ATC) that not only provides controllers with azimuth position information, but also requests additional information from the aircraft itself such as its altitude.

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Consultation NATMAC members plus selected additional stakeholders were directly consulted. In addition, general public consultation was undertaken by publication of the consultation material on the DONG website. A list of identified stakeholders is at Annex A4 (individual members of the public who submitted unsolicited comments are not listed). The purpose of the consultation was to seek primarily industry comment on DONG’s proposal and to refine this accordingly prior to implementation.

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Contents

1 Glossary ...... 9

2 Introduction ...... 13

2.1 General ...... 13 2.2 Purpose and Objectives ...... 14 2.3 Consultation ...... 14 2.4 Document structure ...... 15

3 The Need for an Airspace Change Proposal ...... 16

3.1 Overview ...... 16 3.2 General flying operations at Warton Aerodrome ...... 16 3.3 Justification for an Airspace Change ...... 17

4 Proposed Design ...... 22

4.1 Overview ...... 22 4.2 Option 0 – Do nothing ...... 22 4.3 Option 1 – A PSR solution ...... 22 4.4 Option 2 – Radio Mandatory Zone (RMZ) ...... 23 4.5 Option 3 – Secondary Surveillance Radar (SSR)-only ...... 23 4.6 Option 4 – Primary Surveillance Radar (PSR) blanking or Non-Auto Initiation Zone (NAIZ) only ...... 23 4.7 Option 5 – A Transponder Mandatory Zone (TMZ) with associated PSR Suppression Techniques ...... 24 4.8 The Proposed TMZ...... 24

5 Impact of the Proposed TMZ ...... 28

5.1 Overview ...... 28 5.2 Impact of the TMZ on military operations ...... 28 5.3 Impact of the TMZ on light GA operations ...... 28 5.4 Impact of the TMZ on offshore helicopter operations ...... 29

6 Environmental and Economic Considerations of a TMZ ...... 30

6.1 Overview ...... 30 6.2 Impact of noise ...... 30 6.3 Anticipated level of fuel burn/CO2 emissions ...... 30 6.4 Anticipated effect on local air quality ...... 31 6.5 Environmental implications ...... 31

7 Consultation Response Analysis ...... 32

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7.1 Overview ...... 32 7.2 Consultation summary ...... 32 7.3 Consultee organisations ...... 33 7.4 Responses ...... 34 7.5 Meetings with major stakeholders ...... 36 7.6 Consultation results ...... 36 7.7 Confidentiality ...... 37 7.8 Publication ...... 37

8 References ...... 38

A1 Burbo Bank Extension Offshore Wind Farm Line of Sight Assessment ...... 39

A1.1 Overview ...... 39 A1.2 Boundary Details...... 39 A1.3 LoS Assessment Methodology ...... 39 A1.4 LoS Assessment Results ...... 40 A1.5 Conclusion ...... 40

A2 Proposed TMZ Co-ordinates ...... 41

A3 Consultation Background and Methodology ...... 42

A3.1 Background to the Consultation ...... 42 A3.2 Method of Consultation ...... 42

A4 Stakeholder / Consultee List ...... 44

A4.1 Aviation Consultees ...... 44 A4.2 Aerodromes / Local Aviation Consultees ...... 45 A4.3 Non-Aviation Consultees: National Bodies ...... 46 A4.4 Non-Aviation Consultees: Regional Council Authorities ...... 46 A4.5 Non-Aviation Consultees: Council Wards / Local Authorities ...... 46 A4.6 Non-Aviation Consultees: Town / Parish Councils ...... 48 A4.7 Information Organisations: Members of Parliament ...... 48 A4.8 Information Organisations: Civil Aviation Authority ...... 48

Table of Figures Figure 1 Burbo Bank Proposed TMZ. Contains Ordnance Survey data © Crown Copyright. All rights reserved. 2013 License number 0100031673...... 4 Figure 2 Liverpool Bay and Morecambe Bay Airspace. The proposed TMZ, with section ceilings, is outlined in Green. The Black solid line shows the extended main runway centrelines at Blackpool (20 NM from the TMZ boundary), Warton (20 NM) and RAF Woodvale (6 NM). Reproduced from CAA digital map data © Crown copyright 2014. UK IAIP ENR...... 17 Figure 3 Liverpool Bay and Morecambe Bay Airspace with the Warton Fillet outlined in Orange and the southern boundary of the Warton ARA outlined in Purple. Reproduced from CAA digital map data © Crown copyright 2014. UK IAIP ENR...... 18

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Figure 4 Burbo Bank Proposed TMZ including 2 NM Buffer Zone. Reproduced from CAA digital map data © Crown copyright 2014. UK IAIP ENR...... 26 Figure 5 Distribution of Consultees...... 34 Figure 6 Responses from Listed Consultees...... 35 Figure 7 Support Ration from Listed Consultees...... 36 Figure 8 LoS Profile between Warton (PSR) and Point 1...... 40

Table of Tables Table 1 Responses from Consultees...... 34 Table 2 Table of References...... 38 Table 3 Summary of Turbine/Boundary Details...... 39 Table 4 Summary of Turbine/Boundary Detection...... 40 Table 5 Burbo Bank TMZ Co-ordinates...... 41

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1 Glossary

Acronym Meaning

AAIB Air Accident Investigation Board

ACC Airport Consultative Committee

ACP Airspace Change Process

ACAS Airborne Collision Avoidance System

AEF Air Experience Flight

agl above ground level

AIP Aeronautical Information Publication

AOA Airport Operators Association

AOPA Aircraft Owners and Pilots Association

AR Airspace Regulation

ARA Advisory Radio Area

amsl above mean sea level

ATC Air Traffic Control

ATM Air Traffic Management

ATSOCAS Air Traffic Service Outside Controlled Airspace

ATS Air Traffic Service

ATSU Air Traffic Service Unit

BAA British Airports Association

BABO British Association of Balloon Operators

BALPA British Airline Pilots’ Association

BATA British Air Transport Association

BBAC British Balloon and Airship Club

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BBGA British Business and General Aviation Association

BGA British Gliding Association

BHA British Helicopter Association

BHPA British Hand Gliding and Paragliding Association

BIA Blackpool International Airport

BMAA British Microlight Aircraft Association

BMFA British Model Flying Association

BPA British Parachute Association

CAA Civil Aviation Authority

CAP Civil Aviation Authority Aviation Publication

CAS Controlled Airspace

CAT Commercial Air Transport

CO2 Carbon Dioxide

CTA Control Area (Class D UK Airspace)

DAATM Defence Airspace and Air Traffic Management

Directorate of Airspace Policy (part of the CAA – now DAP SARG)

DIO Defence Infrastructure Organisation

DfT Department for Transport

DS Deconfliction Service

ELFAA European Low Fares Airline Association

FJ Fast Jet

ft feet

GA General Aviation

GASCo General Aviation Safety Council

GAT General Air Traffic

GAPAN Guild of Air Pilots and Air Navigators

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GATCO Guild of Air Traffic Control Officers

HCGB Helicopter Club of Great Britain

HQ DAAvn Headquarters Director Army Aviation

IAIP Integrated Aeronautical Information Package

IFP Instrument Flight Procedure

IoMA Isle of Man Airport

km kilometre

kts knots

LAA Light Aircraft Association

LARS Lower Airspace Radar Service

LJLA Liverpool John Lennon Airport

LoA Letter of Agreement

LOS Line of Sight

m metre

MAA Military Aviation Authority

MoD Ministry of Defence

MTWA Maximum Total Weight Authorised

MW Mega Watt

NAIZ Non-Automatic Initiation Zone

NATMAC National Air Traffic Management Advisory Committee

National Air Traffic Service

NATS Provider of en-route air traffic services in the Scottish and London Flight Information Regions and at some civil airports.

