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 Replacement of Class F Airspace in the UK FIRs - Consultation Report 17 April 2014 Replacement of Class F Airspace in the UK FIRs - Consultation Report 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: Replacement of Class F Airspace in the UK FIRs - Consultation Report 17 April 2014 Page 1 of 16 Replacement of Class F Airspace in the UK FIRs - Consultation Report 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 Replacement of Class F Airspace in the UK FIRs - Consultation Report 17 April 2014 Page 2 of 16 Replacement of Class F Airspace in the UK FIRs - Consultation Report 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 Replacement of Class F Airspace in the UK FIRs - Consultation Report 17 April 2014 Page 3 of 16 Replacement of Class F Airspace in the UK FIRs - Consultation Report 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.