TAG/Farnborough ACP

Latest – 14th December 2016

Following the closure of the Additional Consultation on 2nd November 2016 for the TAG Farnborough Airport Airspace Change Proposal, ‘Feedback Report C’ which summarises the responses received and details changes to the airspace design that have been made can be found at www.consultation.tagfarnborough.com

TAG Farnborough has noted that it has requested that the CAA restart the ACP decision process paused on 30 October 2015 with immediate effect.


Latest – 17th October 2016

Please note that the TAG Farnborough additional airspace change consultation closes on the 2nd November.

Responses should be submitted to consultation@tagfarnborough.com with the subject ‘Airspace Consultation’. If you are unable to use email, send a letter to ‘Airspace Consultation, TAG Farnborough Airport, Hampshire, GU14 6XA’

Helpful links:


Update – August 2016

TAG Farnborough Airport has recently commenced an ‘additional consultation’ proposing further controlled airspace in addition to their proposal that was submitted to the CAA in July 2015.

TAG/Farnborough additional consultation

This additional proposal represents a devastating impact on Southdown GC by effectively cutting off that site from gliders returning from the west. Lasham gliders and others using the south east of England will have similar problems. The proposal will also result in significant levels of new noise pollution for villages and towns under revised flightpaths.

The additional proposal does nothing to alleviate our original concerns described below under ‘TAG/Farnborough airspace change proposal’.

If very few responses are submitted to their latest consultation, TAG Farnborough Airport will be able to report that there is very little objection. We strongly recommend that pilots who fly in the south east of England respond individually to the consultation.

The BGA will also be responding to this consultation.


Update – May 2016

On 26th May 2016, the FASVIG published its report on the TAG Farnborough proposals. The detail can be viewed in the BGA news article.


Update – October 2015

On 30 October 2015, the CAA advised TAG Farnborough Airport of its intention to pause the decision process to review certain technical, implementation aspects and airspace sharing arrangements.  TAG Farnborough Airport will advise when the process has resumed.


TAG/Farnborough Airspace Change Proposal

TAG/Farnborough (TAG) operates business jets and other GA aircraft flying some 28,000 movements (ie takeoffs and landings) per year at Farnborough airfield.

In support of its own operation, TAG wants to take control of an enormous area of airspace surrounding Farnborough by changing it from class G to class D airspace. Their proposals will fundamentally change the air space structure over a very large area of southern England.

TAG’s proposals will impact on some 240,000 movements per year currently flown safely by all traffic in the area affected. For a variety of reasons, a large proportion of those movements will be forced to operate outside the class D airspace.

If successful in their airspace grab, similar airfields with similar commercial aspirations will be emboldened to do the same in other parts of the country.

Please read on…

The very significant and detrimental implications of TAG’s proposals for a very wide cross section of GA and air sport mean that it is absolutely vital that the CAA undertakes a comprehensive, rigorous and evidence-based assessment of all aspects and impacts of TAG’s formal Airspace Change Proposal (ACP) before arriving at any decision. Our own review of TAG materials related to the ACP leads us to believe that there are a number of important issues that are unlikely to be adequately reflected by TAG in their submission to the CAA (submitted July 2015).

TAG states that the proposed airspace changes have been developed to:
a) Improve overall efficiency of the airspace
b) Increase safety
c) Reduce environmental impact

And will:
a) Increase predictability and efficiency of arrival and departure movements
b) Reduce the complexity of aircraft interactions
c) Encourage a route structure
d) Encourage GA to use Farnborough air traffic services

The implication is that TAG’s proposals will deliver direct and material benefits to the GA community by addressing safety and efficiency issues, and better enabling normal GA operations in the area around Farnborough. The clear reality is that TAG’s proposals are entirely self-serving; will impact, distort and limit the activities of a great many GA pilots; and will increase risk for those operating outside of the boundaries of the airspace being requested.

TAG’s proposals present neither a clear and accurate picture of, nor a valid case in light of certain key factors, ie;

Proportionality

TAG’s proposals are entirely disproportionate to its relative importance as a local airspace user:

  1. TAGs activities are primarily concerned with general and business aviation and none are associated with fare-paying passengers in a commercial air transport sense.
  2. TAG accounts for less than 10% of movements from non-CAT airfields in the area affected by their proposals. If one were to take into account levels of GA transit traffic in the area, their share of overall activity would reduce much further. These proportions will not change by much even if TAG achieves the growth in movement numbers that they believe possible. Indeed, TAG have publicly stated at various times that CAS is not required to enable safe operation at their maximum permitted number of movements – 50,000 per annum, approximately double their current level.
  3. A significant proportion, data suggests just under half, of Farnborough’s movements are related to crew-only positioning flights. When passengers are carried, there are, on average, in the region of 2 on board.
  4. TAG have admitted that the primary reason that it wants CAS is in order to allow for their in-bound and out-bound movements to take place with the absolute minimum of delay – though even here, TAG has never shown any analysis of current ‘delay’ levels.
  5. TAG have never acknowledged the disproportionate nature of their ACP, and have never shown any concern whatsoever for the impact of its proposals on the majority of other current users of local airspace.