NERL NATS En-Route Ltd

NCHQ Navy Command Head Quarters

NM Nautical Mile

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NOTAM Notices to Airmen

NO2 Nitrogen Dioxide

OS Ordnance Survey

PSR Primary Surveillance Radar

RAF Royal Air Force

SARG CAA Safety and Airspace Regulation Group

SSR Secondary Surveillance Radar

TMZ Transponder (SSR) Mandatory Zone

UAS University Air Squadron

UAV Unmanned Air Vehicles

UKAB UK Airprox Board

UKFSC UK Flight Safety Committee

VFR Visual Flight Rules

VGS Volunteer Gliding Squadron

VHF Omni Directional Radio Range; a type of short-range VOR radio navigation system for aircraft

WAL Wallasey VOR

WTG Wind Turbine Generator

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2 Introduction

The presence of the Burbo Bank Extension Offshore Wind Farm would affect BAE Systems Warton Aerodrome flying and Air Traffic Service (ATS) operations, with the most significant impact being the detection of the Wind Turbine Generators (WTGs) as unwanted clutter by the Warton Primary Surveillance Radar (PSR). DONG Energy (DONG) and BAE Systems have worked together to identify a suitable mitigation which will enable the Burbo Bank Extension Wind Farm WTGs to be built without affecting Warton flying operations.

2.1 General DONG Energy (DONG) wishes to develop an extension to the existing Burbo Bank Offshore Wind Farm, referred to as the Burbo Bank Extension Wind Farm. The project development site will be located west of the operational offshore wind farm in Liverpool Bay, around 7 km (3.8 NM) north of the North Wirral coast near the village of Meols, 8.5 km (4.6 NM) from Crosby beach, and 12.2 km (6.6 NM) from the Point of Ayr on the Welsh coast. DONG is the Sponsor for the proposed airspace change herein detailed. The presence of the Burbo Bank Extension Offshore Wind Farm WTGs would affect BAE Systems Warton Aerodrome flying and ATS operations thereby requiring a change to the arrangements and procedures in the immediate airspace surrounding the wind farms. WTGs located within PSR coverage can present themselves as moving targets to the radar, which look similar to aircraft radar returns. Air traffic controllers are required to take action in response to these false radar returns (also known as “clutter”) displayed on the radar screen, as it cannot be assumed they are not aircraft, which has the potential to erode levels of effectiveness and efficiency for the control of aircraft flying in the area of the Burbo Bank Offshore Wind Farms. False radar returns may cause disruption by forcing air traffic controllers to take unnecessary action in order to maintain radar separation in accordance with Civil Aviation Authority (CAA) regulations. Hence, any loss of radar performance in this area, along with any misleading or unnecessarily distracting displayed radar information, has the potential to erode the effective and efficient use of the airspace in the area of Burbo Bank Extension Offshore Wind Farm. Analysis completed as part of the Planning Application for the Burbo Bank Extension Offshore Wind Farm concludes that it is highly likely that the Warton PSR will detect all WTGs located within the planned Extension area. Annex A1 provides an example radar Line of Sight (LoS) profile for reference. The existing operational Burbo Bank Offshore Wind Farm does not affect the Warton PSR, as the WTGs are smaller than the those planned for the extension, and there is

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partial intervening terrain that also serves to shield the existing turbines from detection by the radar. The degradation in the detection and tracking capabilities of the Warton PSR in the area of Burbo Bank Extension Offshore Wind Farm is of particular importance with regard to the flight test area near to the Wind Farm boundary. The Burbo Bank Extension Wind Farm WTGs lie adjacent to a piece of airspace known as the ‘Warton Fillet’ area, ordinarily Controlled Airspace (CAS) that is delegated to Warton on occasion to provide a sufficient volume of airspace for testing of advanced air systems. If there were a reduced ATS from Warton Air Traffic Control (ATC) in the area of the Burbo Bank Extension Offshore Wind Farm WTGs, it would effectively render the southern half of the ‘Warton Fillet’ unusable. Other airspace users requiring a service from Warton ATC may also experience disruption due to unnecessary route deviation. Extensive work to determine a solution to the potential impact of the turbines on the ATS provided by Warton has been undertaken by DONG and Warton. It has been determined that the introduction of a Transponder Mandatory Zone (TMZ) over the Burbo Bank Wind Farms will mitigate the effects of the detection of WTGs by the Warton PSR. Any change to airspace constructs requires adherence to CAP 725 [Ref 1] and the Airspace Change Process (ACP). DONG is the sponsor of this Airspace Change Proposal and has engaged Osprey Consulting Services Ltd (Osprey) to manage the process on their behalf. 2.2 Purpose and Objectives The purpose of this document is to provide information regarding the proposal to establish a Burbo Bank Transponder Mandatory Zone (TMZ), including any changes made to the airspace design following consultation, over the existing Burbo Bank Offshore Wind Farm and its Extension to mitigate the effects of the detection of unwanted wind turbine radar returns by the Warton PSR. This document has been prepared by Osprey, on behalf of DONG and Warton and in accordance with CAP 725 [Ref 1]. The objectives of the document are to: • Provide the Airspace Change Proposal; and • Describe the other mitigation options considered and explain why these options have been considered insufficient for the effects of the detection of unwanted WTG radar returns by the Warton PSR. It is DONG’s responsibility as Sponsor of the proposed change to consult with all relevant stakeholders who may be directly or indirectly affected by the proposal. 2.3 Consultation NATMAC members plus selected additional stakeholders were directly consulted on the proposal. In addition, general public consultation was undertaken by means of publication of consultation material on the DONG website. A list of identified stakeholders is at Annex A4 (individual members of the public who submitted unsolicited comments are not listed). The purpose of the consultation was to seek primarily aviation industry comment on DONG’s proposal and to refine this

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accordingly prior to implementation. Such refinement would result in a reshape of the airspace design. An analysis of consultation responses is presented in Section 7 of this document. 2.4 Related Documents Request for SSR-Only Control within the proposed Burbo Bank TMZ (Issues by BAES Warton to SARG Stirling). Burbo Bank TMZ Consultation Document (Osprey, 7750 010). Burbo Bank TMZ FAQs (Osprey, 7750 016). Burbo Bank TMZ Consultation Record (Osprey, 7750 020). Burbo Bank TMZ Safety Program Plan (Osprey, 7750 021). Burbo Bank Safety TMZ Case Pt1 (Osprey, 7750 022). Burbo Bank TMZ Interim Consultation Report (Osprey, 7750 023). Burbo Bank TMZ Final Consultation Report (Osprey, 7750 024). Burbo Bank Safety TMZ Case Pt2 (Osprey, 7750 026). Burbo Bank TMZ Traffic Survey (Osprey, 7750 027). 2.5 Document Structure This document contains eight main sections and four Annexes, outlined below for convenience: • Section 1 provides a glossary; • Section 2, this section, introduces the document; • Section 3 describes the necessity for an ACP; • Section 4 gives an overview of the proposed design option; • Section 5 assesses the impact of the proposed TMZ; • Section 6 details the environmental and economic considerations; • Section 7 analyses the consultation responses; and • Section 8 provides a list of references. There are four Annexes: • Annex A1 details the radar line of site assessment for the Burbo Bank Extension Offshore Wind Farm; • Annex A2 provides the co-ordinates of the proposed TMZ; • Annex A3 describes the consultation background and methodology; and • Annex A4 lists the Consultees.

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3 The Need for an Airspace Change Proposal

Warton ATC operates under regulatory oversight of both the Military Aviation Authority (MAA) and the CAA, providing essential ATS to military and civil aircraft in the area of the Burbo Bank Extension Wind Farm development.

