Exeter Airport ACP

exeter-acp

Background

Exeter airport has proposed that it should establish a large area of class D controlled airspace (CAS) to replace class G airspace both around its airfield and further afield.

Exeter airport claims that it needs this CAS as it has decided the airport needs a ‘known environment’. The airport claims that the proposed CAS has nothing to do with commercial aspiration. The safety case is based on three no collision risk airprox that occurred in the past 12 months and a similar number in total over the previous 10 years, as well as the subjective views of the airport management.

Exeter airport has engaged Osprey to develop and manage its airspace change plans. Airspace consultants in general are well known across the aviation community for developing airspace change proposals based in part on selective facts and in avoiding what they view as unnecessary consultation. A number of indivudual consultants are former CAA staff with inside knowledge of CAA systems and process. Unfair as that may be, it’s the system we have to deal with.

The volume of class D controlled airspace proposed by Exeter airport and its consultants is huge, dwarfs  most others around a UK airport and in any case far exceeds any real or perceived need. In discussing the subject with Exeter airport, it has become clear that they view the airspace design as, to quote them, ‘a starter for 10’. Exeter airport have claimed that any airspace design changes put to them will be considered. The BGA has developed and is proposing a number of significant changes to Exeter’s airspace design – particularly in the north of the proposed CAS – that should reasonably meet the needs of Exeter airport commercial air transport and all other stakeholders.

The BGA has no objection in principle to the application of CAS in situations where a rational assessment of public risk leads to the requirement for CAS as a logical and proportionate conclusion. However, it is clear that the CAS proposed by Exeter does not meet that criteria. Therefore the BGA objects to the proposed airpace design described in the consultation.

You can view the Exeter airspace change proposal consultation document here.

How you can help

On receipt of comments, ACP proposers are required to summarise feedback and send this to the CAA. We have seen summaries which try to portray numbers of objections as being small even when some responses are on behalf of organisations that represent tens of thousands of members.  To avoid such misrepresentation, it is really important that Exeter airport receive a significant number of responses from opponents to the proposal.

Please make your own thoughts known to Exeter airport. As the consultation document is quite long and detailed, we’ve provided below some headline guidance on the issues.

Please submit your own response to the consultation to the following email address:

acpconsultation@exeter-airport.co.uk

The consultation closes on Friday 9th June 2017 so please make your views known before then.

Headline Guidance

Please don’t cut and paste this detail as in doing so, your response may be ignored by Exeter airport. Please use your own words and thoughts.

There are a number of key themes that the BGA believes help to explain why the airspace design proposed in the Exeter airspace change consultation must be opposed and reconsidered in detail, as described by the BGA in meetings with Exeter airport and in its submission to the consultation. They are:

Safety

  • Soaring pilots generally have to treat CAS as a no-go area. The BGA has explained to Exeter airport why that is the case.
  • If the CAS is implemented as proposed it would force such aircraft to fly at a reduced height compared to that flown historically, thereby reducing safety and likelihood of success (resulting in out landing).
  • The alternative would be to route much further north than historically, into proven poorer soaring conditions and over higher ground, into an area already restricted by the Cardiff CTA, thereby reducing safety margins and the chances of a successful transit.
  • This proposal results in significant safety issues for gliding and other transiting traffic that Exeter has not considered within its proposal.

 Proportionality

  • The area of CAS proposed by Exeter is, by their own admission, based on a line drawn around the areas currently flown over by all traffic that uses Exeter’s services including CAT, General Aviation and RAF Brize Norton-based military traffic carrying out procedural training.
  • It is understood that Exeter utilises procedures that were implemented prior to any need to consult with the public, and that Exeter are keen to avoid a public consultation.Much of Exeter’s traffic doesn’t follow the established procedures.
  • There have been three ‘no risk of collision’ airprox in the vicinity of Exeter in the past 12 months, and a similar number of additional airprox in total in the same area in the previous 10 years.
  • On a number of occasions, controllers have had to direct traffic around potential conflicts, which is presumably the role of an air traffic controller.
  • The existing airspace is, as described by Exeter, tolerably safe and commercial air transport movements are not increasing.
  • Implementing an area of CAS many times larger than that of Gatwick airport is not proportionate to any real or perceived need.
  • Exeter have stated that their principal aim is to create a known environment and yet have chosen to ignore the option of using a Radio Mandatory Zone which would achieve exactly that with least disruption to other airspace users. Instead, the ACP seeks the right of refusal to any transit traffic, which is inherent in Exeter seeking class D airspace, ie the same classification as given to London Heathrow.

Limiting access to gliding and other traffic

  • The proposed CAS will result in a significant reduction in historical freedoms and will damage gliding.
  • Glider cross-country flights are frequently flown in the area covered by the ACP airspace design.  Soaring pilots generally have to treat CAS as a no-go area.
  • As explained above, if the CAS is implemented as proposed it would force such aircraft to fly at a reduced height compared to that flown historically.  The alternative would be to route much further north over higher ground and into an area already restricted by the Cardiff CTA. Use of radio at the same time as soaring makes such flights unworkable.
  • This proposal effectively cuts off the south west to gliding and much of the light end of aviation and is damaging to both to private owners of aircraft and their clubs.

Damage to the Devon and Somerset Gliding Club.

  • DSGC has a long and important history of operating in this region well before Exeter Airport began its gradual commercial expansion.
  • Its operation has been persistently squeezed further north as Exeter Airport has expanded, damaging its ability to fly locally, eroding its freedoms, and threatening its viability. Exeter’s proposals add further severe limitations on its future success.
  • The draft LOA, which is published in the ACP without DSGC’s agreement and certainly not as an agreed document, appears to offer some comfort, but for DSGC traffic only.  However, an LOA has no guarantees and can be removed at a whim.
  • Uncertainty damages any business, and Exeter’s proposals have already introduced significant uncertainty over DSGC’s future. Rather than introduce LOAs to mitigate poor airspace design, the BGA strongly believes that the airspace design should be designed appropriately in the first place.

Damage to freedom of movement for GA traffic.

  • Exeter Airport currently provides a LARS facility for any traffic in the area that prefers to make use of the service. Figures for those choosing to use LARS compared to those who do not have not been made available in the proposal.
  • The culture of controllers is to seek ever-greater control, and this may be a driver in Exeter Airport’s desire to have full control over a significant volume of airspace.  This is contrary to the wishes of the many GA pilots who prefer to choose whether and when to request traffic information from a LARS unit.
  • Introduction of the proposed airspace would damage this freedom significantly, whilst delivering no benefit to GA traffic.

You can view a copy of the BGA response here.