Current proposals, how do they affect Burley & Menston?
None of the current proposals seek to amend the initial departure routes at LBA, rather what’s being considered are changes to the standard instument departure routes after air traffic has followed the existing NPR swathe. What’s interesting about the consultation is that, according to design principal 3 rural areas (those with the lowest population and AONB’s) are ranked more highly than disturbance to tranquil or rural areas like Burley and Menston. The straight off route, which would improve fuel efficiency, air miles travelled and minimise noise are not being considered.
Veiw the Stage 2a workshop proposals.
My response to these proposals; on behalf of Burley Parish Council and residents, are given below.
CAA website extracts.
In the latest version of the Response on Design Principles (Version 3) available on the CAA Airspace change portal Airspace change proposal public view (caa.co.uk) the following is published in response to the comments on Question 1 of the previous survey:-
“Taking all the quantitative feedback and the many welcome comments into account, the avoidance of new people appears to be a less significant issue; the majority of the respondents chose to reduce environmental impact. The ‘Environmental’ DPs (DP2 & DP3) capture the desire to ‘Seek options that reduce environmental impact and have greater efficiency.”
In the case of LBA, the NPRs are defined by the Local Authority under a Section 106 planning agreement as the swathe. The introduction of PBN in the future should improve the accuracy and compliance with the NPR and this ACP will look to address the Section 106 where necessary. Local communities and stakeholders will be kept updated throughout the CAP1616 process.”
The comment above in bold is repeated several times in the document, and this appears to prevent any change to the NPRs.
Leeds City Council Section 106 and NPRs.
In addition, there are the following comments published when LBA deal with the NPR/Section 106 issue alone: –
In response to varied feedback from the stakeholders surrounding the Section 106 agreement and associated NPRs, we engaged with Leeds City Council to gain some clarity on their position and ours. The response from Leeds City Council with respect to the NPRs is shown below:
‘Whilst in principle, we support a review of the NPR any changes put forward are likely to include a variation in the departure/arrival routes and/or the rate of ascent/decent of aircraft. Such changes are likely to result in some areas experiencing greater noise impacts than they do currently, with the potential for properties to experience significant impacts either in terms of a noticeable increase in decibel level and/or awareness of an aircraft noise that currently doesn’t exist. Conversely, some areas of the community will notice little change or could benefit from a reduction in noise intrusion.
In considering any proposals, there will be a need to take the net effect of any proposed changes into account in line with the design principals’ (contained within this report). Whilst any proposed changes to the NPRs and Section 106 are yet to be determined via stakeholder engagement and public consultation, Leeds City Council have made it clear that for any amendments to be considered a net benefit would need to be assessed’.
There is a door open for “any proposed changes to the NPRs and Section 106 ….to be determined via stakeholder engagement and public consultation,” however, I do not believe that this will occur through the ACP process. It appears that the ACP ignores any options that would involve consideration of a new NPR.
With this uppermost in mind, and decoupling the NPR issue from the ACP I wish to raise the following additional comments and suggestions:-
At this stage of the CAP 1616 process, communities are allowed to suggest alternative options which may not have been considered by the sponsor as part of its comprehensive list (including all radical options). Failure to consider these alternatives, or to justify why they are not achievable is contrary to CAP 1616, Appendix C, Para C28. It is therefore suggested that an alternative option is put forward that involves aircraft flying straight ahead after departure from RWY 32 before turning west or east subject to other airspace constraints. It should be acknowledged that this would require the NPR to be changed.
Could the Sponsor indicate when and how local communities can put forward alternative options.
Compliance to the CAP1616 process.
As part of the Stage 2 Gateway, the change sponsor is required to submit a formal Design Principles Evaluation (DPE) document and a separate Initial Options Appraisal (IOA) document. Based on the stakeholder presentation and high-level DP assessment, the below points are valid. However, as part of the Stage 2 Gateway, (currently set for 31st March 2023) the sponsors formal DPE/IOA documents may answer the points below. Failure to do so, in my view would be non-compliance with the CAP1616 process and as such the CAA should not allow it to progress into Stage 3.
A. How has compliance with DP2 been measured? To be able to determine a reduction in the number of people overflown, you should provide a form of measurement. E.g., If the baseline overflies 3,000 people and the option overflies 2,000 people it provides a clear indication of a reduction. No Baseline figures are apparent.
B. There is reference to an NPR route, but it is not clear to community stakeholders where this is. In future engagement, please include the NPRs on images for reference. There also appears to be no acknowledgement or reference that the NPR may have to change because of the ACP. Reference should be made to the Gatwick Route 4 ACP (Available on the CAA Airspace change portal) which appears to initially have failed to accurately present the NPR to stakeholders during engagement. In addition, the Gatwick Route 4 ACP appears to have failed at the Post Implementation Review (PIR) stage and the CAA’s decision to approve it was eventually quashed as part of a judicial review. Failure to comply with the NPR was one of the points that lead to this.