3.1 Overview This section describes the background relevant to this Airspace Change Proposal by providing an overview of flying operations at Warton and by highlighting the primary areas of concern relating to the effects of the Burbo Bank Extension Offshore Wind Farm on Warton operations. In this case, there are four principal issues to be considered: Test flying operations near the ‘Warton Fillet’ (L70); Services to aircraft under the Lower Airspace Radar Service (LARS) scheme; The Approach Control Service; and operations at RAF Woodvale. 3.2 General flying operations at Warton Aerodrome A range of military and civilian aircraft operate from Warton aerodrome. The airfield carries out, on average, around 1000 aircraft movements per month, 40% of which are military registered flights, in support of the following operational tasks: • Flight development and test activities, predominantly on Typhoon, Tornado and Hawk aircraft, which can include civilian test support aircraft operations; • Production test flying of brand new Typhoon (and soon to be Hawk) aircraft that are manufactured on site; • Daily commercial passenger flying operations; • Military and civilian transport operations; • National Police Helicopter operations; and • Flying training activity on civilian and military aircraft. Warton ATC provides aerodrome control and approach control services to a wide range of commercial, general aviation and military aircraft in the airspace over the Irish Sea and overland near Warton. In addition to these routine ATC tasks, Warton ATC is responsible for providing LARS cover to a radius of 74 km (40 NM) from Warton and a dedicated specialist service to aircraft conducting test and development flights flying up to (and occasionally beyond) 370 km (200 NM) from Warton. Warton ATC operates under regulatory oversight of both the MAA and the CAA. The standard ATS, the LARS, and the dedicated test service combine to support the

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required efficient and effective operations of a mix of aircraft in the local and extended operating areas. 3.3 Justification for an Airspace Change As outlined above, the impact of the Burbo Bank Extension Offshore Wind Farm WTGs on the Warton PSR, giving rise to false radar returns, will have an impact on the provision of radar services in relation to the following four issues: • Test flying control in the vicinity of the L70 Warton fillet; • Services to aircraft under the LARS scheme when aircraft are operating outside CAS; • Approach Control Service; and • RAF Woodvale operations. These areas of concern have led to the requirement to mitigate the effects of the Burbo Bank Extension Offshore Wind Farm WTGs. Figure 2 below shows the extent of the proposed Burbo Bank TMZ, the hatched area within the yellow Burbo Bank Extension area shows the theoretical extent of the related wind turbine generated clutter.

Figure 2 Liverpool Bay and Morecambe Bay Airspace. The proposed TMZ, with section ceilings, is outlined in Green. The Black solid line shows the extended main runway centrelines at Blackpool (20 NM from the TMZ boundary), Warton (20 NM) and RAF Woodvale (6 NM). Reproduced from CAA digital map data © Crown copyright 2014. UK IAIP ENR.

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3.3.1 Flight test operations in the vicinity of the L70 Warton fillet Warton’s coastal location, adjacent to extensive CAS and uncontrolled airspace, makes it an ideal site for testing, research and development of complex military aircraft. The majority of these operations take place offshore over Morecambe Bay and Liverpool Bay. The Ministry of Defence (MoD), in support of front line military aviation operations, and other export customers rely on this operation for the delivery of high specification military capability. The Fast Jet (FJ) military aircraft conducting test and development sorties operate in accordance with predetermined schedules to ensure that appropriate test data is gathered; the test and development aircrew involved rely on Warton ATC to provide a range of air traffic services.

Figure 3 Liverpool Bay and Morecambe Bay Airspace with the Warton Fillet outlined in Orange and the southern boundary of the Warton ARA outlined in Purple. Reproduced from CAA digital map data © Crown copyright 2014. UK IAIP ENR.

The Warton Advisory Radio Area (ARA) incorporates the Morecambe and Liverpool Bay areas and is notified airspace extending from FL95 (9,500 feet (ft)) to FL190 (19,000 ft). Within the ARA all pilots are advised to make radio contact with Warton ATC in order to receive up to date information on other traffic operating in the area. The ‘Warton Fillet’ (see Figure 3) is a portion of airspace encompassed by and on the southern boundary of the Warton ARA and within airway L70 (normally Class C (CAS), from FL85 (8,500 ft) to FL195 (19,500 ft)). When operating as L70 CAS, control services within the Warton Fillet are provided by National Air Traffic

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Services (NATS)3. However, when required by Warton ATC, the Warton Fillet can be activated and control services revert to Warton ATC (‘claw back’) to support test- flying activities whilst that portion of airway L70 is not used by Commercial Air Traffic (CAT). This happens, as an average, on twenty occasions each month (for periods of 2 – 6 hours) and the robust airspace sharing agreement enables the airspace classification in the Fillet to revert to Class G (uncontrolled airspace), which allows Warton ATC to have efficient and flexible tactical freedom for aircraft manoeuvres close to Warton and in the airspace above Liverpool Bay. The Burbo Bank Extension Offshore Wind Farm boundary lays 3.7 km (2 NM) to the south of the Warton Fillet. Class G airspace is uncontrolled in that any aircraft may use the airspace under the Air Navigation Order and the Regulations (ANO) CAP 393 [Ref 3] and although an ATS may be available, it is not mandated; Military and General Aviation use large portions of Class G airspace below FL195 (19,500 ft) extensively. The service provided by Warton controllers to test and evaluation pilots in Class G airspace, aimed at achieving notified deconfliction minima from other traffic in Class G airspace, is a Deconfliction Service (DS). In Class G airspace, the avoidance of other traffic is ultimately the pilot’s responsibility. However, under DS the controller provides the pilot with specific surveillance-derived traffic information and issues advisory headings and/or levels aimed at achieving the required deconfliction minima. The deconfliction minima required against unknown or unco-ordinated traffic, or unknown radar returns (like wind turbine generated returns) are: • 9.3 km (5 NM) laterally (subject to surveillance capability and regulatory approval); or • 3,000 ft vertically and, unless the Secondary Surveillance Radar (SSR) code indicates that the Mode C data has been verified, the surveillance returns, however presented, should not merge. (Note: Mode C can be assumed to have been verified if it is associated with a deemed validated Mode A code. The Mode C data of aircraft transponding code 0000 is not to be utilised in assessing deconfliction minima). If the Warton radar clutter induced by the Burbo Bank Extension Offshore Wind Farm WTGs is not addressed, Warton ATC will be required to apply 9.27 km (5 NM) between any aircraft in receipt of a DS and any unknown or false returns from the wind turbines, which could render the southern half of the Warton Fillet unusable for military test flying operations. In summary, degradation of detection and tracking capabilities of the Warton radar in the area of Burbo Bank Extension Offshore Wind Farm is of particular importance. Habitually reduced ATS from Warton ATC in the area of the Burbo Bank Extension Offshore Wind Farm would effectively render the southern half of the ‘Warton Fillet’ unusable. This would represent a significant reduction in the size of the Warton ARA airspace available for critical flight test activities. Other airspace users requiring a service from Warton ATC may also experience disruption due to unnecessary route deviation.

3 NATS, the en-route provider of ATS in CAS.

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3.3.2 LARS provision Warton ATC provides a LARS for the purpose of ensuring participating pilots are aware of other nearby aircraft and/or flying activities, thereby enhancing flight safety in the area. This service is available to any aircraft operating outside CAS, from ground level up to 10,000 ft, within a 74 km (40 NM) radius of Warton. The Warton LARS is active between the hours of 0730 and 1900 (Mon-Thu), 0730 and 1700 (Fri); which is coincidental with the operating hours of Warton Aerodrome. LARS is regarded as a very important scheme, which is sponsored by the Department for Transport (DfT) and is determined by the CAA Safety and Airspace Regulation Group (SARG) as key to enhancing the effectiveness and efficiency of the airspace in an area that can be busy with a mixture of aviation activities. A recent LARS review by DfT recognised Warton’s key role as a provider of LARS in the North West of England. The service would necessarily be reduced or terminated near Burbo Bank Extension Offshore Wind Farm if the radar returns from the WTGs were not mitigated. 3.3.3 Approach Control Service The airspace around Warton is considered to be of medium complexity in that it is surrounded by areas of open (Class G) airspace, particularly to the west and northwest, but is bounded closely by CAS to the south and east. Warton ATC is responsible for providing services to aircraft arriving at and departing from Warton, as well as local air traffic and military aircraft involved in complex test and development flights. Warton ATC, in accordance with CAP 393 [Ref 3] provides an approach control service to aircraft operating from the aerodrome. Warton is also the approach control unit for Barrow/Walney Island and has a Letter of Agreement (LoA) with Blackpool International Airport (BIA) to cater for seamless ATS provision in the event of BIA PSR failure. Aircraft routing via the Wallasey VOR (WAL) to or from Warton, Barrow/Walney Island or BIA will leave, or join, CAS 3.7 km (2 NM) north of the Burbo Bank Extension Wind Farm when the Warton Fillet is active, as the airspace is rendered Class G on the twenty occasions each month when under Warton’s control (‘clawed back’). In this airspace configuration these aircraft would require a robust ATS from Warton ATC which could be compromised by the presence of false radar returns from the WTGs in the area. 3.3.4 RAF Woodvale operations The Royal Air Force (RAF) operates Grob 115E Tutor aircraft from Woodvale aerodrome as part of the Liverpool, Manchester and Salford University Air Squadrons (UAS). The Air Experience Flight also operates from Woodvale, providing flying experience and pilot training for Air Cadets in the North West Region. Furthermore, the Volunteer Gliding Squadron (VGS) operates Grob 109B Vigilant motorgliders from the airfield. As part of a LoA with the RAF, Warton ATC will provide, where controller workload permits, an air traffic service to any of the aircraft operating from RAF Woodvale. RAF Woodvale can also request, through Warton ATC, to activate (‘claw back’) the Warton Fillet in support of their own flying activities.

