Airspace Change Proposals (CAP1616) at LBA

LBA Stakeholder meetings – Burley in Wharfedale.

The Stakeholder meeting covered expansion at LBA.

The Airspace Change Program (ACP) has not been discussed with the community.

ACP Summary

The request to Stakeholders is basically to deal with the issues highlighted by the CAA in the failure of the CAP 1616 Stage 2 Gateway. The ACP as with all others, is focused by the CAA on the CAP 1616 process which is the way in which the ultimate decision will be justified.

The reasons for the gateway failure where: –

1. Failure to produce a comprehensive list of airspace change design options

• • The CAA has not been able to clearly determine how the change sponsor developed the stated comprehensive list of options.
  • The change sponsor did not clearly describe the do-nothing and do-minimum options.

2. Failure to engage with relevant stakeholders to explore those options to the CAA’s satisfaction against the requirements in CAP 1616 Appendix C.

CAP1616 Appendix C, as referenced in the context of airspace change proposals in the UK, relates to the regulatory process for changing airspace design, including community engagement requirements. Specifically, it outlines the consultation and engagement process that change sponsors must undertake. This includes identifying stakeholders, sharing design options, providing engagement evidence, and demonstrating how feedback has been considered. The appendix is part of the Civil Aviation Authority (CAA) guidance on the airspace change process. 

• • The change sponsor has not clearly and consistently demonstrated how decisions it has taken relate to stakeholder feedback.

3. Failure to produce a design principle evaluation that the CAA has accepted, showing how its design options have responded to the design Principles. (See attached and below)

• • The change sponsor did not produce a fair and consistent Design Principle Evaluation (DPE) nor provide a clear explanation as to how options have been reviewed against the criteria, taking into account the language for each design principle.
  • The change sponsor did not present a clear or consistent discounting.

4. The change sponsor must have produced an Initial options appraisal.

• • The change sponsor did not present robust rationale and evidence to support the discounting methodology followed in the initial options appraisal.
  • The change sponsor must provide a qualitative statement on the potential impact of each option on safety.

The documents presented are an attempt to address the feedback from the CAA and provide further clarification where needed as well as identifying specific topics that require additional stakeholder engagement. LBA have also introduced an extra eastern arrival transition option for Runway 32.

This request for feedback focuses on the detail of how the options have been evaluated however it does give us the opportunity to comment again on what is being presented.

Clarification and Updates

LBA have, apparently due to stakeholder feedback revised the format of the presentation of the departure options to present a clearer and less cluttered depiction of departure swathes. The options themselves have not changed, and a reiteration of our previous comments is perhaps appropriate.

RW32 – New Option A-Potential Respite Route

They again, in effect are saying (without saying it) that the existing Runway 32 departure route that squeezes between Menston and Burley in Wharfedale will continue to be used!

The mitigation they propose is a route that turns left much earlier than the current one and routes between Guiseley and Menston and once clear of houses in the Bradford Golf club area, route to the Network joining points.

This had been labelled a Potential Respite Route with the objective of reducing noise nuance by ’sharing the load’ between this new route and the existing one.

There is no indication as to how often and in what circumstances this new route would be used. This detail MUST be forthcoming for stakeholders to be able to comment. If this is not forthcoming my opinion is that LBA again will not have satisfied the CAA criteria 2 above and shown how they have consistently demonstrated how decisions it has taken relate to stakeholder feedback.

In light of this, from the CAA Stage failure notification

1. Failure to produce a comprehensive list of airspace change design options.

• • The CAA has not been able to clearly determine how the change sponsor developed the stated comprehensive list of options.

There is an opportunity to push LBA to insist that, if the New Option A is only to be used as respite from the exiting route, they produce a comprehensive Design Principle Evaluation (DPE) of the existing route for comparison. This DPE should use their new definitions for: –

Qualitive Assessment – Meets; Limits or has the potential to reduce the number of people overflow.

Qualitive Assessment – Has the potential to reduce CO2 emissions.