C. CAP 1616 Appendix B, Para B76 defines Tranquillity (for the purposes of ACPs) as AONBs and National Parks, however, there appears to be no mention of National Parks, specifically the Yorkshire Dales National Park in Design Principle description.
D. Define “community disturbance” this is not an official term. Air Navigation Guidance 2017 Para 3.3a and CAP1616 state that preference should be given to options that reduce the affect on people below 4,000ft, therefore priority should be given to compliance with DP2 rather than DP9.
E. The use of swathes as opposed to individual routes at Stage 2 does not provide community stakeholders with enough information to accurately determine whether the Design Principles can be met or not as it is difficult to understand the exact impacts over the ground of specific routes. In addition, if this approach was to be taken forward into CAP 1616 Step 2B, the Initial Options Appraisal (and associated baseline) would not enable communities to understand the impact of the options, contrary to the spirit of CAP1616 with regards to transparency and may also contradict CAP 1616 Para C29.
F. There is no clear methodology or rationale for the drawing of the swathes. To help community stakeholders understand the logic and/or rationale this should be explained in full.
G. LBA route options should seek to avoid areas of tranquillity, specifically:
-
- South Pennines Moors Special Site of Scientific Interest/ Special Area of Conservation (SSSI/SAC).
- South Pennines Moor Phase 2 Special Protection Area (SPA).
- European Protected Species (e.g., bats) in vicinity of Burnley in Wharfdale/Menston
- Little Skirtful of Stones (Scheduled Monument near Burley in Wharfdale)
(Failure to consider above locations when specifically stated is contrary to CAP1616 Appendix B, Para B76 and CAP1616 Appendix C, Para C28.
H. IAA, what is this? Does it not mean Area of Intense Aerial Activity? I realise that I’m being pedantic but ACPs have failed for issues such as this.
I. There is continual reference to a baseline, but this is not defined at all. Where is it? What year is it? What assumptions have been made to establish the baseline?
J. There is no definition of how Met/Partial/Not Met has been achieved to provide Red/Amber/Green colouring. E.g., What does Amber actually mean? Because of this, the logic behind why options that overfly populated areas have deemed as Amber rather than Red when assessing DP2 and/or DP3 is unclear. There are multiple instances of this throughout the presentation.
K. The Sponsor appears not to have considered “an informed view of the future” (CAP1616 Para E21) when setting the baseline. Area of Intense Aerial Activity for military aircraft are mentioned but this has not considered the closure of RAF Linton-on-Ouse and thus an “informed view of the future” appears not to have been considered.
L. In assessing DP6, there is acknowledgment that some options may conflict with inbounds. Why is this not considered/mentioned as part of DP1 as said conflicts may also compromise safety?
M. In accordance with Air Navigation Guidance 2017 and CAP1616, noise is paramount over track length/emissions below 4,000ft. Option 14SE-A should not be discounted on the basis that it has increased track miles if it provides benefits in terms of noise (as per DP2).
N. For arrivals, why have some options been assessed as Amber for DP2 when the DP specifically mentions the possibility of respite. “Different communities to be overflown” implies a degree of respite for those who are usually overflown (i.e., respite). As such, the assessment of DP2 for some arrivals appears to contradict DP2.
Yours sincerely,
Bob
Recently published guidance Stage 2.
Attached is recently published guidance from the CAA on Stage 2 of the CAP1616 process and note the content on the last page. Recently published Stage 2 guidance.
This clearly states that if stakeholders identify themselves (I have) and “ if there is information that may inform the development / rejection of the options ( straight ahead is a development) the sponsor may elect to engage with those stakeholders during stage 2” this could also be in stage 3.
I will press to turn the ‘may’ into a shall for the straight ahead proposal.
Additionally “ the CAA will look for evidence that the change sponsor has captured and taken into account the views of stakeholders and that they have set out how decisions they have taken relate to stakeholder feedback”
This is good news and I’m pushing LBA again to give details of how this evidence will be gathered and taken into account.
This is in response to letters to the CAA anmd LBA which are shown below.
Dear Sir/Madam,
Re:LBA ACP-2021-026
Further to correspondence in response to your Design Principles Consultation and the subsequent responses posted on the CAA ACP portal, and in line with the very positive comments from Damien Ives, Operations Direct, in a letter of 19th November 2020 where it was stated:
“We will be reviewing all options (for the initial departure routes from Runway 32) available to us at this stage, we would not rule out a straight-ahead departure on Runway 32” and in the spirit of a collaborative approach to ensuring a positive outcome for local residents and LBA alike, I offer the following for consideration.
You will of course be aware, that airspace change sponsors as part of the Future Airspace strategy – North (FASI-N) programme are required to follow and abide by the process defined within CAP 1616. As an impacted stakeholder, I would like to highlight some key points within CAP 1616 that enable stakeholder views to be fully considered, which in line with the spirit of CAP 1616, focusses on transparency.