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A LoA was established with Warton to provide Air Traffic Services Outside Controlled Airspace (ATSOCAS) as No 22 Group (controlling authority for Grob Tutor aircraft) mandated AEF and UAS pilots to maintain a radar service during flying operations, following the recommendation from the Air Accident Investigation Board (AAIB) Accident Report 6/20104. RAF Woodvale therefore only operates in the Liverpool Bay area during the hours of LARS provision from Warton ATC. In summary, if unmitigated, the radar returns from the Burbo Bank Extension Offshore Wind Farm WTGs will limit the airspace available for use by pilots operating out of RAF Woodvale.

4 Mid-air collision between two AEF Grob 115E Tutor aircraft in 2009.

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4 Proposed Design

Warton’s preferred solution is to establish a TMZ with associated PSR suppression of return around the operational and extension wind farms up to the base of CAS within the Warton LARS provision times.

4.1 Overview DONG has considered a variety of design options in their aim to provide sufficient mitigation, whilst meeting the needs of Warton and all other aviation and non- aviation stakeholders. The following mitigation design options were considered: • Do nothing; • Implement a PSR solution; • Implement a Radio Mandatory Zone (RMZ); • Conduct SSR only operations; • Implement PSR blanking or a Non-Automatic Initiation Zone (NAIZ) only; or • Implement a TMZ with associated SSR-only operations and PSR suppression of returns. This section provides details of the design options considered, along with results of the extensive evaluation of each. 4.2 Option 0 – Do nothing If no mitigating actions are taken for the impact of the Burbo Bank Extension Offshore Wind Farm wind turbines on the Warton PSR, air traffic services provided by Warton ATC utilising the PSR would be impacted. Wind turbines located within PSR coverage can reduce the ability of the radar to detect aircraft, and ATC to differentiate between a wind turbine return and a radar return from an aircraft. The effects are well documented and are detailed within CAP 764 (CAA Policy and Guidelines on Wind Turbines) [Ref 4]. 4.3 Option 1 – A PSR solution Warton operates a Selex ES ATCR-44 ATC PSR, which is complimented by a co- mounted Mode S SSR, and SSR data from NATS radars at Clee Hill and Lowther Hill. DONG and Warton have held discussions with Selex ES, the PSR Design Authority, to investigate if there are approved methods in which the PSR could be modified to enable Warton to continue to provide an ATS using the PSR in the region of the Burbo Bank Extension Offshore Wind Farm wind turbines. As yet there is no radar mitigation solution that eliminates clutter generated by WTGs that provides a high degree of confidence of success in every case. There are

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several technologies in an advanced stage of development, but yet to achieve regulatory approval. DONG, Warton and the Defence Infrastructure Organisation (DIO) who safeguard operations at BAES Warton require a high degree of certainty of a successful mitigation, which is not currently available for a technical PSR solution. 4.4 Option 2 – Radio Mandatory Zone (RMZ) A Radio Mandatory Zone (RMZ) would require aircraft to be in two-way communication with ATC and provide information pertinent to the flight prior to entering the designated airspace. Although ATC would be able to provide some level of service to traffic in the area, it would not prevent wind turbine generated radar returns from being displayed on the radar display, with the effect of limiting service provision as outlined previously and requiring the re-routing of aircraft under DS around the clutter. An RMZ also permits access to aircraft that are not transponder equipped. This makes it difficult to identify them and maintain track identity for the purposes of providing traffic information and separation. Warton has rejected this option as it provides insufficient mitigation. 4.5 Option 3 – Secondary Surveillance Radar (SSR)-only The sole reliance and use of this surveillance technique, without appropriate airspace use rules in place, is not approved in the UK due to busy approach environments. However, due to the ‘small’ area of the Burbo Bank Offshore Wind Farms, it may be justifiable to use SSR-only to maintain the identity of an aircraft as it transits through the wind turbine development. Warton has rejected this option alone as it does not solve the problem of being able to distinguish between primary radar returns created by the turbines and those created by non-transponding aircraft. Simply providing a service using SSR only does not prevent non-transponder equipped aircraft from entering the airspace and therefore safety could be compromised as a result of the inability to identify, track and provide separation from those aircraft. 4.6 Option 4 – Primary Surveillance Radar (PSR) blanking or Non-Auto Initiation Zone (NAIZ) only PSR blanking involves the deliberate masking of fixed areas on the radar display. This ensures that clutter caused by a wind turbine development is not presented to the controller. The potential drawback of this option is that in addition to WTG clutter, primary radar returns from legitimate aircraft are also blanked and therefore not presented to the air traffic controller. Clutter effects can be limited by establishing NAIZ in which new tracks are prevented from initiating, whilst mature tracks are maintained and updated. A NAIZ placed over the location of a WTG development ensures that turbine blades do not create false tracks, but established aircraft tracks entering the location continue to be updated. Despite WTG returns being inhibited, there is potential for the PSR processing to confuse the two returns, and switch the association of the established aircraft track from its real radar response to that of the WTG response. Switching of track association presents false information to the air traffic controller and may cause risk

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to flight safety. Moreover, a NAIZ cannot identify the source of new potential tracks within the zone, and so will not enable initiation of a track on a radar response caused by an actual aircraft whose radar responses have only just begun to be received by the radar (i.e. climbing out of low level) before it enters the wind farm. Warton has rejected this option as it provides insufficient mitigation. 4.7 Option 5 – A Transponder Mandatory Zone (TMZ) with associated PSR Suppression Techniques The proposed establishment of the TMZ is one element of a 3-part Mitigation Package aimed at negating the impact of the clutter from the Burbo Bank Extension Offshore Wind Farm WTGs upon the Warton PSR. The three parts are: • Element 1: Establishment of a TMZ; • Element 2: Authorisation to control SSR-only and; • Element 3: Suppression of PSR returns within the boundary of the Wind Farms. The proposed solution provides Warton ATC with assured positional identification and Commercial Air Traffic (CAT) operators with collision avoidance mitigation through the cooperative use of ACAS. It will also maintain current effectiveness and efficiency in the airspace while radar services are provided using SSR data-only in the area of the Burbo Bank Wind Farms. Figure 2 (section 3.3) illustrates the airspace above the Burbo Bank Operational and Burbo Bank Extension Offshore Wind Farms. Class G airspace is ‘stepped’ from 2,000 ft to FL45 (approximately 4,500 ft) and the Burbo Bank Offshore Wind Farms extend beyond the confines of the Manchester Terminal Manoeuvring Area (TMA) and Liverpool Control Area (CTA). The primary determining features for the TMZ would be: • The location of the current operational turbines (Burbo Bank Offshore Wind Farm); • The location of the planned extension turbines (Burbo Bank Extension Offshore Wind Farm); • The tracking characteristics of the Warton PSR; • The base of CAS above the Wind Farms; • The presentation of the TMZ to pilots (i.e. how it is portrayed on the charts); • Proximity to the coastline; and • Proximity to the Liverpool John Lennon Airport (LJLA) CTA. 4.8 The Proposed TMZ The overall aim of the Burbo Bank Airspace Change Proposal is to maintain airspace efficiency and effectiveness for all users and mitigate the impacts of Burbo Bank Extension Offshore Wind Farm on Warton flying and ATS operations. The CAA, in CAP 725 [Ref 1], lays down extensive regulatory requirements to be applied to the design of the airspace arrangements. However, most of these requirements, such as Instrument Flight Procedure (IFP) containment, are relevant