Qualitive Assessment – Meets ; Fuel efficiency is optimal without an adverse impact on local communities.

And using all the other Criteria.

I would hope that should this be undertaken the advantages on the straight-ahead departure route could be re-tabled at the Stage 3 consultation phase.

In LBA’s assessment using the new DPE criteria this option has gained amber assessments (partially meets) for Operational Cost and Airspace Modernisation Strategy (AMS) Realisation.

We should insist that the impact of these going from Green to Amber is made transparent.

Runway 32 New Option B – Potential Night Route

This remains a further attempt to soften the blow on the existing route being retained and on the face of it has merit. It takes aircraft on an initial right  turn and round to the North of Otley before joining the routes that are currently used, they will miss Burley in Wharfedale entirely. Aircraft will join the network routes at a much higher level due to the extra track miles introduced by the initial right turn. It seems to be being rejected as a regularly used day route due to extra track miles but is being offered as night mitigation.

There remain 2 points on this.

• Are they committing to using this at all times? This question needs answering now.
• And if so, are we talking about this being used in the current published ’Night” hours of 2300-0700?

In their assessment using the new DPE criteria this option has gained a new amber assessment (partially meets) for Airspace Modernisation Strategy (AMS) Realisation.

 

We should insist that the impact of this going from green to Amber is made transparent.

Runway 32 New Option C

This route is advertised as a respite from the existing route OR a night route so the comments/questions from above remain applicable.

‘There is no indication as to how often and in what circumstances this new route would be used.’

Aircraft on this route aircraft would miss Burley in Wharfedale.

In their assessment using the new DPE criteria this option has gained 4 new red (Does not meet) assessments for Noise, Emissions and Air Quality, Operational Cost and AMS Realisation. There is also a new amber assessment (partially meets) for Airspace complexity.

We should insist that the impact of these assessment changes are made transparent. This move in the new assessments however will probably mean this option will be dropped.

Runway 32-New Option D

This is a proposed Night only route and turns right instead of left at Menston. It then continues right to come back over the airport.

This seems to be a halfway house type offering as noise will still be experienced in the Menston and Burley in Wharfedale area.

Again, conformation of the times it would be in used would be needed.

In LBA’s assessment using the new DPE criteria this option has gained 2 new red (Does not meet) assessments for Noise and AMS Realisation. There is also a new amber assessment (partially meets) for Airspace Complexity.

We again should insist that the impact of these assessment changes are made transparent.

Runway 32 New Option E

This is a proposed Night only route and turns right instead of left at Menston. It then routes north before turning left to join the network routes.

This again seems to be a halfway house type offering as noise will still be experienced in the Menston and Burley in Wharfedale area.

And again, conformation of the times it would be in used would be needed.

This option picks up a new Amber assessment for AMS Realisation.

Conclusion

All in all, the new assessment criteria seem to have added doubt as to the legitimacy of most of the New Runway 32 Options and we should highlight this and insist on another option with Straight ahead past Menston and Burley in Wharfedale is included.

The CEO has said that he would support an option with this routing, and we should make the point that the increase in Red and Amber assessments set out above are “in “the CAA CAP 1616  ACP process and so this update allows him to instruct his team to have a straight-ahead option incorporated.

The main feedback request is on whether the DPs have been correctly applied to the new options. We should respond with a “yes” with the following comment.

In several of the assessment changes the comment appears that the colour coding has changed “Due to reassessment by Subject Matter Experts (SME) at LBA.”

It is legitimate when we consider the impact that this major change will have on the lives of many thousands of people overall that the qualifications and impartiality of the “SME” is made transparent.

Turning to the New Runway 32 Arrival route it requires new Controlled Airspace (CAS) to the East and SE – so we should contend the Straight-ahead option that turns right after Otley should be reinstated and assessed using the new DPEs.

In addition, most of the arrival options require an increase of CAS to the north of the existing structure which could be also used to accommodate Runway 32 straight-ahead routes, and these should be delivered as options for assessment.

Regards,

Bob Felstead