I refer to CAP 1616, Appendix E, paragraph E16 which states:
“As part of development options, the change sponsor should try to:
- Look at examples where a similar issue has been addressed
- Identify the full range of interventions available
- Develop and consider radical options – these may not become a formal appraisal but may help test the parameters for feasible solutions.”
I believe that the current stage 2 documentation fails to ‘consider all radical options’ such as the consideration of options which fly straight ahead after departing Runway 32, avoiding Burley in Wharfedale. I understand that this may would likely include an amendment of the Runway 32 Noise Preferential Route (NPR), which is outside the scope of CAP 1616, but nevertheless should be considered in accordance with Paragraph E16 above. I believe that LBA should engage with the appropriate local authorities to investigate amendments to the NPR as a direct result of this airspace change.
Additionally, I refer to CAP 1616, Appendix C, paragraph C27 which states:
“As the change sponsor is required to design options that meet the design principles developed during Stage 1b, they must seek feedback from key stakeholders to test their hypotheses. The design principle evaluation should be signposted for stakeholders as this sets out how the design options have responded to the design principles. Bilateral meetings and smaller challenge groups are likely to be sufficient to ensure that stakeholder concerns have been properly understood and accounted for in designing options.”
During the recent stakeholder feedback, I specifically highlighted several points related to the paragraph above and failure to consider these points, I believe, would be a clear and obvious disregard for the CAP 1616 process. In my opinion, your approach seems vague, and will not allow stakeholders to understand how proposed designs will respond to the design principles, which is contrary to paragraph C27 above. Leading on from this, the swathe methodology is so vast that is difficult to determine the ‘key impacted audiences’, simply because of the size of the area. The continued use of this methodology, I believe is contrary to CAP 1616, Appendix C, paragraph C29 which reads:
“Within the development of the options appraisal during Step 2B, the key impacted audiences will be far more clearly identified. This insight should be used to inform the development of the consultation strategy in Stage 3.”
In addition, CAP 1616, Appendix C, paragraph C28 states:
“In judging the efficacy of engagement, the CAA will not look for discussion on the pluses and minuses of each option – that should come during consultation – but will seek evidence stakeholders are content that their views have been captured and taken into account by the change sponsor. The size and nature of meetings should dictate whether formal record keeping and minutes are necessary (in any situation such notes may be helpful for sponsors and stakeholders), but at a minimum sponsors must set out how decisions they have taken relate to stakeholder feedback.”
Based on your use of swathes, at this stage, I am unable to conclude that I or in fact yourselves can be ‘content that [my] views have been captured’ due to the ambiguity and vagueness of the proposed options. I therefore request that more detail is provided into the exact nature of the options being proposed, moving away from the large swathe concept. I am aware of other FASI change sponsors who have provided stakeholders with detailed designs created by an Approved Procedure Design Organisation (ADPO), which are fully compliant with the regulatory standards (e.g., ICAO PAN-OPS) and consider the views of community stakeholders. These change sponsors have presented detailed ‘lines in the sky’ as opposed to swathes, which in my view, provides a better basis for community stakeholders to understand the impact of a proposed option.
Additionally, I refer to previous correspondence and changes faced in your last ACP, of replication to the current NPR with PBN principles. I am aware that several airlines have attempted to “unofficially” replicate the 32-departure route which have not improved the inconsistencies in track keeping, as the residents of Burley in Wharfedale and Menston will attest.
Once again in the spirit of Mr Ives, where taking “full offer of our offer of support” is relayed, and the point of inconsistency in flying the current NPR in mind, below is a rudimentary diagram of how a straight-ahead departure from Runway 32, that incorporates a new NPR and swathe and connects to ALL the options that deliver the stated Runway 32 Design Objectives might look like:
Serious consideration and engage discussion of this, I believe will assist in delivering the stage 2 requirement to ‘consider all radical options.’
I am of course fully aware that any such revision to the NPR and Swathe comes under the jurisdiction of Leeds City Council, and they are copied into this correspondence. They have indicated in their response to the design principles that they would be willing to look at an amendment, subject to assessment of the net position/benefit, on people change and current noise profiles. To positively progress this, I would like to explore the possibility of a joint approach to having this assessment undertaken, for my proposal, with a view to delivering further options that could be considered in the CAP 1616 process.
Subject to the outcome of this assessment, and subject to the availability of any detail/technical documentation of previous work, that could be used or form part of new NPR/SID design, I would be keen to work collaboratively on using an Approved Procedure Design Organisation (ADPO), to design fully compliant ICAO PAN-OPS departures from Runway 32 that incorporate a straight-ahead element.
Changes to the NPR and section 106 ageements.
Although Bradford Council have responded to the Stage 2 consultation, I understand that from recent dialogue, that they didn’t raise material breaches in the consultation process. That having been said, it’s quite clear that they haven’t carried out sufficient research into the matter. I have indicated to senior planners that I’m prepared to take a colloborative approach on CAP1616. Several weeks have now elapsed, and I have yet to have a face-to-face with the planning team.