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to the development of CAS, which is not the case with this TMZ proposal. The significant regulatory requirements applicable to this proposal are that the: • Dimensions of the proposed airspace should be the minimum practicable to meet the safety and operational requirements; and • Configuration of the airspace should be as simple as practicable. Thus, the primary matters for consideration in the development of the proposed TMZ are the lateral and vertical dimensions, including alignment with other, pre-existing, airspace boundaries and the impact on: • Those aircraft wishing to use the airspace which are not and/or cannot be equipped with a transponder; and • The operational impact on adjacent Air Traffic Service Units (ATSU) who may not be SSR equipped. The proposed solution provides Warton ATC with an informed traffic environment where each aircraft can be identified and monitored for the purpose of providing separation and traffic information. Any unknown targets that are presented without a corresponding SSR return can be assumed to be either spurious or created by the turbines. This provides the assurance that any aircraft that are in receipt of a service within the TMZ can be positively identified and the appropriate separation can be provided between aircraft. This enhances safety since it removes any doubt that unknown primary only returns created by the turbines are assured to be turbine returns and not unknown aircraft. Warton’s preferred solution is to establish a TMZ, with associated suppression of PSR returns within the boundary of the Wind Farms, around the operational and extension wind farms up to the base of CAS within the Warton LARS provision times. The development of this option for the configuration of Transponder Mandatory Airspace is detailed in the subsequent Section of this document. 4.8.1 TMZ horizontal buffer zone In order to assure effective and expeditious ATS provision within and around the TMZ, it is considered that an additional lateral buffer for ATS purposes is necessary to mitigate any potential navigation error that could occur close to the area of PSR return suppression. Such a buffer zone would provide time for ATC to provide avoiding action to other aircraft close to the boundary of the TMZ, if required. Thus, it is concluded that an additional volume of airspace should be added to the surface footprint of the Wind Farms themselves to cater for TMZ infringements. The Warton PSR requires 30 seconds to establish and display an aircraft track (6s per sweep with the track displayed on the 5th sweep). Considering the worst case scenario, where Class G General Air Traffic (GAT) can travel up to speeds of 250 knots (kts) (4 NM/min), the Warton radar would require 3.7 km (2 NM) to create a coherent foreground track. It is therefore logical to implement a 3.7 km (2 NM) lateral buffer zone around the required TMZ over the wind farms, in order to ensure that tracks are well initiated and known to ATC as they in close proximity to the zone. Due to the proximity of the existing Burbo Bank Offshore Wind Farm to its extension, the TMZ would encompass both Wind Farms. This would avoid issues with visual confusion from the air, difficulty in navigation chart interpretation and visual depiction on ATC video display screens.

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Figure 4 below illustrates the airspace at Liverpool Bay and Morecambe Bay, and the proposed TMZ in relation to the Burbo Bank Offshore Wind Farms.

Figure 4 Burbo Bank Proposed TMZ including 2 NM Buffer Zone. Reproduced from CAA digital map data © Crown copyright 2014. UK IAIP ENR.

By way of comparison to other offshore wind farm mitigations, the TMZs around the London Array and Thanet Offshore Wind Farms, administered by Manston ATC, also have buffer zones of 3.7 km (2 NM). 4.8.2 Vertical extent of the TMZ It is proposed that the TMZ should extend from sea level up to the base of CAS above the Burbo Bank Offshore Wind Farms, since transponder carriage within the CAS above is already mandated. The ceiling (or top altitude) of the proposed TMZ is shown in Figure 2 (section 3.3). The co-ordinates for the five corners of the Burbo Bank Offshore Wind Farm TMZ (with buffer zone) are given in Annex A2, together with the proximity of the TMZ to military and civilian aerodromes. 4.8.3 Hours of operation of the TMZ Under normal UK Integrated Aeronautical Information Package (IAIP) arrangements, the operating hours of a particular airspace segment established for ATS purposes are linked to the operating hours of the associated ATS Unit. Hence, DONG and Warton propose that Warton ATC is the TMZ Control Authority and TMZ activation coincides with the Warton LARS hours (Mon-Thu 0730-1900; Fri 0730-1700 Local Time). The information will be captured within the UK IAIP, noting the LARS

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frequency and timings as well as the boundary of the TMZ, and associated CAA Visual Flight Rules (VFR) Charts. Warton propose that exceptions to this are promulgated by Notices to Airmen (NOTAM)5.

5 NOTAMs cover short duration or temporary changes or short notice permanent changes. They contain information concerning the establishment, condition or change in any aeronautical facility, service, procedure or hazard, the timely knowledge of which is essential to personnel concerned with flight operations.

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5 Impact of the Proposed TMZ

The overall aim of the Burbo Bank Airspace Change Proposal is to maintain airspace efficiency and effectiveness for all users whilst mitigating the impacts of the Burbo Bank Extension Offshore Wind Farm on Warton flying and ATS operations.

5.1 Overview A potential drawback of establishing a TMZ is that non-transponding aircraft may choose to take an alternative route in order to ‘bypass’ the TMZ, resulting in a change in traffic patterns and ATC workload in this area. This would only reasonably occur when aircraft have been unable to establish two-way radio communications with Warton ATC, the TMZ Controlling Authority. 5.2 Impact of the TMZ on military operations No impact on military operations has been identified since the majority of UK and European-based military aircraft carry and operate SSR transponders, and in most cases, these are Mode S compatible. The only UK military aircraft types that are not transponder equipped are gliders. It is considered that military gliders are unlikely to operate as far offshore as the Burbo Bank Offshore Wind Farms and so would be unaffected by the TMZ requirements. 5.3 Impact of the TMZ on light GA operations All aircraft operating on Public Transport flights within UK airspace are required to be equipped with, as a minimum, Mode S Elementary transponders. It can be assumed that the majority of General Aviation (GA) aircraft over 5,700 kg Maximum Total Weight Authorised (MTWA) are likely to be transponder equipped: such aircraft types, which can be used for public transport operations, are likely to operate from time to time within Class A, C or D CAS (where carriage of transponders is mandatory). Whilst not prohibited from operating over water, the majority of pilots of light aircraft (sports and recreation) prefer to minimise their over-water flight time by using routes that route predominantly overland and require them to be over water for as short a period as practicable. Warton and LJLA ATC note that the majority of GA operating around the periphery of Liverpool Bay operate SSR transponders and follow the coastlines applying the Right-Hand Traffic Rule 196 (this is confirmed by a

6 CAP 393 [Ref 3]. Air Navigation: The Order and the Regulations (ANO).

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survey7 of traffic behaviour near the Burbo Bank). A pilot following a line feature (a

Controlrailway, Uni road,t. Thisriver rule or coastline ensures separationetc.) must fly between so that two the aircraftline feature following is on his the LEFT, same unless the aircraft is flying in CAS and has been instructed otherwise by an Air Traffic of the line feature. line feature but flying in opposite directions as both aircraft will be flying to the right Notwithstanding the transponder mandate within a TMZ, provision exists within the TMZ Rules for conditional access by non-equipped aircraft by prior arrangement, establishing two-way radio contact, with the appropriate ATSU (Controlling Authority), in this case Warton ATC. The recent traffic surveys, each of one month’s duration, undertaken at Warton of movements in and around the area of the proposed TMZ demonstrate that the large majority8 of GA (sports and recreational) aircraft were transponder equipped. Conditional access to the TMZ airspace by non-transponder equipped aircraft is available by radio and it is anticipated that the impact of a TMZ on light GA operations, including glider, microlight and balloon operations, would be minimal as these types are unlikely to be operating far offshore. Any refusal for access, issued by Warton ATC, will only occur when a particularly complex trial or evaluation mission is reaching completion near or within the geographical confines of the proposed TMZ. 5.4 Impact of the TMZ on offshore helicopter operations As outlined in Section 5.3 above, aircraft likely to be affected by the proposed TMZ are those with an MTWA of less than 5,700 kg, as above this weight the aircraft are likely to be used for public transport operations and therefore transponder equipped. Offshore helicopter types are categorised into the following MTWA groups: • Extra Heavy Twin >20,000 kg (e.g. Chinook); • Heavy Twin >5,700 kg (e.g. Bell 214ST, Super Puma, EC225, S61 and S92); • Medium Twin 2,730 to 5,700 kg (e.g. Dauphin, EC155, S75 and AW139); and • Light Twin <2,730 kg (e.g. Bo105). The helicopters operated by Bond Offshore Helicopters in the Burbo Bank area are Medium Twin aircraft equipped with a transponder. Light Twin helicopters are unlikely to operate with regularity in the area of the Wind Farms. There is a regular, daily return air taxi flight by a light helicopter (captured in the air traffic survey) between Andreas Aerodrome (on the north of the Isle of Man) and Chorley, Lancashire that transits close to the Burbo Bank area. This flight will be unaffected as it carries both a transponder and radio.