Safety

  1. TAG have repeatedly stated that there are no specific or systematic, demonstrable safety-related issues that require direct action. Our own analysis of airprox and other official data concludes the same. As a consequence, there is no safety case for the introduction of CAS in the area.
  2. TAG’s insistence on the use of the adjective ‘tolerable’ to describe currently safety levels implies an unstable and unsatisfactory situation. TAG has never explained to us the basis on which it makes use of the term. In order to ensure that there is absolutely no misunderstanding of the safety situation around Farnborough, the term should be either translated into clearer, evidence-based – and, therefore verifiable, language – or disregarded should it appear in the ACP text.
  3. It is a matter of principle that airspace and policy changes should not result in a less safe situation. Independent analyses have shown that the majority of GA operators choose to avoid CAS. Similarly independent analyses also show that in the region of 70% of GA traffic elects to circumnavigate new CAS.
  4. The area of open FIR to the west of Farnborough, roughly up to the Solent CTA, is probably among the busiest area for GA traffic in the country – through a combination of very busy local airfields and high levels of transit traffic. There is an already recognised and well-studied GA ‘choke point’ in the area. Were TAG to receive the CAS it no doubt wants, risk levels for GA in those remaining areas of class G west of Farnborough would increase materially – both local GA activity and re-routing transit traffic would be consigned to a smaller area outside of CAS. TAG has been made aware of this fact repeatedly. It has never properly acknowledged it, and not directly or indirectly presented any worthwhile or workable mitigation measures.
  5. TAG’s suggestion that any potential problems could be addressed by encouraging GA pilots to seek an ATC service from Farnborough is naïve in light of the independent analysis referred to earlier. Just as concerning is its belief that it could field the necessary number of controllers and communication bandwidth to deal with the numbers of GA pilots otherwise affected by any new CAS.

At various points during the consultation process, we have been very concerned with the way in which TAG has presented its plans and proposals:

  1. Its presentation of environmental-related data, especially noise, was misleading and we had to invest a considerable amount of time in turning their plans into terms that could be properly understood by non-aviation stakeholders
  2. Movement growth projections, in common with many others the CAA has had to accompany ACPs, show an un-founded and un-justified ‘hockey-stick’ profile. TAG’s previous attempts at forecasting movement growth were shown to be unduly optimistic, and so their latest projections should be subject to detailed scrutiny. In any event, TAG has always stated that Farnborough can handle 50,000 movements per year without controlled airspace.

Summary

In summary, it is our strong belief based on rigorous and evidence-based analyses that:

  1. TAG’s proposals fail any reasonable test for the granting of CAS on critical safety and proportionality grounds.
  2. Their case also fails on the CAA’s own stated test for the efficient use of airspace.
  3. There do not appear to be any areas where TAG’s proposals might be usefully modified to the point where they might overcome our basic objections.

Can I read the ACP?

No. The ACP cannot be published as it is ‘commercially confidential’. The content of the ACP submitted to the CAA will only become public after the CAA has made a decision on whether to support the proposed change. Of course by then it is too late to amend anything. There is no appeal process on either the confidentiality clause or the CAA’s decision.

Do I need to do anything?

The BGA is working with it’s colleagues in GA and sporting and recreational aviation to ensure that the CAA and others fully understand the depth and breadth of opposition to TAG’s proposals.

The recent response by glider pilots to the TAG airspace consultation was outstanding. We may need further support by glider pilots as this issue unfolds. Please be prepared to stand up and be counted. Meanwhile, you might want to read the recently published S&G article describing the issues. And then remind yourself how to contact your MP.

We will ensure that clubs and pilots are appropriately informed as this critically important issue unfolds.

Further Information

Lasham Gliding Society

Southdown Gliding Club

CAA guidance on submitting an airspace change proposal.

TAG airspace information meeting presentation, 23 March 2014

The BGA’s 2014 response to TAG’s airspace change proposal consultation