July 12, 2019
AEF has responded to the Civil Aviation Authority’s consultation ‘Airspace change: a decision-making process for PPR (planned and permanent redistribution of air traffic) proposals’ following the DfT’s instruction to develop a new process for these changes. The consultation closed on 7th July.
Previously operational changes to existing airspace (or PPR) would not have required approval from the CAA but, recognising that such changes can have significant environmental impacts, Government has asked the CAA to introduce a decision-making process which will take effect for all qualifying PPRs from this November.
AEF broadly welcomes the new process, but we have a number of specific concerns about the proposals.
1. The new process appears to rely entirely on Air Navigation Service Providers voluntarily bringing PPRs forward to the CAA, based on information that they privately hold, with no comeback if they fail to identify a change that could be a PPR. The CAA has no statutory function to require the ANSP to go through the PPR decision-making process retrospectively if it later transpires that a change, once implemented, subsequently meets the qualifying criteria.
It’s difficult to see how an ANSP would feel motivated to go through the process, if this is the case. It leaves a gaping hole in the process.
2. As the CAA is not under any obligation to reduce noise overall, and the criteria for a “relevant PPR” are quite narrowly drawn, changes that could also increase noise impacts significantly fall outside of its scope. Changes that are made to airline operations, or occurring due to “natural growth”, or expansion wil be excluded. Similarly, various kinds of cumulative impacts are either poorly addressed, or not addressed at all.
Additionally, a relevant PPR will include changes to written operational procedures anticipated to increase air transport movements using a Standard Instrument Departure (SID) by at least 5000 movements per year. Not only, in AEF’s view, is the increase threshold pretty high – if there’s more than one SID, departures will be counted separately, and the possible cumulative effect of this is specially excluded.
Meanwhile, the CAA proposes that the “knock-on effects” – where one PPR proposal prompts a PPR at a neighbouring airport – should be treated as a package, but acknowledge that there is a problem with this:
“A change elsewhere may have knock-on effects that requires changes in air traffic control operational procedure at a different airport and therefore potentially by a different air navigation service provider.”
The CAA proposes to take a “pragmatic approach” and asks for suggestions on how the issue would be “managed effectively.” Meanwhile, there is no mention at all of the cumulative noise impacts on communities overflown by more than one airport.
3. The CAA states that “The number of stakeholders potentially affected by a proposed PPR change will determine how extensive a consultation must be.” Noise impacts may, however, be significant in rural areas where ambient noise is relatively low, even if population numbers are small. The CAA should confirm that such communities will need to be effectively consulted.
Our full consultation response is available here.