7 Confirmed by the Warton air traffic surveys. 8 Only one aircraft movement of over 200 in the proposed TMZ area was not transponder equipped.

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6 Environmental and Economic Considerations of a TMZ

Overall, it is anticipated that the environmental impact of the Burbo Bank TMZ will be neutral within the three major categories of noise, fuel burn and local air quality.

6.1 Overview This section discusses the effects of the proposed airspace change on the environment in terms of noise pollution, fuel burn and local air quality. In any airspace decision-making, the CAA must consider the environmental impact of aviation and the disturbance caused to the public. The airspace within which the introduction of a TMZ is proposed lies offshore and is in Class G airspace and lies greater than 1.9 km (1 NM) from the North Wales and Wirral coastlines. Notwithstanding that the proposed TMZ airspace is not CAS, and no aircraft operations are excluded from it, it is possible nonetheless that some GA operators might elect to route on or closer to shore to avoid the TMZ requirements rather than routing offshore through the TMZ. Airspace activity in Class G airspace is not routinely monitored. However, the two individual surveys of one month duration each confirmed that the large majority of transit GA (Sports and Recreation included) in the Burbo Bank Offshore Wind Farms area remain close (within 1.9 km (1 NM)) to the coastlines. Furthermore, observed traffic farther offshore is transponder equipped and usually in two-way radio contact with BIA, LJLA or BAES Warton ATC. Therefore, it is anticipated that there will be little, if any, traffic displacement due to the proposed Burbo TMZ inhibiting GA flight operations. 6.2 Impact of noise It is expected that the noise impact after TMZ implementation is insignificant due to the offshore location of the proposed TMZ and the little, if any, traffic displacement different from the pre-implementation situation.

6.3 Anticipated level of fuel burn/CO2 emissions

It is recognised that aircraft contribute to carbon dioxide (CO2) emissions and this has an impact on climate change. Access to the activated TMZ airspace (Mon-Thu 0730-1900 Local; Fri 0730-1700 Local Time) will be available wherever practicably possible, little, if any, traffic displacement or re-routing is anticipated and any re- route taken is likely to be insignificant. No re-routing will be required outside the

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TMZ activation times. This airspace proposal ensures sustainability of the efficient routing of aircraft. 6.4 Anticipated effect on local air quality CAP 725 [Ref 1], Appendix B, Annex 8 identifies that local air quality at ground level remains largely unaffected by aircraft emissions that take place above 3,000 ft above ground level (agl) because dispersion reduces concentration levels for these emissions. It is understood that in the context of local air quality, the overall objective under CAP 725 is to determine whether the proposed airspace changes will exceed any statutory air quality standards, and if so, what contribution the airport operations make towards such departures. The proposed TMZ lies offshore and it is not anticipated that Air Quality Standards will be breached. 6.5 Environmental implications Overall, it is anticipated that the environmental impact of a Burbo TMZ will be neutral, or at worst insignificant, within the three major categories of noise, fuel burn and local air quality because of the proposed airspace change. It is not anticipated that the Burbo TMZ will reduce the environmental impact of aviation in the subject airspace; however, it is reasonable to expect that the environmental impact of aviation in the subject airspace will not worsen because of the change. Both tranquillity and visual intrusion are unlikely to be impacted by any GA displacement and, in the worst case, the numbers of those negatively affected are not likely to increase significantly upon implementation.

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7 Consultation Response Analysis

The Burbo Bank TMZ consultation invitations were circulated to a total of 105 stakeholder consultee organisations or individuals. Twenty-three responses to this consultation were received. Of these, seven supported the proposal, 14 provided a neutral response and one objected to the proposal.

7.1 Overview This section summarises the aim of the consultation exercise, describes the categories of consultee organisations and individuals that were consulted and provides a breakdown of the responses received. It also explores the support ratio of consultee responses received to give a general indication of stakeholder acceptance of this proposal. 7.2 Consultation summary The purpose of this consultation was to gather and analyse the views of the various stakeholders concerning a proposal to establish a TMZ over the existing Burbo Bank Offshore Wind Farm and the Burbo Bank Extension Offshore Wind Farm in the Liverpool Bay. Fundamentally, the consultation has enabled DONG to obtain or confirm views and opinions about the impact of the proposed airspace change. The proposed establishment of the TMZ is one element of a three-part Mitigation Package aimed at negating the impact of the clutter from the Burbo Bank Extension Offshore Wind Farm WTGs upon the Warton PSR. The three parts are: • Element 1: Establishment of a TMZ; • Element 2: Authorisation to control SSR-only and; • Element 3: Suppression of PSR returns within the boundary of the Wind Farms. Such an airspace change is necessary in order to mitigate the effects of the wind turbines on the Warton PSR. This will ensure that a full suite of ATSOCAS can continue to be provided, whilst maintaining the current levels of airspace effectiveness and efficiency in this area. This aim of the consultation was not about facilitating a change in routine air traffic procedures at local aerodromes. The background to this consultation and the methodology used are detailed in Annex A3 to this document.

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7.3 Consultee organisations The Burbo Bank TMZ consultation invitations were circulated to a total of 1059 stakeholder consultee organisations or individuals detailed in Annex A4 and comprising: • 38 Aviation “National Organisations” (CAA NATMAC list); • 1 Aviation Association; • 10 Local Aerodromes/Aviation Consultees; • 9 Members of Parliament; • 31 Council Wards and Local Authorities; • 10 Town/Parish Councils; and • 6 Local/National Environmental Organisations. The consultation document was distributed via a dedicated link on the DONG website and by email to all consultees. During the consultation period, the website10 link was visited more than 500 times. Consultees broadly fall into two categories: • Aviation consultees; and • Non-aviation consultees. Aviation consultees included aviation parties such as the MoD, airlines, aircraft operators, adjacent aerodromes, all local airspace users and the national bodies representing all UK aviation interests that may be affected by the regulatory requirements within the TMZ. National bodies such as LAA, BALPA, AOA etc. are represented through the auspices of the National Air Traffic Management Advisory Committee (NATMAC), sponsored by the CAA. A number of military organisations are also members of the NATMAC. Non-aviation stakeholders for consultation included environmental and heritage organisations, local planning authorities and the general public. Although the proposed change to the airspace lies offshore, and there are no changes to the way aircraft operate over land, the neighbouring coastal districts and parish councils were also consulted. The consultee groups are detailed in Figure 5 below.

9 It should be noted that NATMAC comprises a total of 38 organisations, represented by 48 individuals. The consultation document was circulated to each individual. However, this analysis reflects the views of the organisations as a whole and not of the individuals representing them. In some cases it was found that representation had changed from the list provided by the CAA. 10 http://www.burbobankextension.co.uk/en/application-for-consents/consultation-for-transponder- mandatory-zone-(tmz)

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Figure 5 Distribution of Consultees.

7.4 Responses A total of 23 responses (approximately 22% of consultees) to this consultation were received. A breakdown of these is provided in Table 1 and Figure 6 below.

