Leeds Bradford Airport ACP
Leeds Bradford Airport (LBA) has launched a consultation on proposals for what it describes as;
- New arrival procedures (including changes implemented by FASI North associated with LBA)
- New airspace structure
- GNSS approach procedures that replicate the current approach procedures
- PBN departure procedures that replicate the current departure routes
The closing date for consultation feedback is Sunday 5th November 2017.
On receipt of comments, airspace change 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 LBA receives a significant number of responses from opponents to the proposal.
To help glider pilots and clubs to develop their own responses, the locally based team of BGA and BHPA pilots with others including the BGA airspace committee who are developing a response to the consultation, have provided the following summary information.
How To Respond – Four Steps
- Read the consultation on the LBA website
- Read our guidance below
- Consider and write your response – please be polite
- Send your response to firstname.lastname@example.org and to Lbaconsultation@ospreycsl.co.uk
Risk based and proportionate airspace restrictions
It is vitally important that regulation of airspace is risk based and proportionate taking into equal consideration the needs of all airspace users. The BGA is committed to supporting that approach. Gliding has no objection in principle to the use of controlled airspace where justified, proportionate and necessary for the safety of Commercial Air Transport passengers. The BGA does not oppose all proposed airspace changes. We are vigorously opposed to the LBA airspace change proposal vecause it fails to meet the justified, proportionate and necessary criteria.
LBA’s driver for the proposal is to expand its operations. Yet they appear unwilling to commit to the necessary infrastructure works. They state ground facilities will be expanded “as and when required”. However, our experts note that without the infrastructure improvement any expansion will be highly problematical. In short, there is no properly researched airport development plan.
LBA has failed to meaningfully consult despite the opportunities to do so. LBA has failed to form/facilitate any focus groups as described in the CAA’s Airspace Change Procedure publication CAP 725. As a consequence, LBA has failed to understand the needs of the soaring community and this is reflected in the very short and misleading para in the proposal on soaring.
Over the last 3 years, LBA’s rationale and justification for the proposal has gone from ‘expansion of commercial operations’, to ‘environmental grounds’, to ‘mitigating the withdrawal of obsolete ground based navigation aids’, to ‘fitting in with the FASI North airspace project’, and finally, to ‘current procedures can lead to unsafe situations in flight and the CAS changes are required to ensure passenger safety’. This last statement probably follows advice to LBA on how to ensure a proposal has the best chance of success. However, the statement is not supported with compelling evidence (see ‘safety’ below).
LBA has produced 2 versions of the proposal and an addendum, with the latter two arising from mistakes in the original proposal identified by BGA and BHPA pilots, ie, inaccurate CTA/CTR coordinates and Noise Preferential Routes issues.
LBA and their consultants, Osprey, know that the CAA is unwilling or unable to get involved with airspace development and planning. CAA will simply accept or reject the proposal. So LBA and Osprey are relying on the fact that CAA will not get involved, regardless of the impact on others. Your comments should include a statement that current CAA airspace policy is failing to address the safety needs of the majority of airspace users operating outside of controlled airspace.
There is no compelling safety case for LBA’s proposals.
LBA’s proposals increase risk for pilots operating outside the proposed controlled airspace.
The proposal cites in Annex A a number of ‘safety events’ as reasons for the expansion. Yet most are ‘level busts’ and none involve gliders.
The proposed lower bases of controlled airspace will increase the risks to GA including risk of landouts by soaring aircraft
The proposed changes will result in more dangerous ‘choke points’ for GA and soaring pilots operating outside and around the controlled airspace. LBA’s consultants, Osprey, admit to not being concerned about safety outside the proposed controlled airspace.
Increasing Air Traffic Levels?
Passengers numbers have increased but are offset by declining movement numbers. Future passenger growth is based on 2013 ‘high end’ DfT forecasts and fail to take into account Brexit impact, economic uncertainty and the fragility of the airline industry
These have been grossly exaggerated and disproved by our experts.
LBA cites the use of “obsolescent, conventional ground-based navigation beacons to PBN routes based on satellite data” as justification for the proposal. This has been disproved by our experts.
Withdrawal of DVOR beacons?
Our expert’s understanding is that current procedures can continue to be followed in existing airspace irrespective of whether DVORs are withdrawn. Arguments about the withdrawal of conventional navigation aids are, thus, a red-herring, as modern GPS tracking can directly replace previous routings and is more accurate.
Air Traffic Control Procedures and Workload?
LBA cites any future growth may result in ATC overload. The solution is of course to employ more controllers, rather than impose restrictions on other airspace users. LBA will be aware that recruiting controllers is currently difficult. The commercial aviation industry has failed to ensure an adequate supply line of trained and qualified people.
If one of the supposed primary drivers for airspace and procedural change is safety, why will 18 blocks of airspace comprising 3 CTR’s and 15 CTA’s be safer than 4 blocks of current LBA Class D? It is well known that airspace busts are more likely to occur in complex airspace constructs.
Why is it necessary to have the base of controlled airspace as low as 3000’/3500’ between 15nm and 20nm out from the airport? Operating at this level is inefficient and significantly increases the noise footprint. Crucially, neither airline operators nor their pilots would want to be that low that far out from the airport.
Impact on Gliding and Soaring?
The negative ipacts are very severe for Burn & Rufforth in particular, given their proximity to the expanded CTA 9, as both clubs generally operate to the west of their sites given the prevailing winds. Similar problems for Sutton Bank re their flights into the Pennines and also cross-Pennine flights for all Yorkshire based clubs.
Training and sport gliding activity by thousands of pilots of all ages will be significantly impacted.
There will be severe limitations for wave flying given the new CTA 9, which encompasses a wave soaring area.
The narrowing of the Upton Corridor will prevent north/south transits via this route and force traffic down the already congested east side of RHADS, which is also a much less favourable area for soaring, with its inherent sea breezes and flat, low-lying land. This is a major negative impact on all UK cross country pilots.
The proposals will force soaring traffic further into the already heavily congested Vale of York area and other choke points.