Number Consultee Groups Responses % Consulted

1 NATMAC (Civil) 33 8 24.24

2 NATMAC (Military) 5 2 40.00

3 Aviation Associations 1 0 0

4 Local Aerodromes/Aviation Consultees 10 9 90.00

5 MPs 9 0 0

6 Council Wards & Local Authorities 31 3 9.68

7 Parish Councils 10 0 0

8 Environmental Organisations 6 0 0

9 Individuals N/A 1 N/A

Totals 105 23 21.90%

Table 1 Responses from Consultees.

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Figure 6 Responses from Listed Consultees.

It should be noted that “NATMAC (Civil)” and “NATMAC (Military)” comprise those organisations who are members of the CAA’s NATMAC. The NATMAC consultee list includes some CAA Departments who, for reasons of CAA impartiality, do not respond to consultations. 7.4.1 Objection(s) The Light Aircraft Association (LAA) reject the arguments and oppose the proposal to establish a substantial TMZ in association with the Burbo Bank Development. This objection is on the basis that the chosen solution would disbenefit GA operations, but have minimum cost to DONG. The LAA reflects the views of some 8000 members who own and operate some 4000 aircraft which the association oversees on behalf of the UK CAA. The LAA acknowledges that there is no great volume of non- transponder traffic through the area11. However, they state that the TMZ will lie on a route that is important because the Liverpool/Manchester area is difficult to cross VFR and they expect that to become more difficult as the TC North Project develops in the next few years. 7.4.2 Irish Sea Concerns The Isle of Man Airport (IoMA) accepts that the proposed Burbo Bank TMZ is on the limits of both surveillance cover and IoMA service provision. However, IoMA has concerns over the cumulative effect of wind farm development in the Irish Sea and the use of TMZs as mitigation. IoMA also has concerns in general with the concept of declaring a TMZ active only during the notified hours of a particular Air Traffic Service Unit (ATSU). The IoMA states that’s its response to this consultation is to

11 Confirmed by the Warton air traffic surveys.

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highlight the cumulative effect of wind farm development in the Irish Sea and raise the issue of the possibility of multiple TMZs within the Irish Sea. 7.5 Meetings with Major Stakeholders Prior to the commencement of the consultation period, a number of meetings were held with some of the major stakeholders. Although most of these organisations had been contacted during the initial requirements capture phase, the purpose of these meetings was to present the detail that would be incorporated into the Consultation Document to ensure there were no surprises for stakeholders when it came to formal comment. Consultation meetings were organised with the following stakeholders: • LJLA; • Bond Offshore Helicopters, BIA; and • Caernarfon Aerodrome. 7.5.1 Local International Airports LPJL is supportive of the Burbo Bank TMZ proposal. BIA has no objection to the Burbo Bank TMZ proposal. 7.6 Consultation Results Of the 23 responses received from the consultee organisations: • 7 consultees (30.4%) supported the proposal to establish a TMZ over the Burbo Bank Offshore Wind Farms; • 1 consultees (4.4%), the LAA, objected to the proposal; and • 14 consultees (60.9%) provided a neutral response, whereby the consultee did not object or provided no comments on the proposal.

Figure 7 Support Ration from Listed Consultees.

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An objection was raised not related to the development of a Burbo Bank TMZ, but to construction of the extension to the Burbo Bank Offshore Wind Farm itself. Such comments have therefore not been included in the analysis. 7.7 Confidentiality All the feedback from the consultation has made available to the CAA as part of the Airspace Change Proposal. This will allow the CAA to assess independently whether the appropriate conclusions have been drawn in the development of the proposed design. Responses will be treated with due care and sensitivity by us and by the CAA. 7.8 Publication Should the CAA, without the need for further design optimisation or analysis, accept the Airspace Change Proposal, DONG suggest that the implementation of the TMZ would take place on a single date to coincide with the full operational date of the Burbo Bank Extension Offshore Wind Farm expected to be in late 2015. DONG proposes to detail the TMZ within the UK Mil AIP Warton AD2 entry, in UK IAIP ENR GEN 1.5 (Aircraft Instruments, Equipment and Flight Documents) and ENR 6.1 (Morecambe Bay/Liverpool Bay Gas Field Helicopter Support Flights). This would serve the purpose of formally notifying the TMZ; the AIRAC date is to be confirmed.

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8 References

Reference Name Origin

1 CAP 725 CAA Guidance on the Application of CAA the Airspace Change Process ISBN 978 0 11790 739 3 Third Edition (corrected) April 2007

2 DAP Policy: Transponder Mandatory Zone CAA (TMZs)

17 April 2009

3 CAP 393 Air Navigation: The Order and the CAA Regulations ISBN 978 0 11792 658 5 Third Edition (incorporating amendments up to 1/2012) 10 August 2012

4 CAP 764 CAA Policy and Guidelines on Wind CAA Turbines ISBN 978 0 11792 634 9

5 CAP 493 Manual of Air Traffic Services CAA (MATS) Part 1 ISBN 978 0 11792 780 3

Table 2 Table of References.

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A1 Burbo Bank Extension Offshore Wind Farm Line of Sight Assessment

A1.1 Overview This Annex contains the results of the radar Line of Sight (LoS) assessment for the Burbo Bank Extension Offshore Wind Farm WTGs in respect of the PSR located at Warton Aerodrome. The analysis was carried out on representative points (labelled 1-6) on the Burbo Bank Extension Offshore Wind Farm boundary, provided at Table 3. A1.2 Boundary Details

Boundary Point Easting/Northing Blade Tip Height (m)

Point 1 313377/397126 223

Point 2 308698/401584 223

Point 3 319176/401373 223

Point 4 318877/400488 223

Point 5 321833/397700 223

Point 6 320677/397014 223

Table 3 Summary of Turbine/Boundary Details.

A1.3 LoS Assessment Methodology Over the distance between a PSR and a wind turbine, radar signal will attenuate (lose power) and be refracted and diffracted (change direction). The likely radar performance characteristics for the assessed radar station were predicted in order to model the radar signal. The intervening terrain and signal path between the assessed radars and the Burbo Bank Extension Offshore Wind Farm development have been modelled using ATDI ICS LT. For LoS analysis, the terrain path has been assessed to determine whether the intervening terrain is likely to be significant enough to prevent the turbines/boundary points being detectable by radar. The direct LoS and the 1st Fresnel zone, an elliptical zone around the direct LoS where the radio waves remain strong, were assessed. Objects that infringe upon the Fresnel zone or the direct LoS will cause the signal to diffract and attenuate. The effect of diffraction means that the direct transmitted radio waves and those in the upper 1st Fresnel zone can still reach the turbine and be returned to the radar receiver, hence why it is not always obvious that terrain shielding is sufficient. LoS diagrams have been produced illustrating the likely detectability of the Burbo Bank Extension Offshore Wind Farm development by the assessed radar stations. Within the

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diagrams (see Figure 8 below), the signal propagation is modelled from the radar (far most left) to the turbine blade tip (far most right). The black line in the diagram with area underneath filled in dark brown represents the terrain profile between the radar and the boundary point. The red line in the diagram represents the direct LoS between the two locations. The orange ellipse around the direct line of sight represents the 1st Fresnel zone. The light blue and magenta lines are not relevant to this assessment. Although every care has been taken during the line of sight modelling and analysis process, modelling limitations and assumptions obviously lead conclusions to be based on theoretical results. The results are therefore indicative, and actual radar performance may differ from this analysis. A1.4 LoS Assessment Results The LoS assessment has been carried out based on six boundary locations and a tip height of 223 m above mean sea level (amsl). Osprey concludes that all of the Burbo Bank Extension Offshore Wind Farm boundary points are highly likely to be detected by the radar: direct line of sight exists between the radar and the wind turbine/boundary point.

Radar Station Approx. Range to Burbo Bank Assessment Result Extension Offshore Wind Farm Boundary (km / NM)

Warton (PSR) 34 km / 18.3 NM Yes (for all points)

Table 4 Summary of Turbine/Boundary Detection.

Figure 8 shows the LoS profile between the Warton PSR and Point 1, the closest point to the Warton PSR. This result is indicative of that for all Points assessed; all locations are highly likely to be detected by the Warton PSR at a height of 223 m amsl.

Figure 8 LoS Profile between Warton (PSR) and Point 1.

A1.5 Conclusion In conclusion, assessed with reference to a blade tip height of 223 m amsl, the boundary points for the Burbo Bank Extension Offshore Wind Farm are highly likely to be detected by the PSR at Warton Aerodrome due to the lack of intervening terrain that exists between the radar and the proposed development.

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A2 Proposed TMZ Co-ordinates

The co-ordinates for the five corners of the proposed Burbo Bank Offshore Wind Farm TMZ are given in Table 5 Burbo Bank TMZ Co-ordinates. below. These co-ordinates provide for a TMZ directly above the Wind Farm and a 3.7 km (2 NM) buffer surrounding the WTGs.

WGS84 Point Latitude Longitude

A N53 32 15.8 W003 30 59.2

B N53 32 11.4 W003 09 48.2

C N53 28 44.8 W003 04 05.1

D N53 25 50.0 W003 10 30.2

E N53 25 49.2 W003 20 46.2

Table 5 Burbo Bank TMZ Co-ordinates.

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A3 Consultation Background and Methodology

A3.1 Background to the Consultation DONG, as the sponsor of the proposed airspace change, is required to submit a case to the Civil Aviation Authority (CAA) to justify the change in airspace over the Burbo Bank Offshore Wind Farms. Also, as part of the CAA’s ACP, it is DONG’s responsibility to consult with all relevant stakeholders who may be directly or indirectly affected by the proposal. A3.2 Method of Consultation The Burbo Bank TMZ consultation was conducted in accordance with the principles set out in the Cabinet Office Code of Practice on Consultation12, as required by the CAA. A comprehensive Consultation Document, approved by SARG, was prepared by Osprey on behalf of DONG. Full details of the proposed change, including rationale, perceived impacts and the mitigation measures undertaken by DONG and Warton, were provided in the Consultation Document. A link to the Consultation Document was made available on the DONG website13. All consultees were notified by email detailing the consultation and how to access the Consultation Document. Local aviation stakeholders were engaged at an early stage during the design process. Prior to the preparation of the Consultation Document, meetings were conducted with the following major stakeholders: • LJLA; • Bond (helicopter operators to the Liverpool and Morecambe Bay gas fields and the Search and Rescue helicopter based at Caernarfon Aerodrome); and • Caernarfon Aerodrome (Bangor). The primary purpose of these meetings was to present the detail that will be incorporated into the Consultation Document to ensure there are no surprises for stakeholders when it comes to formal comment. Full consultation commenced with wide circulation of the electronic Consultation Document to all identified stakeholders on 31st March 2014 on completion of the design process and environmental studies. The consultation process was planned to run until 29th June 2014 - a period of 13 weeks. This allowed a minimum of twelve weeks required for formal

12 https://www.gov.uk/government/publications/consultation-principles-guidance 13 http://www.burbobankextension.co.uk/en/application-for-consents/consultation-for-transponder- mandatory-zone-(tmz)

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consultation14, recognised the number of Public Holidays during the period and provided scope for any unforeseen delays at the start, or any significant issues that may arise during the process. Due to some technical issues with the DONG consultation website, stakeholders were unable to access the consultation document in late June 2014 for a period of four days. The consultation period was consequently extended to 4th July 2014, lengthening the duration of the consultation to 14 weeks. Consultees were asked to consider the proposal and submit a response to DONG in writing or through a dedicated email address ([email protected]). In order to promote maximum response, two reminder emails were sent to those consultees who had not yet provided a response to date. The first email reminder was sent, on 19th May 2014 (more than one month before the end of the consultation period), to all consultees listed at Annex A4 who had not responded by that date. A second email reminder followed on 17th June 2014 to only the Aviation Stakeholders (NATMAC) who had not responded by that date.

14 The Cabinet Office Code of Practice on Consultation and the CAA requirements specify a minimum period of 12 weeks for consultation.

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A4 Stakeholder / Consultee List

A4.1 Aviation Consultees

National Organisations (NATMAC)

Consultation Also known As

Aircraft Owners and Pilots Association AOPA UK

Airport Operators Association AOA

Aviation Division Navy Command Headquarters NCHQ

Aviation Environment Federation AEF

BAESystems Warton BAES

British Air Transport Association BATA

British Airline Pilots’ Association BALPA

British Airports Association BAA

British Airways BA

British Association of Balloon Operators BABO

British Balloon and Airship Club BBAC

British Business and General Aviation Association BBGA

British Gliding Association BGA

British Hang Gliding and Paragliding Association BHPA

British Helicopter Association BHA

British Microlight Aircraft Association BMAA

British Model Flying Association BMFA

British Parachute Association BPA

Civil Aviation Authority CAA SRG

Defence Airspace and Air Traffic Management (incl. the Military User Advisory DAATM (MUACT) Consultative Team)

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Euro UAV Systems Centre Ltd

European Low Fares Airline Association ELFAA

General Aviation Safety Council GASCo

Guild of Air Pilots and Air Navigators GAPAN

Guild of Air Traffic Control Officers GATCO

Headquarters Director Army Aviation HQ DAAvn

Heavy Airlines

Helicopter Club of Great Britain HCGB

Light Aircraft Association LAA

Light Airlines

Low Fares Airlines

Military Aviation Authority MAA

Ministry of Defence MOD

MoD Flight Test Regulator

NATS (NSL) NSL

NATS En-Route Ltd NERL

PPL/IR Europe PPL/IR

The British Business and General Aviation Association BBGA

UK Airprox Board UKAB

UK Flight Safety Committee UKFSC

3 AF-UK/A3

A4.2 Aerodromes / Local Aviation Consultees

Consultee Also known As

Blackpool International Airport EGNH

Bond Offshore Helicopters

Caernarfon Aerodrome Bangor

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Chester Hawarden EGNR

City (Barton) Heliport EGCB Manchester

Ince West Lancashire Microlight

Isle of Man Airport EGNS

Liverpool John Lennon Airport EGGP

Lleweni Parc Airfield Denbigh Gliding

RAF Woodvale EGOW

A4.3 Non-Aviation Consultees: National Bodies

Consultee

Friends of the Earth

A4.4 Non-Aviation Consultees: Regional Council Authorities

Consultee

Liverpool Council

Sefton Council

Wirral Council

A4.5 Non-Aviation Consultees: Council Wards / Local Authorities

Metropolitan Borough of Liverpool

Consultee

Fazakerley

Warbeck

County

Kirkdale

Metropolitan Borough of Sefton

Consultee

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Ainsdale

Birkdale

Blundellgands

Ford

Harrington

Kew

Linacre

Litherland

Meols

Netherton and Orrell

Ravenmeols

Metropolitan Borough of Wirral

Consultee

Bidston and St James

Claughton

Greasby, Frankby and Irby

Heswall

Hoylake and Meols

Leasowe and Moreton East

Liscard

Moreton West and Saughall Massie

New Brighton

Pensby and Thingwall

Seacombe

Wallasey

West Kirby and Thurstaston

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A4.6 Non-Aviation Consultees: Town / Parish Councils

Metropolitan Borough of Sefton in Merseyside

Consultee Town / Parish

Aintree Village

Formby

Hightown / Little Altcar

Ince Blundell

Lydiate

Maghull

Melling

Sefton

Thornton

A4.7 Information Organisations: Members of Parliament

Consultee Constituency

MP Wirral South

MP Wallasey

MP Sefton Central Constituency

MP Wirral West

MP Southport

MP Bootle Constituency

Riverside

MP Birkenhead

Walton

A4.8 Information Organisations: Civil Aviation Authority

Consultee Also known As

Safety and Airspace Regulation Group SARG

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Safety and Airspace Regulation Group (Airspace ATM and Aerodromes) Head of Aerodrome & Air SARG (AAA) Manager Aerodromes Traffic Standards Division

Safety and Airspace Regulation Group Flight Ops SARG Flight Ops Division Division

Safety and Airspace Regulation (Airspace ATM and SARG (AAA) Manager Airspace Regulation Aerodromes) Head of Airspace Regulation

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